Information Notice 1994-23, Guidance to Hazardous, Radioactive and Mixed Waste Generators on the Elements of a Waste Minimization Program
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D.C. 20555 March 25, 1994 NRC INFORMATION NOTICE NO. 94-23: GUIDANCE TO HAZARDOUS, RADIOACTIVE AND
MIXED WASTE GENERATORS ON THE ELEMENTS OF A
WASTE MINIMIZATION PROGRAM
Addressees
All NRC Licensees.
Purpose
The Nuclear Regulatory Commission is issuing this information notice to inform
addressees subject to regulation under the Resource Conservation and Recovery
Act (RCRA) of the Environmental Protection Agency's (EPA's) interim final
guidance to assist hazardous waste generators and others comply with the waste
minimization certification requirements of RCRA sections 3002(b) and 3005(h).
These licensees are strongly encouraged to contact the appropriate EPA or
State hazardous waste authority to determine if their activities are subject
to the requirements of RCRA sections 3002(b) and 3005(h).
In addition, this interim final guidance may be useful to radioactive Waste
generators who wish to develop or enhance a program to minimize the generation
of radioactive and/or mixed waste (waste that contains both radioactive
material and hazardous waste) at their facilities. It is expected that
recipients will review this information notice for applicability to their
activities and consider actions, as appropriate, to minimize waste generation.
However, suggestions contained in this information notice are not new NRC
requirements and no specific action nor written response is required.
DescriDtion of Circumstances
On May 28, 1993, EPA published, in the Federl Reister (58 fR 31114), interim
final guidance on what EPA would consider to constitute a "program in place"
for compliance with the certification requirements of RCRA sections 3002(b)
and 3005(h) (see Attachment 1). Section 3002(b) requires generators of
hazardous waste to certify, on their hazardous waste manifests, that they have
a waste minimization program in place to reduce the volume and quantity or
toxicity of such waste to the degree determined by the generator to be
economically practicable. Section 3005(h) requires owners and operators of
facilities that receive a permit for the treatment, storage, or disposal of
hazardous waste on the premises where such waste was generated, to make the
same certification no less often than annually. EPA issued this interim X7J7§ /at
guidance to fulfill a commitment it made in a report to Congress entitled,
- .1 o__cf oA 9 qo03 k9403160172 > PD B IVIJ;
\opaD' iAj# Si I
I .
IN 94-23 March 25, 1994 'The Minimization of Hazardous Waste," (EPA/530-SW-86-033) to provide
additional information to generators on the meaning of the certification
requirements placed in RCRA.
Discussion
In the past, the predominant practice used by facilities generating hazardous
waste has been lend of pipe" treatment or land disposal of the waste.
Congress established, in 1984, that the reduction or elimination of hazardous
waste generation at the source (i.e., pollution prevention) should take
priority over the management of hazardous wastes, after they have been
generated. In 1990, Congress further clarified the role of pollution
prevention by passing the Pollution Prevention Act (P.L. 101-508, 42 U.S.C.
13101, et seq.). In that Act, Congress stated that the national policy of the
United States is that pollution should be prevented or reduced at the source
whenever feasible; pollution that cannot be prevented should be recycled in an
environmentally safe manner whenever feasible; pollution that cannot be
prevented or recycled should be treated in an environmentally safe manner
whenever feasible; and disposal or other release into the environment should
be employed only as a last resort, and should be conducted in an
environmentally safe manner.
The Low-Level Radioactive Waste Policy Amendments Act of 1985 established a
series of milestones, penalties, and incentives to ensure that States make
adequate progress toward being able to manage their low-level radioactive
waste. However, to date, progress in developing additional radioactive waste
disposal capacity has been slow. As such, some NRC licensees may be forced to
store radioactive waste until this disposal capacity is developed. Since the
early 1980's, NRC has issued guidance for those licensees that are
contemplating storing their waste (see Attachment 2). In addition to
developing storage capacity for their radioactive waste, some licensees may
find that they can significantly reduce the amount of radioactive waste they
generate and the cost of such waste by implementing effective waste
minimization programs.
The attached EPA guidance presents information on developing a comprehensive
program to reduce hazardous waste that, in many situations, may be applicable
to radioactive waste as well. The guidance discusses the elements of a waste
minimization program and the benefits of the development and implementation of
a successful program. Elements of a successful plan include: top management
support; characterization of waste generation and waste management costs;
periodic waste minimization assessments; appropriate cost allocation;
encouragement of technology transfer; and program implementation and
evaluation. The benefits of waste minimization include a potential reduction
in waste disposal costs; reduction in the need for waste storage; reduction in
worker radiation exposure; and improvement of the facility's public image.
- -'
IN 94-23 March 25, 1994 In addition to the programmatic elements outlined in EPA's guidance, NRC
believes that licensees may further reduce the amount of radioactive waste
requiring ultimate disposal in a licensed low-level radioactive waste disposal
facility by employing procedures already allowed under NRC's regulations.
These procedures include volume reduction by segregation, consolidation, compaction, extraction, or greater reliance on decay-in-storage in accordance
with 10 CFR 20.2001. NRC believes that licensees can reduce their waste
disposal costs and improve the manner in which they manage their waste by
instituting a comprehensive waste management program that reduces the amount
of waste at the source, recycles waste that must be produced, treats waste
that cannot be prevented or recycled, and relies on disposal or other releases
into the environment only as a last resort.
This information notice requires no specific action or written response. If
you have any questions about the information in this notice, please contact
the technical contact listed below.
John T. Greeves, Director
V Division of Low-Level Waste Management
and Decommissioning
Office of Nuclear Material Safety
and Safeguards
Technical contact: Dominick A. Orlando, NMSS
(301) 504-2566 Attachments:
1. EPA Guidance to Hazardous Waste Generators
on the Elements of a Waste Minimization Plan
2. List of NRC Information Notices and Generic
Letters on the Storage of Radioactive Waste
3. List of Recently Issued NMSS Information Notices
4. List of Recently Issued NRC Information Notices
Attachment 1 IN 94-2 March 25, 1994 Friday
May 28, 1993 Part VII
Environmental
Protection Agency
Guidance to Hazardous Waste Generators
on the Elements of a Waste Minimization
Program; Notice
9
. % Attachment 1 IN 94- 23 -
March 25, 1994 31114 Federal Register / Vol. 58, No. 102 I Friday, May 28. 1993 I Notices
ENVIRONMENTAL PROTECTION DATES: EPA urges all interested Parties generators on the meaning of the
AGENCY to comment on this interim final certification requirements placed in
guidance, in writing. by July 27. 1993. HSWA
[EPA 530-Z-43-07; FRL-465-5 ADDRESSES: The public must send an Additionally, EPA published in the
original and two copies of their Federal Register, on January 26, 1989 Guidance to Hazardous Waste (54 FR 3845). a proposed policy
Generators on the Elements of a Waste comments to: RCRA Information Center statement on source reduction and
Minimization Program (OS-305), U.S. Environmental
Protection Agency, 401 M Street, SW., recycling. This policy commits the
AGENCY: Environmental Protection Washington, DC 20460. Agency to a preventive strategy to
Agency [EPA]. Place the docket number F-93- reduce or eliminate the generation of
ACTION: Interim final guidance. WMIF-FFFFF on your comments. environmentally-harmful pollutants
Commenters who wish to submit any which may be released to the air, land.
SUMMARY: EPA is committed to a information they wish to claim as surface water or ground water. We
national policy for hazardous waste Confidential Business Information must further proposed to incorporate this
management that places the highest submit an original and two copies. preventive strategy into EPA's overall
priority on waste minimization. To this under separate cover, to: Document mission to protect human health and the
end, EPA is today providing interim Control Officer (OS-312), Office of Solid environment by making source
final guidance to assist hazardous waste Waste, U.S. Environmental Protection reduction a priority for every aspect of
generators and owners and operators of Agency, 401 M Street, SW., Washington, Agency decision-making and planning, hazardous waste treatment, storage, or DC 20460. with environmentally-sound recycling
disposal facilities to comply with the FOR FURTHER INFORMATION,
CONTACT
- as a second and higher priority over
waste minimization certification Becky Cuthbertson, Office of Solid treatment and disposal. Today's notice
requirements of sections 3002(b) and Waste, 703-308-8447, or the RCRA is an important step in implementing
3005(h) of the Resource Conservation Hotline, toll free at (800) 424-9346. TDD this policy with respect to hazardous
and Recovery Act (RCRA), as amended (800) 553-7672. wastes regulated under RCRA.
by the Hazardous and Solid Waste EPA has taken the January 26, 1989 Amendments of 1984 (HSWA). 42 SUPPLEMENTARY INFORMATION:
proposed pollution prevention policy
U.S.C. 6922(b) and 6925(h). Guidance to Hazardous Waste statement two steps further By
Section 3002(b) requires generators of Generators on the Elements of a Waste publishing a 'Polluton Prevention
hazardous waste to certify on their Minimization Program Strategy" in the February 26, 1991 hazardous waste manifests that they Federal Rgister (56 FR 7849). and by
have a waste minimization program in L.
Purpose
proposing the creation of a program that
place. Section 3005(h) requires owners The purpose of today's notice is to would encourage and publicly recognize
and operators of facilities that receive a provide guidance to hazardous waste environmental leadership, and would
permit for the treatment, storage, or generators and owners and operators of promote pollution prevention in
disposal of hazadous waste on the hazardous waste treatment, storage, and manufacturing In the anuary 15, 1993 premises where such waste was disposal facilities on what constitutes a Federal Register (58 FR 4802)
generated to make the same certification waste minimization "program in place,"
no less often than annually. in order to comply with the certification H. Background
EPA believes waste minimization requirements of sections 3002(b) and A. Statutory
Intent
and Requirements
programs should incorporate, in a way 3005(h) of the Resource Conservation and Definition of Waste Minimization
that meets individual organizational and Recovery Act (RCRA), as amended
needs, the following basic elements In the past, the predominant practice
by the Hazardous and Solid Waste used by manufacturing, commercial and
common to most good waste Amendments of 1984 (HSWA), 42 minimization programs: (1) Top other facilities that generate hazardous
U.S.C. 6922(b) and 692(h). Section waste has been end of pipe treatment
management support; (2) 3002(b) requires hazardous waste
characterization of waste generation and generators who transport their wastes or land disposal of hazardous and
waste management costs; (3) periodic nonhazardous wastes. While this
off-site to certify on their hazardous approach has provided substantial
waste minimization assessments; (4) waste manifests that they have programs
appropriate cost allocation; (5) progress in improving the quality of the
in place to reduce the volume or environment tere are limits as to how
encouragement of technology transfer, quantity and toxicity of hazardous waste
and (6) program implementation and much environmental improvement can
generated to the extent economically be achieved using methods which
evaluation. Thus, generators and owners practicable. Certification of a waste
and operators of hazardous waste manage pollutants after they have been
minimization "program in place" is also generated.
treatment, storage, and disposal required as a condition of any permit
facilities should use these elements to With the passage of HSWA in 1984, issued under section 3005(h) for the Congress established a significant new
design multimedia pollution prevention treatment, storage. or disposal of
programs directed at preventing or policy concerning hazardous waste
hazardous waste at facilities that management. Specifically, Congress
reducing wastes, substances, discharges generate and manage hazardous wastes
and/or emissions to all environmental declared that the reduction or
on-site. This guidance fulfills a elimination of hazardous waste
media-air, land, surface water and commitment made by EPA in its 1986 ground water. generation at the source should take
report to Congress I entitled The priority over the management of
EPA is publishing this guidance as an Minimization of Hazardous Waste (EPA/
interim final version, and solicits hazardous wastes after they are
530-SW-86-033. October 1986) to generated. hiparticular, section 1003(b),
further public comments on it. provide additional information to
However, until the guidance is 42 U.S.C. 6902(b), of RCRA the Congress
finalized, persons should use It in declares it to be the national policy of
151 FR 4683 (Dember 11. t986). Notice of the United States that, wherever
developing their waste minimization Avaellbility of the report to Congress on waste
programs in place. feasible, the generation of hazardous
Attachment 1 IN 94-23 March 25, 1994 311115 Federal Register / Vol. 58, No. 102 / Friday. May 28, 1993 / Notices
onventlonal waste management
Iconventional waste management
.
waste is to be reduced or eliminated as raw materials. and improvements In
expeditiously as possible. Waste that is housekeeping. maintenance, training, or Mactivities do not constitute waste
inventory control. minimization.
nevertheless generated should be Treatment for the purposes of
treated, stored, or disposed of so as to EPA believes this definition is
destruction or disposal is not part of
minimize the present and future threata appropriate for use in identifying waste minimization, but is, rather, an
to human health and the environment.* opportunities for source reduction
under RCRA. activity that occurs after the
In this declaration, Congress for waste minimization
established a clear national priority for The second category, environmentally opportunities
sound recycling, is the next preferred have been pursued. When source
eliminating or reducing the generation reduction and recycling opportunities
of hazardous wastes. At the same time. alternative for managing those
at are exhausted to thse extent
however, the national policy recognized pollutants which cannot be reduced hazardous economically practicable, EPA has set
that some wastes will "nevertheless" be the source. In the context of
generated, and such wastes should be waste management, there are certain standards for the treatment, storage and
managed in a way that "minimizes" practices or activities which the disposal of hazardous wastes. Treatment
hazardous waste regulations define as may be either thermal (i.e.,
p resent and future threat to human for incineration), chemical, or biological, health and the environment. "recycling." The definitions
In this. Congress further clarified the materials that are "recycled" are found especially for organic hazardous wastes.
role of pollution prevention in the in Title 40 of the Code of Federal Where destruction methods for
nation's environmental protection Regulations, S 261.1(c). A "recycled" treatment are not available or
scheme, by passing the Pollution material is one which is used, reused, or ineffective, immobilization
Prevention Act (Pub. L. 101-508,42 reclaimed. 2 A material is "used or (stabilization) is often effective, U.S.C. 13101. et seq.). In section 6602(b) reused" if it is (i) employed as an especially for inorganic hazardous
of this law.42 USC. 13101(b), Congress ingredient (including use as an wastes..
stated that national policy of the United intermediate) in an industrial process to Transfer of hazardous constituents
States is that pollution should be make a product (for example. from one environmental medium to
prevented or reduced at the source distillation bottoms from one process another also does not constitute waste
whenever feasible: pollution that cannot used as feedstock in another process) minimization. For example, the use of
be prevented should be recycled in an ^ * ^ or (ii) employed in a'particular an air stripper to evaporate volatile
environmentally safe manner, whenever function or application as an effective organic constituents from an aqueous
feasible; pollution that cannot be substitute for a commercial waste only shifts the contaminant from
prevented or recycled should be treated product.' * ' water to air. Furthermore, concentration
in an environmentally safe manner A material is "reclaimed" if it Is activities conducted solely for reducing
whenever feasible; and disposal or other "processed to recover a usable product. volume does not constitute waste
release into the environment should be or if it is regenerated." 4 minimization unless. for example.
employed only as a last resort and On the other hand, the regulations concentration of the waste is an integral
should be conducted in an define "treatment" and "disposal" as setup in the recovery of useful
environmentally safe manner. follows: constituents prior to treatment and
disposal. Similarly, dilution as a means
Thus. Congress set up a hierarchy of Treatment means any method, technique, management options in descending or process. including neutralization, of toxicity reduction would not be
order of preference: prevention. designed to change the physical. chemical, or considered waste minimization, unless
environmentally sound recycling, biological character or composition of any dilution is a necessary step in a recovery
treatment, and hazardous waste so asto neutralize such or a recycling operation.
environmentally sound
environmentally sound disposal. waste, or so as to recover energy or material EPA firmly believes that waste
EPA believes that waste resources from the waste, or so as to render minimization will provide additional
such waste non-hazardous, or less hazardous; environmental improvements over "end
minimization, the term employed by safer to transport. store, or dispose of; or control practices, often with
Congress in the RCRA statute, includes amenable for recovery, amenable for storage. of pipe" added benefit of cost savings to
(1) source reduction. and (2) or reduced in volume.' the
environmentally sound recycling. (See Disposalmeans the discharge, deposit. generators of hazardous waste and
later discussion for further clarification injection, dumping, spilling, leaking, or reduced levels of treatment, storage and
of which types of recycling are not placing of any solid waste or hazardous disposal. Waste minimization has
waste minimization.) waste into or on any land or water so that already been shown to result in
The first category, source reduction, Is such solid waste or hazardous waste or any significant benefits for Industry, as
defined in section 6603 (5)(A) of the constituent thereof may enter the evidenced in numerous success stories
Act,r42 U.S.C. environment or be emitted into the air of documented in available literature.
Pollution Prevention discharged into any waters, including ground
13102(5)(a), as any practice which (i) The benefits that accrue to facilities
waters.' that pursue waste minimization often
reduces the amount of any hazardous
substance. pollutant, or contaminant Some readers of today's guidance may include:
entering any waste stream or otherwise question whether certain types of (1) Minimizing quantities of
release into the environment recycling are within the concept of hazardous waste generated, thereby
(including fugitive emissions) prior to waste minimization. EPA believes that reducing waste management and
recyclinsi treatment, or disposalt and recycling activities closely resembling compliance costs and improving the
(xi) Reduces the hazards to public protection of human heafth and the
'40 CFR 261 1(c)(7).
n patc hc i
130()a.a
health and the environment associated environment;
with the release of such substances, '40 CFR 21.(e)C4).
(2) Reducing or eliminating
pollutants, or contaminants. '40 CFR 260.10. Most types of recycling are in
The term includes equipment or fact classified as treatment (see 48 FR at 14502- ' It is. of course. not always easy to distinguish
recycling (envIronmentally sound or otherwise]
technology modifications process or 14504. April 4.1983). and some also meet the
from conVgntol treatnent. See 56 FR at,71
43 procedure modifications. reformulation definition of disposal (February 21. 1991): 53 FR at 522 (January a.1988).
or redesign Pfeproduct. 4.:2ntit~tir rU t '40CV! 760.10.
Attachment 1
.IN 94-23 March 25, 1994 31116 Federal Register / Vol. 58, No. 102 / Friday, May 28, 1993 / Notices
inventories aiid possible releases of Small quantity generators who included in a waste minimization
"hazardous chemicals;" generate greater than 100 kilograms but program, although the Agency realizes
(3) Possible decrease in future less than 1000 kilograms of hazardous that each element may be Implemented
Superfund and RCRA liabilities, as waste per month are not subject to the in different ways depending on the
well as future toxic tort liabilities: same "program in place" certification needs and preferences of Individual
(4) Improving facility mass/energy requirement as large quantity organizations or facilities. The generator
efficiency and product yields; generators. Instead, they must certify on or treatment. storage, or disposal facility
(5) Reducing worker exposure; nd their hazardous waste manifests that should document its program (in
(6) Enhancing organizational they have "made a good faith effort to writing) so that it is available for
reputation and image. minimize" their waste generation. EPA interested parties. EPA also believes that
In addition to establishing a national encourages small quantity generators to the waste minimization program should
policy to foster waste minimization, develop waste minimization programs be signed by that corporate officer who
HSWA also included several specific of their own, to show their good faith is responsible or ensuring RCRA
requirements that promote efforts. compliance.
implementation of waste minimization This notice does not provide guidance The waste minimization program
at individual facilities. In particular. on the determination of the phrase elements are as follows:
RCRA section 3002(b) requires "economically practicable". As A. Top management support.Top
generators of hazardous waste who Congress indicated in its accompanying management should support an
transport wastes off-site to certify on reporttoHSWA(S. Rep No 98-284, organization-wide effort. There are
each hazardous waste manifest that they 98th Cong. 1st. Sess.. 1983) many ways to accomplish this goal.
have a program in place to reduce the "economically practicable" is to be Some of the methods described below
volume and toxicity of such waste to the defined and determined by the may be suitable for some organizations.
degree determined by the generator to generator. The generator of the while not for others. However, some
De economically practicable. Similarly, hazardous waste, for the purpose of combination of these techniques or
ertain owners and operators of RCRA meeting this certification requirement. similar ones will demonstrate top
permitted treatment, storage and has the flexibility to determine what is management support:
iisposal facilities are also required to economically practicable for the
provide the same certification annually -Make waste minimization a part of the
RCRA Section 3005(h)). These two
generator's particular circumstances. organization policy. Put this policy in
'equirements for certification, taken Whether this determination Is done in a writing and distribute it to all
ogether, have the effect of insuring that combined fashion for all operations or departments and individuals. Each
Naste minimization programs are put in on a site-specific basis is for the individual, regardless of status or
3lace for facilities that generate generator to decide. rank, should be encouraged to
Hazardous waste regardless of whether m. Guidance to HazardousWaste Identify opportunities to reduce waste
he wastes are managed on-site or off- Generatorson the Elements of a Waste generation. Encourage workers to
dite. The purpose of today's Federal MinimizationProgram,as Required adopt the policy in day to day
register notice is to provide guidance to UnderRCRA Sections 3002(b) and operations and encourage new ideas
hese hazardous waste handlers, who 3005(h)' at meetings and other organizational
nust certify that they have a waste functions. Waste minimization.
ninimization program in place. Waste minimization programs have especially when incorporated into
Hazardous waste generators and been implemented by a wide array of organization policy, should be a
iwners/operators of hazardous waste organizations. The elements discussed process of continuous improvement.
reatment. storage and disposal facilities in this notice reflect the results of EPA Ideally, a waste minimization
vho manage their own hazardous waste interactions with State governments and program should become an integral
In-site, must also identify in a biennial industry waste minimization program part of the organization's strategic
eport to EPA (or the State): (1) The managers. Numerous state governments plan to Increase productivity and
fforts undertaken during the year to have already enacted legislation
educe the volume and toxicity of waste requiring facility specific waste _- plicit goals for reducing the
enerated; and (2) the changes in minimization programs (for example. volume and toxicity of wste streams
olume and toxicity actually achieved the enactment of the MIssachusetts that are achievable within a
n comparison to previous years. Toxics Use Reduction Act of 1989. reasonable time frame. These goals
Oregon Toxics Use Reduction and may be quantitative or qualitative.
I Scope of This Notice Hazardous Waste Reduction Act, and Both can be successful.
Today's notice provides guidance on Art. 11.9. Chap. 6.5. Div. 20 of -Commit to implementing
he basic elements of a waste California Health and Safety Code. recommendations identified through
Minimization "program in place" that, if October 1989.) Other states have assessments, evaluations, waste
resent, will al ow persons to properly legislation pending that may mandate minimization teams, etc.
ertify that they have implemented a some type of facility specific waste -Desigate a waste minimization
rogram to reduce the volume and minimization program. coordinator who is responsible for
)xicity of hazardous waste to the extent EPA believes that each of the general facilitating effective implementation, economically practicable." The elements discussed below should be monitoring and evaluation of the
uidance is directly applicable to program. In some cases (particularly
enerators who generate 1000 or more IOn June 12. i0e., the EPA published a pMoposd in largemrulti-facility organizations),
guidance an what constituted a "proam Inplace".
ilograms per month of hazardous waste and solicitad public coamnnts. 33 Commants WWI an organizational waste minimization
'large quantity" generators) or to nceived in response to the draft guidance. most coordinator may be needed in
wners and operators of hazardous comments suggsted clarifctons er ecanlo af addition to facility coordinators. In
taste treatment, storage, or disposal specifte points, whie some comements saned other cases, a single coordinator may
with poriosat tfhe, proposal Both th costs
kcilities who manage their own and [PA's response to the comments have responsibility for more than one
azardous waste on-site. swummaizd In th Appeni to thX notie. facility. In these cases. thi coordinator
-'I-, Attachment 1 a IN 94-23 March 25, 1994 Federal Register / Vol. 58, No. 102 I Friday, May 26, 1993 / Notices 31117 should be involved Of be aware of treatment/storage/disposal costs, the first place (e.g.. identifying specific
operations and should be capable of employee exposure and health care, operations that generate the waste, facilitating new ideas at each facility. liability insurance, and possible future rather than charging the waste
It is also useful to set up self- RCRA or Superfund corrective action management costs to "overhead"). Cost
managing waste minimization teams costs. Both volume and toxicities of allocation can properly highlight the
chosen from a broad spectrum of generated hazardous waste should be parts of the organization where the
operations: engineering, management. taken Into account. Substantial greatest opportunities for waste
research & development, sales & uncertainty in calculating many of these minimization exist; without allocating
marketing, accounting. purchasing, costs, especially future liability. may costs, waste minimization opportunities
maintenance and environmental staff exist. Therefore, each organization can be obscured by accounting practices
personnel. These teams can be used to should find the best method to account that do not clearly identify the activities
identify, evaluate and implement for the true costs of waste management generating the hazardous wastes.
waste minimization opportunities. and cleanup. E.Encourage technology transfer.
-Publicize success stories. Set up an C. Periodicwaste minimization Many useful and equally valid
environment and select a forum assessments. Different and equally valid techniques have been evaluated and
where creative ideas can be heard and methods exist by which a waste documented that are useful in a waste
tried. These techniques can inspire minimization assessment can be minimization program. It is important to
additional ideas. performed. Some organizations identify seek or exchange technical information
-Recognize individual and collective sources of waste by tracking materials on waste minimization from other parts
accomplishments. Reward employees that eventually wind up as waste, from of the organization/facility, from other
that identify cost-effective waste point of receipt to the point at which companies/facilities, trade associations/
minimization opportunities. These they become a waste. Other affiliates, professional consultants and
rewards can take the form of organizations perform mass balance university or government technical
collective and/or individual monetary calculations to determine input and ssistance programs. EPA and/or State
or other incentives for improved outputs from processes and/or facilities. funded technical assistance programs
productivity/waste minimization. Larger organizations may find it useful (e g.. Minnesota Technical Assistance
-Train employees on the waste- to establish a team of independent Progam-MnTAP California Waste
generating impacts that result from experts outside the organization Minimization Clearinghouse. EPA
the way they conduct their work structure, while some organizations.may Pollution Prevention Information
procedures. For example, purchasing choose teams comprised of in-house Clearinghouse) are becoming
and operations departments could experts. increasingly available to assist in
develop a plan to purchase raw Most successful waste minimization finding waste minimization options and
materials with less toxic impurities or assessments have common elements technologies.
return leftover materials to vendors. that identify sources of waste and F. Programimplementation and
This approach can include all calculate the true costs of waste evaluation. Implement
departments, such as those in generation and management. Each recommendations identified by the
research & development, capital organization should decide the best assessment process. evaluations, waste
planning, purchasing, production method to use in performing a waste minimization teams, etc. Conduct a'
operations, process engineering, sales minimization assessment that addresses periodic review of program
& marketing and maintenance. these two general elements: effectiveness. Use these reviews to
B.Characterizationof waste -Identify opportunities at all points in provide feedback and Identify potential
generation and waste management a process where materials can be areas for improvement.
costs. Maintain a waste accounting prevented from becoming a waste (for IV. AdditionalResources Available to
system to track the types and amounts example. by using less material, Generatorsand Others on Waste
of wastes as well as the types and recycling materials in the process. Minimization Programs
amounts of the hazardous constituents finding substitutes that are less toxic EPA and the States have worked
in wastes, including the rates and dates and/or more easily biodegraded. or cooperatively to put in place a variety
they are generated. EPA realizes that the making equipment/process changes). of technical information and assistance
precise business framework of each Individual processes or facilities programs that make information on
waste generator can be unique. should be reviewed periodically. In source reduction and recycling
There fore, each organization must some cases, performing complete techniques available directly to industry
decide the best method to obtain the facility material balances can be and the public.
necessary information to characterize helpful. EPA has developed information
waste generation. Many organizations -Analyze waste minimization sources that can be used to provide
track their waste production by a variety opportunities based on the true costs information directly to industry or
of means and then normalize the results associated with waste management through State technical assistance
to account for variations in production and cleanup. Analyzing the cost programs. EPA maintains a Pollution
rates. effectiveness of each option is an Prevention Information Clearinghouse
Additionally, a waste generator Important factor to consider. (PPIC). which is a reference and referral
should determine the true costs especially when the true costs of source for technical, policy, program, associated with waste management and treatment, storage and disposal are legislative and financial information on
cleanup, including the costs of considered. pollution prevention. PPICs telephone
regulatory oversight compliance. D. A cost aJlocation system. Where number is (202) 260-1023; the facsimile
paperwork and reporting requirements, practical and implementable, number is (202) 260-0178. EPA also
loss of p~rouction potential, costs of organizations should appropriately publishes a pollution prevention
materials found in the waste stream allocate the true costs of waste newsletter and produces videos and
(perhaps based on the purchase price of management to the3 activities
those materials), transportationl responsible -I tw the waste 4n
Attachment 1 IN 94-23 March 25, 1994 31118 Federal Register / Vol. 58, No. 102 I Friday, May 25, 1993 / Notices
literature on waste minimization that Additionally, at least 29 states effective waste minimization programs
are available to the public.9 reported in their Capacity Assurance appropriate to specific circumstances and
Examples of general documents that Plans (October 1989) that they have in processes.
place some type of technical assistance While RCRA makes it clear that the waste
assist organizations with more detailed
guidance on conducting waste to organizations that seek alternatives to minimization certification provisions are
mandatory and enforceable, the Agency
minimization assessments and treatment, storage and disposal of waste. believes that it is the intent of Congress to
developing pollution prevention V. Conclusion allow for flexibility in implementing facility
programs are the Waste Minimization specific waste minimization programs. In
Opportunity Assessment Manual. EPA EPA is committed to the elimination, etting forth the wate minimization
625/7-88/003, July 1988.10 and the reduction, and/or recycling of waste as approach given in this Interim final
Facility Pollution Prevention Guide, the first steps in our national waste guidance. EPAW believes it has acted in a
management strategy. Only through manner that fllows Congressional intent.
EPA/600/R-92/088. 1 Another general Because of this the Agency does not believe
document that introduces the concept of preventing pollution in the first place
will our nation be able to ensure both it is necessary to describe the approach in the
waste minimization is Waste interim final guidance text as "nonbinding"
Minimization: Environmental Quality a healthy, vibrant economy that can because such a term would be redundant; the
with Economic Benefits, EPA/530-SW- prevail In a competitive worldwide guidance is nonbinding by being guidance.90-044, April 1990.12 EPA has also
economy. and a healthy environment However, while the specific elements are
developed numerous waste that provides us with the resources we guidance, the certification requirements of
nee and use in our everyday lives. As sections 3002(b) and 3005(h) are mandatory.
minimization and pollution prevention a result of the approach Congress has set The nature of the guidance does not reduce
documents that are tailored to specific in both the national policy of RCRA and in any way these mandatory certification
manufacturing and other types of in the Pollution Prevention Act, requirements.
processes, and periodically sponsors generators of waste must shoulder some Another respondent stated that EPA's
pollution prevention workshops and of the responsibility to implement waste definition of waste minimization is too
conferences. minimization measures, which will restrictive in allowing only source reduction
EPA also promotes technical and recycling activities to define waste
assist in prevention of risks to today's minimization. While activities of this nature
assistance to industry indirectly by and tomorrow's environment. may be the most desirable. Congress clearly
supporting the development of State Generators have demonstrated the stated the overall goal was to "minimize the
technical assistance programs. State usefulness and benefits of waste present and future threat to human health
personnel often have the primary day to minimization practices. EPA believes and the environment." Therefore. better
day contacts with industry for many that as more organizations implement treatment and proper disposal could be
RCRA program matters. Examples of their waste minimization programs and considered a part of waste minimization. By
State technical assistance programs are; demonstrate their usefulness and not defining treatment and disposal as part
Minnesota Technical Assistance benefits, many other organizations will of waste minimization, the commenter
Program-MnTAP and California Waste be encouraged to seek greater believed that EPA may be discouraging
Minimization Clearinghouse. EPA also improvements which could be
opportunities to incorporate waste environmentally beneficial.
provides partial funding for the National minimization in their operations. The Agency has clearly stated Its position
Roundtable of State Pollution Today's guidance on the elements of that a waste management hierarchy exists
Prevention Programs, an organization of effective waste minimization programs where source reduction and
State technical assistance and regulatory may help encourage regulated entitles to environmentally-sound recycling are the
program representatives that meets investigate waste minimization primary and secondary priorities of the waste
regularly to discuss technical and alternatives, implement new programs, management hierarchy and together define
programmatic waste minimization or upgrade existing programs. Although waste minimization. Treatment and disposal
issues. The Roundtable uses the PPIC as the approaches described above are are alternatives of last resort to waste
a central repository for technical directed toward minimizing hazardous minimization, not substitutes for it. EPA
disagrees with the respondent's suggestion
exchange and publishes proceedings on waste, they are also important elements that defining waste minimization as source
state waste minimization activities. in the design of multi-media source reduction and recycling could discourage
EPA's Office of Research and reduction and recycling programs for all improvements in treatment and disposal
Development also funds several forms of pollution. technologies On the contrary EPAbelieves
different types of waste minimization Dated: May 18. 1993. that the main thrust of the RCRA program has
research and demonstration projects in been to improve treatment and disposal
Carol M. Browner, technology. The Agency believes that the
a variety of point ventures with States Administrator.
and industry, and publishes industry. intent of the HSWA National Policy was to
specific pollution prevention Appendix move beyond treatment and disposal
approaches to prevention approaches. It is on
guidances.' 3 Response to Comments on EPA's Draft this basis that the Agency concludes that
"Guidance to HazardousWaste Generators treatment and disposal are not (nor should
'To be added to the newsletters mailing list. on the Eements of a Waste Minimization they be) part of waste minimization.
write: Pollution Prevention News. U.S. EPA. PM- Program" Guidance Element A: Top Management
222B.401 M St. SW.. Washington. DC 20460.
One respondent objected to the nonbinding Support and Facility Coordination:
"Available from the National Technical approach of the guidance, stating that some This element of the proposed guidance
Information Service; telephone (7033 4a7-4850: the stated that top management should ensure
publication number is PB 92-216 285 and the cost basic definition of program acceptability
is S27.00. should be specifically given. This respondent that waste minimization is a company-wide
" Available by calling the CEMU Publications Unit stated that the approach would encourage effort: Several techniques were proposed that
at EPA's Cincinnati. OH office at (513) 569-7562. only a voluntary effort to implement waste should be used to demonstrate top
"3Available by calling the RCRA Information minimization programs. However, most management support.
Center; telephone (2021 260-4327. respondents supported the approach and Several respondents stated that employee
"Contact the CEFU publications unit at EPA's encouraged EPA to retain this approach in education and feedback as well as
Cincinnati. OH office, telephone (513) 569-7562. the final guidance. These respondents stated management support is Important to the
for a list of available pollution prevention that the flexlbllit inherent in the apprch success of a waste minimization plan. The
publications. should assist organizations in implementing Agency agrees that employee education and
Attachment 1
-IN 94-23 March 25, 1994 Federal Register / Vol. 58, No. 102 _ Friday. May 28, 1993 I Notices 31119 particular waste accounting systemns In the I iey elements including: waste stream
management support is an important element proposed guidance for precisely those characterization; Identification and tracking
of any waste minimization program. of wastes; the determination of the true cost
However, the Agency believes that each reasons. However It Important that each
facility and/or organization have a system eof treatment, storage. and disposal; allocation
organization should decide what the of costs to the activities responsible for waste
parameters of that support will be. based that identifies and chacterizes all waste
streams and their sources, whatever form the generation; and identification of
upon its organizational structure. For opportunities for waste minimization. (Note
example. in some organizations, support may system takes. The Agency believes that there
are key parameters that waste accounting that information developed in the waste
take the form of a directive from top accounting and allocation system Is critical
management formally establishing waste systems should address. Among these are
minimization teams. In other organizations. identification of all wastes in terms of to identifying waste minimization
volume and toxicity as well as sources of all opportunities.1 support might be in the form of extending the One respondent stated that this section
scope of existing quality circles to include wastes. EPA also believes that It Is critical to the purchasing
waste minimization. What is appropriate for account for the costs of managing the wastes. should specifically state thatthat have been
including the amounts and costs of raw of materials and packaging
ons organization might not be appropriate for designed to facilitate reuse and recycling
others. materials or other by-products found In waste
streams and the costs of compliance with the should be specified as an identified
Many respondents also recommended that opporunity for waste minimization.
the policy should ackowledge that in some regulations for treatment, storage, and
disposal of hazardous wastes. The Agency arees that the use of
cases individual facility coordinators may be packaging that is designed to facilitate reuse
inappropriate, especially for companies with One respondent indicated that tracking of nd recycli can be an opportunity in waste
numerous small andor similar facilities. the rates of waste generation is not However, numerous
Respondents suggested that in these cases, a mentioned as a program element and that the minimization.
rates of waste generation are more relevant suggestions for specific types of waste
national or regional coordinator may be more minimization opportunities were received
appropriate. EPA believes that the key than the dates of generation as was stated in from respondents The EPA acknowledges
function of a coordinator is to facilitate and the draft guidance. The Agency agrees that that there are many examples of waste
maintain plant planning and operations. The rates of waste generation are more likely to minimization opportunities. However for the
most successful programs have an on-site be relevant than the dates of waste generation ake of brevity they could not all be included
person who deals with day to day tasks when tracking waste generation. However, In either the draft guidance or Interim final
necessary to keep the program on track and both are important to providing a clear guidance.
consistent with organizational goals. Some picture of the sources and quantities of Another respondent indicated that EPA
organizations with multiple facilities also waste. Therefore, the interim final guidance should state more forcefully in its interim
have a coordinator whose function is to has been changed accordingly. final guidance that finding substitutes to
facilitate communication and informational Guidance Element C Periodic Waste toxic materials that poe less of a danger to
flow between facilities and top management Minimization Assessments: human health and the environment and that
and ensure that adequate support is This element of the proposed guidance are more easily degraded is an important
available. Nevertheless, EPA believes each stated that periodic waste minimization opportunity in waste minimization. The
organization should determine how best to assessments should be conducted to identify Agency agrees that material substitution is an
fulfill the functions of managing and opportunities for waste minimization and to important aspect of waste minimization, coordinating waste minimization activities. determine the true costs of waste. which has been appropriately emphasized In
Finally, one respondent stated that EPA One respondent suggested that the section the draft and interim final guidance.
should recognize that the setting of on periodic waste minimization assessments Another respondent suggested that a waste
aggressive goals by upper management to should contain a flexibility clause stating that minimization assessment should commence
demonstrate commitment may prove there are a number of different ways to from the "point of receipt" of raw materials
counterproductive when these goals are not accomplish a waste minimization rather that "from the loading dock" as
realized. The Agency believes that the setting assessment. The respondent stated that some written in the draft guidance. The reason for
of specific, realistic goals is very Important of the methods described in the draft this is that loading docks are used for
to the success of a waste minimization guidance may be suitable for some shipping aswell as receiving. The Agency
program. However. each organization must organizations but not others. In particular. agrees and has changed the language of the
determine what these goals are as well as many materials that become wastes do not interim final guidance accordingly.
how they are achieved and the timetable for originate fom "loading dock matterials" as Guidance Element a~ A Cost Allocation
their achievement. These goals can be stated In the draft guidance. Also, some System:
qualitative and/or quantitative, but can only wastes are listed ashazardous because they This element of the proposed guidance
be successful If management fully supports are residues (by-products) from a pecifed stated that departments and managers should
employee efforts to achieve them. Both types process or processes and as such would be be charged "fully-loaded" waste management
of goals can be successful. difficult to track from the "loading dock". costs for the wasts they generate. factoring
Guidance Element B: Characterizing Waste The Agency agrees that there are different In liability compliance and oversight costs.
Generation and Waste Accounting: ways to complete a waste minimization The guidance enoes organizations to
This element of the proposed guidance assessment. In some cases, the actual practice Edevelop and maintain a system for
stated that a waste accounting system to track of tracking raw materials through the determining and monitoring wast stream
the types, amounts and hazardous production process to the point where they characteristics and costs. This information
constituents of wastes and the dates they are become wastes can be exceedingly complex. provides a basis for identitying waste
generated should be maintained. such as In petrochemical plants where minimization opportunities which is
integrally linked processes use multiple rawr discussed fAther In guidance element F.
Some respondents recommended that EPA
should clarify that waste accounting systems material Inputs. Each organization should Two respondents indicated that the entire
must be unique to each facility and that this determine what level of anlysis is necessary Cost Allocation Section should be deleted
uniqueness Is a function of the size of the to provide adequate information to formulate from the guidance, stating that the guidance
generator as well as waste characteristics and waste minimization alternatives. The waste is too specific, and that use of the phrase
volumes, processes, and other circumstances minimization team conducting a waste "fuily-oaded waste management costs" in
minimization assessment can make this the draft guidance implies cost accounting
surrounding waste generation. Therefore.
since no two waste accounting systems can determination. procedures that may not be compatible with
The Interim final guidance has been exisng organizational accounting practices.
be precisely alike, EPA will not mandate any However. several ysh dents stated that it
specific type of waste accounting system. changed to clarify this point The interim
final guidance stresses that some level of as appropriate for {PA to suggest that a
The Agency agrees that each waste waste minimizaton p ram include waste
accounting system should be facility-specific process tracking or materials balance should
be used to Identify sources and volumes of management accounting costs with the
and should be designed to accommodate understanding that It Is nappropritte for
each of the parameters mentioned by the waste. The interim final guidance stresses EPA to specify the actual methods to be used.
respondent In fact. EPA did not specify that all approaches used should cover five
Attachment 1
- IN 94- 23 March 25, 1994 31120 Federal Register / Vol. 58, No. 102 I Friday, May 28, 1993 / Notices
Organizations thai have implemented Guidance Element E: Encourage additional wording to stress these points.
successful waste minimization programs Technology Trnnsfer Additionally, asection detailing information
have incorporated cost accounting methods This element of the proposed guidance on waste minimization programs has been
which take into account direct and indirect stated that technology transfer on waste added to the interim final guidance.
waste management costs, the costs of lost minimization should be encouraged from Guidance Element F: Program Evaluation:
production, raw materials, treatment, other parts of a company, from other firms, This element of the proposed guidance
disposal as well as reduced cleanup and trade associations. State and university stated that a periodic review of program
liability costs. An understanding of the full technical assistance programs or professional effectiveness should be conducted and that
costs of waste generation and management is consultants. the review be used to provide feedback and
often a critical element for justifying waste Several respondents strongly supported the identify potential areas for Improvement.
minimization decisions. exchange of waste minimization information In general, the respondents strongly
The Agency does not believe that the cost among all sources. One respondent stated supportd periodic program evaluations that
accounting procedures detailed in the Cost that variability among facilities requires that can be used to Identify areas for
Allocation Section are unduly specific as judgements on the applicability of improvement and enhance the effectiveness
might have been construed from the phrase technology be made on a facility-specific of waste minimization programs.
"fully-loaded waste management costs". basis with considerable Input from The Agency continues to support periodic
However, this phrase has been deleted from production personnel at the facility. Another program evaluations as an element in this
the Interim final guidance and the concept respondent indicated that EPA should guidance. To strengthen this section.
has been reworded as "a system to include specific information on waste however, the name has been changed to
appropriately allocate the true costs of waste minimization resources available to the Program Implementation and Evaluation" in
management to the activities responsible for public from the EPA. order to give additional emphasis to
generating the wase in the first place to The Agency agrees that the exchange of implementing as well as evaluating
clarify the Agency's
Intent
. EPA's Waste waste information among all sources is a key opportunities identified by the assessment
M in imizAtio n Opportun lty Asessme nt factor In the transfer of technology and that process.
Manual (uly 1988), and Faclty Pollution. production personnel need to play a major
Prevention Guide (May 1092) provide a role In the application of appropriate IFR Doc. 93-12759 Filed 5-27-93; 8:45 am]
sample of a waste accounting system. technologies. The interim final guidance has WU OD MDse-
Attachment 2 IN 94-23 March 25, 1994 NRC Information Notices and Generic
Letters on the Storage of Radioactive Waste
1. Generic Letter 81-38: "Storage of Low-Level Radioactive Waste at Power
Reactor Sites"
2. Generic Letter 85-14: "Commercial Storage at Power Reactor Sites of
Low-Level Radioactive Waste Not Generated by the Utility"
3. Information Notice 89-13: "Alternative Waste Management Procedures in
Case of Denial of Access to Low-Level Waste Disposal Sites"
4. Information Notice 90-75: "Denial of Access to Current Low-Level
Radioactive Waste Disposal Facilities"
5. Information Notice 90-09: "Extended Interim Storage of Low-Level
Radioactive Waste by Fuel Cycle and Materials Licensees"
6. Information Notice 93-50: "Extended Storage of Sealed Sources"
Attachment 3 IN 94-23 March 25, 1994 LIST OF RECENTLY ISSUED
NMSS INFORMATION NOTICES
Information Date of
Notice No. Subject Issuance Issued to
94-21 Regulatory Requirements 03/18/94 All fuel cycle and materials
when No Operations are licensees.
being Performed
94-17 Strontium-90 Eye Appli- 03/11/94 All U.S. Nuclear Regulatory
cators: Submission of Commission Medical Use
Quality Management Plan Licensees.
(QMP), Calibration, and
Use
94-16 Recent Incidents Resulting 03/03/94 All U.S. Nuclear Regulatory
in Offsite Contamination Commission material and fuel
cycle licensees.
94-15 Radiation Exposures during 03/02/94 All U.S. Nuclear Regulatory
an Event Involving a Fixed Commission licensees author- Nuclear Gauge ized to possess, use, manu- facture, or distribute
industrial nuclear gauges.
94-09 Release of Patients with 02/03/94 All U.S. Nuclear Regulatory
Residual Radioactivity Commission medical
from Medical Treatment and licensees.
Control of Areas due to
Presence of Patients Con- taining Radioactivity
Following Implementation
of Revised 10 CFR Part 20
94-07 Solubility Criteria for 01/28/94 All byproduct material and
Liquid Effluent Releases fuel cycle licensees with
to Sanitary Sewerage under the exception of licensees
the Revised 10 CFR Part 20 authorized solely for
sealed sources.93-100 Reporting Requirements 12/22/93 All U.S. Nuclear Regulatory
for Bankruptcy Commission licensees.
93-80 Implementation of the 10/08/93 All byproduct, source, and
Revised 10 CFR Part 20 special nuclear material
licensees.
Attachment 4 IN 94-23 March 25, 1994 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information Date of
Notice No. Subject Issuance Issued to
94-22 Fire Endurance and 03/16/94 All holders of OLs or CPs
Ampacity Derating Test for nuclear power reactors.
Results for 3-Hour Fire- Rated Thermo-Lag 330-1 Fire Barriers
94-21 Regulatory Requirements 03/18/94 All fuel cycle and materials
when No Operations are licensees.
being Performed
94-20 Common-Cause Failures 03/17/94 All holders of OLs or CPs
due to Inadequate for nuclear power reactors.
Design Control and
Dedication
94-19 Emergency Diesel 03/16/94 All holders of OLs or CPs
Generator Vulnerability for nuclear power reactors.
to Failure from Cold
Fuel Oil
94-18 Accuracy of Motor- 03/16/94 All holders of OLs or CPs
Operated Valve Diag- for nuclear power reactors.
nostic Equipment
(Responses to Sup- plement 5 to Generic
Letter 89-10)
94-17 Strontium-90 Eye Appli- 03/11/94 All U.S. Nuclear Regulatory
cators: Submission of Commission Medical Use
Quality Management Plan Licensees.
(QMP), Calibration, and
Use
94-16 Recent Incidents Resulting 03/03/94 All U.S. Nuclear Regulatory
in Offsite Contamination Commission material and fuel
cycle licensees.
OL - Operating License
CP - Construction Permit
IN 94-XXX
January , 1994 Page 3 oT3 In addition to the programmatic elements outlined in EPA's guidance, NRC
believes that licensees may further reduce the amount of radioactive waste
requiring ultimate disposal in a licensed low-level radioactive waste disposal facility by
employing procedures already allowed under NRC's regulations.
These procedures include volume reduction by segregation, consolidation, compaction, extraction, or greater reliance on decay-in-storage in accordance with 10 CFR 20.2001.
NRC believes that licensees can reduce their waste disposal costs and improve the manner
in which they manage their waste by instituting a comprehensive waste management program
that reduces the amount of waste at the source, recycles waste that must be produced, treats waste that cannot be prevented or recycled and relies on disposal or other releases
into the environment only as a last resort.
This information notice requires no specific action or written response. If you have any
questions about the information in this notice, please contact the technical contact
listed below.
John T. Greeves, Director
Division of Low-Level Waste Management
and Decommissioning
Office of Nuclear Material Safety
and Safeguards
Technical Contact:
Dominick A. Orlando, NMSS
(301) 504-2566 Attachments:
1. EPA Guidance to Hazardous Waste Generators
on the Elements of a Waste Minimization Plan
2. List of NRC Information Notices and Generic
Letters on the Storage of Radioactive Waste
3. List of Recently Issued NMSS Information Notices
4. List of Recently Issued NRC Information Notices
SUBJECT ABSTRACT:INFORMATION NOTICE ON WASTE MINIMIZATION
- See concurrence on routing slip
OFC : LLDR* LLDR* LLDR* LLWB* IMNs
NAME: DOrlando MWeber JAustin MBell CP lo
DATE: 12/07/93 12/14/93 12/17/93 12/21/93 l ///94 OFC : NRR OGC 6 OSP TechEd IMOB
NAME:
DATE: II &94 T I/ 1/94 1 °; /9 3/D-/94 l l5I/94II
OFC : g 1 IL ll 1 lDATE: al / /94 l Ie
/ l lllll _l _11 Path & File Name:P:EPSIN OFFICIAL RECORD COPY
.- V \_J March 25, 1994 In addition to the programmatic elements outlined in EPA's guidance, NRC
believes that licensees may further reduce the amount of radioactive waste
requiring ultimate disposal in a licensed low-level radioactive waste disposal facility by
employing procedures already allowed under NRC's regulations. These procedures include
volume reduction by segregation, consolidation, compaction, extraction, or greater
reliance on decay-in-storage in accordance with 10 CFR 20.2001. NRC believes that
licensees can reduce their waste disposal costs and improve the manner in which they
manage their waste by instituting a comprehensive waste management program that reduces
the amount of waste at the source, recycles waste that must be produced, treats waste that
cannot be prevented or recycled, and relies on disposal or other releases into the
environment only as a last resort.
This information notice requires no specific action or written response. If you have any
questions about the information in this notice, please contact the technical contact
listed below.
John T. Greeves, Director
Division of Low-Level Waste Management
and Decommissioning
Office of Nuclear Material Safety
and Safeguards
Technical contact: Dominick A. Orlando, NMSS
(301) 504-2566 Attachments:
1. EPA Guidance to Hazardous Waste Generators
on the Elements of a Waste Minimization Plan
2. List of NRC Information Notices and Generic
Letters on the Storage of Radioactive Waste
3. List of Recently Issued NMSS Information Notices
4. List of Recently Issued NRC Information Notices
SUBJECT ABSTRACT:INFORMATION NOTICE ON WASTE MINIMIZATION
- See concurrence on routing slip
lOFC : LLDR* I LLDR* I LLDR* I LLWB* I IMNS l
NAME: DOrlando MWeber JAustin MBell
DATE: 12/079 I 1 3 I 3 21/93 l 112/21/93 I / /94 I
lOFC : NRR* I OGC* I OSP* I TechEd* I IMOB* I
NAME: FCongel STreby RBangart I EKrauss KRamsey
DATE: 01/21/94 I 02/07/94 02/25/94 j , 03/07/994 l
Document Name: 94-23.IN