Information Notice 1994-23, Guidance to Hazardous, Radioactive and Mixed Waste Generators on the Elements of a Waste Minimization Program

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Guidance to Hazardous, Radioactive and Mixed Waste Generators on the Elements of a Waste Minimization Program
ML031060489
Person / Time
Site: Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant  Entergy icon.png
Issue date: 03/25/1994
From: Greeves J
Office of Nuclear Material Safety and Safeguards
To:
References
FOIA/PA-2009-0209 IN-94-023, NUDOCS 9403160172
Download: ML031060489 (16)


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

IN 94-23

.- 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