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
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guidance to fulfill a commitment it made in a report to Congress entitled,
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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 Federal Register / Vol. 58, No. 102 I Friday, May 28. 1993 I Notices
31114
ENVIRONMENTAL PROTECTION
AGENCY
[EPA 530-Z-43-07; FRL-465-5
Guidance to Hazardous Waste
Generators on the Elements of a Waste
Minimization Program
AGENCY: Environmental Protection
Agency [EPA].
ACTION: Interim final guidance.
SUMMARY: EPA is committed to a
national policy for hazardous waste
management that places the highest
priority on waste minimization. To this
end, EPA is today providing interim
final guidance to assist hazardous waste
generators and owners and operators of
hazardous waste treatment, storage, or
disposal facilities to comply with the
waste minimization certification
requirements of sections 3002(b) and
3005(h) of the Resource Conservation
and Recovery Act (RCRA), as amended
by the Hazardous and Solid Waste
Amendments of 1984 (HSWA). 42 U.S.C. 6922(b) and 6925(h).
Section 3002(b) requires generators of
hazardous waste to certify on their
hazardous waste manifests that they
have a waste minimization program in
place. Section 3005(h) requires owners
and operators of facilities that receive a
permit for the treatment, storage, or
disposal of hazadous waste on the
premises where such waste was
generated to make the same certification
no less often than annually.
EPA believes waste minimization
programs should incorporate, in a way
that meets individual organizational
needs, the following basic elements
common to most good waste
minimization programs: (1) Top
management support; (2)
characterization of waste generation and
waste management costs; (3) periodic
waste minimization assessments; (4)
appropriate cost allocation; (5)
encouragement of technology transfer, and (6) program implementation and
evaluation. Thus, generators and owners
and operators of hazardous waste
treatment, storage, and disposal
facilities should use these elements to
design multimedia pollution prevention
programs directed at preventing or
reducing wastes, substances, discharges
and/or emissions to all environmental
media-air, land, surface water and
ground water.
EPA is publishing this guidance as an
interim final version, and solicits
further public comments on it.
However, until the guidance is
finalized, persons should use It in
developing their waste minimization
programs in place.
DATES: EPA urges all interested Parties
to comment on this interim final
guidance, in writing. by July 27. 1993.
ADDRESSES: The public must send an
original and two copies of their
comments to: RCRA Information Center
(OS-305), U.S. Environmental
Protection Agency, 401 M Street, SW.,
Washington, DC 20460.
Place the docket number F-93- WMIF-FFFFF on your comments.
Commenters who wish to submit any
information they wish to claim as
Confidential Business Information must
submit an original and two copies.
under separate cover, to: Document
Control Officer (OS-312), Office of Solid
Waste, U.S. Environmental Protection
Agency, 401 M Street, SW., Washington, DC 20460.
FOR FURTHER INFORMATION,
CONTACT
Becky Cuthbertson, Office of Solid
Waste, 703-308-8447, or the RCRA
Hotline, toll free at (800) 424-9346. TDD
(800) 553-7672.
SUPPLEMENTARY INFORMATION:
Guidance to Hazardous Waste
Generators on the Elements of a Waste
Minimization Program
L.
Purpose
The purpose of today's notice is to
provide guidance to hazardous waste
generators and owners and operators of
hazardous waste treatment, storage, and
disposal facilities on what constitutes a
waste minimization "program in place,"
in order to comply with the certification
requirements of sections 3002(b) and
3005(h) of the Resource Conservation
and Recovery Act (RCRA), as amended
by the Hazardous and Solid Waste
Amendments of 1984 (HSWA), 42 U.S.C. 6922(b) and 692(h). Section
3002(b) requires hazardous waste
generators who transport their wastes
off-site to certify on their hazardous
waste manifests that they have programs
in place to reduce the volume or
quantity and toxicity of hazardous waste
generated to the extent economically
practicable. Certification of a waste
minimization "program in place" is also
required as a condition of any permit
issued under section 3005(h) for the
treatment, storage. or disposal of
hazardous waste at facilities that
generate and manage hazardous wastes
on-site. This guidance fulfills a
commitment made by EPA in its 1986 report to Congress I entitled The
Minimization of Hazardous Waste (EPA/
530-SW-86-033. October 1986) to
provide additional information to
1 51 FR 4683 (Dember 11. t986). Notice of
Avaellbility of the report to Congress on waste
generators on the meaning of the
certification requirements placed in
Additionally, EPA published in the
Federal Register, on January 26, 1989
(54 FR 3845). a proposed policy
statement on source reduction and
recycling. This policy commits the
Agency to a preventive strategy to
reduce or eliminate the generation of
environmentally-harmful pollutants
which may be released to the air, land.
surface water or ground water. We
further proposed to incorporate this
preventive strategy into EPA's overall
mission to protect human health and the
environment by making source
reduction a priority for every aspect of
Agency decision-making and planning, with environmentally-sound recycling
as a second and higher priority over
treatment and disposal. Today's notice
is an important step in implementing
this policy with respect to hazardous
wastes regulated under RCRA.
EPA has taken the January 26, 1989
proposed pollution prevention policy
statement two steps further By
publishing a 'Polluton Prevention
Strategy" in the February 26, 1991 Federal Rgister (56 FR 7849). and by
proposing the creation of a program that
would encourage and publicly recognize
environmental leadership, and would
promote pollution prevention in
manufacturing In the anuary 15, 1993 Federal Register (58 FR 4802)
H.
Background
A. Statutory
Intent
and Requirements
and Definition of Waste Minimization
In the past, the predominant practice
used by manufacturing, commercial and
other facilities that generate hazardous
waste has been end of pipe treatment
or land disposal of hazardous and
nonhazardous wastes. While this
approach has provided substantial
progress in improving the quality of the
environment tere are limits as to how
much environmental improvement can
be achieved using methods which
manage pollutants after they have been
generated.
With the passage of HSWA in 1984,
Congress established a significant new
policy concerning hazardous waste
management. Specifically, Congress
declared that the reduction or
elimination of hazardous waste
generation at the source should take
priority over the management of
hazardous wastes after they are
generated. hiparticular, section 1003(b),
42 U.S.C. 6902(b), of RCRA the Congress
declares it to be the national policy of
the United States that, wherever
feasible, the generation of hazardous
Attachment 1
IN 94-23 March 25, 1994 Federal Register / Vol. 58, No. 102 / Friday. May 28, 1993 / Notices
311115 onventlonal waste management
.
waste is to be reduced or eliminated as
expeditiously as possible. Waste that is
nevertheless generated should be
treated, stored, or disposed of so as to
minimize the present and future threata
to human health and the environment.*
In this declaration, Congress
established a clear national priority for
eliminating or reducing the generation
of hazardous wastes. At the same time.
however, the national policy recognized
that some wastes will "nevertheless" be
generated, and such wastes should be
managed in a way that "minimizes"
p resent and future threat to human
health and the environment.
In this. Congress further clarified the
role of pollution prevention in the
nation's environmental protection
scheme, by passing the Pollution
Prevention Act (Pub. L. 101-508,42 U.S.C. 13101. et seq.). In section 6602(b)
of this law.42 USC. 13101(b), Congress
stated that 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.
Thus. Congress set up a hierarchy of
management options in descending
order of preference: prevention.
environmentally sound recycling, environmentally sound treatment, and
environmentally sound disposal.
EPA believes that waste
minimization, the term employed by
Congress in the RCRA statute, includes
(1) source reduction. and (2)
environmentally sound recycling. (See
later discussion for further clarification
of which types of recycling are not
waste minimization.)
The first category, source reduction, Is
defined in section 6603 (5)(A) of the
Pollution Prevention Act,r42 U.S.C.
13102(5)(a), as any practice which (i)
reduces the amount of any hazardous
substance. pollutant, or contaminant
entering any waste stream or otherwise
release into the environment
(including fugitive emissions) prior to
recyclinsi treatment, or disposalt and
(xi) Reduces the hazards to public
health and the environment associated
with the release of such substances, pollutants, or contaminants.
The term includes equipment or
technology modifications process or
procedure modifications. reformulation
or redesign Pfeproduct. 4.:2ntit~tir rU
t
130()a.a
n
patc
hc
i
raw materials. and improvements In
I
housekeeping. maintenance, training, or
M
inventory control.
EPA believes this definition is
appropriate for use in identifying
opportunities for source reduction
under RCRA.
The second category, environmentally
sound recycling, is the next preferred
alternative for managing those
pollutants which cannot be reduced at
the source. In the context of hazardous
waste management, there are certain
practices or activities which the
hazardous waste regulations define as
"recycling." The definitions for
materials that are "recycled" are found
in Title 40 of the Code of Federal
Regulations, S 261.1(c). A "recycled"
material is one which is used, reused, or
reclaimed.2 A material is "used or
reused" if it is (i) employed as an
ingredient (including use as an
intermediate) in an industrial process to
make a product (for example.
distillation bottoms from one process
used as feedstock in another process)
^ * ^ or (ii) employed in a'particular
function or application as an effective
substitute for a commercial
product.'
- '
A material is "reclaimed" if it Is
"processed to recover a usable product.
or if it is regenerated." 4
On the other hand, the regulations
define "treatment" and "disposal" as
follows:
Treatment means any method, technique, or process. including neutralization, designed to change the physical. chemical, or
biological character or composition of any
hazardous waste so as to neutralize such
waste, or so as to recover energy or material
resources from the waste, or so as to render
such waste non-hazardous, or less hazardous;
safer to transport. store, or dispose of; or
amenable for recovery, amenable for storage.
or reduced in volume.'
Disposal means the discharge, deposit.
injection, dumping, spilling, leaking, or
placing of any solid waste or hazardous
waste into or on any land or water so that
such solid waste or hazardous waste or any
constituent thereof may enter the
environment or be emitted into the air of
discharged into any waters, including ground
waters.'
Some readers of today's guidance may
question whether certain types of
recycling are within the concept of
waste minimization. EPA believes that
recycling activities closely resembling
'40 CFR 261 1(c)(7).
'40 CFR 21.(e)C4).
'40 CFR 260.10. Most types of recycling are in
fact classified as treatment (see 48 FR at 14502-
14504. April 4.1983). and some also meet the
definition of disposal
'40CV! 760.10.
conventional waste management
activities do not constitute waste
minimization.
Treatment for the purposes of
destruction or disposal is not part of
waste minimization, but is, rather, an
activity that occurs after the
opportunities for waste minimization
have been pursued. When source
reduction and recycling opportunities
are exhausted to thse extent
economically practicable, EPA has set
standards for the treatment, storage and
disposal of hazardous wastes. Treatment
may be either thermal (i.e.,
incineration), chemical, or biological, especially for organic hazardous wastes.
Where destruction methods for
treatment are not available or
ineffective, immobilization
(stabilization) is often effective, especially for inorganic hazardous
wastes..
Transfer of hazardous constituents
from one environmental medium to
another also does not constitute waste
minimization. For example, the use of
an air stripper to evaporate volatile
organic constituents from an aqueous
waste only shifts the contaminant from
water to air. Furthermore, concentration
activities conducted solely for reducing
volume does not constitute waste
minimization unless. for example.
concentration of the waste is an integral
setup in the recovery of useful
constituents prior to treatment and
disposal. Similarly, dilution as a means
of toxicity reduction would not be
considered waste minimization, unless
dilution is a necessary step in a recovery
or a recycling operation.
EPA firmly believes that waste
minimization will provide additional
environmental improvements over "end
of pipe" control practices, often with
the added benefit of cost savings to
generators of hazardous waste and
reduced levels of treatment, storage and
disposal. Waste minimization has
already been shown to result in
significant benefits for Industry, as
evidenced in numerous success stories
documented in available literature.
The benefits that accrue to facilities
that pursue waste minimization often
include:
(1) Minimizing quantities of
hazardous waste generated, thereby
reducing waste management and
compliance costs and improving the
protection of human heafth and the
environment;
(2) Reducing or eliminating
' It is. of course. not always easy to distinguish
recycling (envIronmentally sound or otherwise]
from conVgntol treatnent. See 56 FR at,71
43 (February 21. 1991): 53 FR at 522 (January a. 1988).
Attachment 1
.IN 94-23 March 25, 1994 Federal Register / Vol. 58, No. 102 / Friday, May 28, 1993 / Notices
31116 inventories aiid possible releases of
"hazardous chemicals;"
(3) Possible decrease in future
Superfund and RCRA liabilities, as
well as future toxic tort liabilities:
(4) Improving facility mass/energy
efficiency and product yields;
(5) Reducing worker exposure; nd
(6) Enhancing organizational
reputation and image.
In addition to establishing a national
policy to foster waste minimization,
HSWA also included several specific
requirements that promote
implementation of waste minimization
at individual facilities. In particular.
RCRA section 3002(b) requires
generators of hazardous waste who
transport wastes off-site to certify on
each hazardous waste manifest that they
have a program in place to reduce the
volume and toxicity of such waste to the
degree determined by the generator to
De economically practicable. Similarly, ertain owners and operators of RCRA
permitted treatment, storage and
iisposal facilities are also required to
provide the same certification annually
RCRA Section 3005(h)). These two
'equirements for certification, taken
ogether, have the effect of insuring that
Naste minimization programs are put in
3lace for facilities that generate
Hazardous waste regardless of whether
he wastes are managed on-site or off- dite. The purpose of today's Federal
register notice is to provide guidance to
hese hazardous waste handlers, who
nust certify that they have a waste
ninimization program in place.
Hazardous waste generators and
iwners/operators of hazardous waste
reatment. storage and disposal facilities
vho manage their own hazardous waste
In-site, must also identify in a biennial
eport to EPA (or the State): (1) The
fforts undertaken during the year to
educe the volume and toxicity of waste
enerated; and (2) the changes in
olume and toxicity actually achieved
n comparison to previous years.
I Scope of This Notice
Today's notice provides guidance on
he basic elements of a waste
Minimization "program in place" that, if
resent, will al ow persons to properly
ertify that they have implemented a
rogram to reduce the volume and
)xicity of hazardous waste to the extent
economically practicable." The
uidance is directly applicable to
enerators who generate 1000 or more
ilograms per month of hazardous waste
'large quantity" generators) or to
wners and operators of hazardous
taste treatment, storage, or disposal
kcilities who manage their own
azardous waste on-site.
Small quantity generators who
generate greater than 100 kilograms but
less than 1000 kilograms of hazardous
waste per month are not subject to the
same "program in place" certification
requirement as large quantity
generators. Instead, they must certify on
their hazardous waste manifests that
they have "made a good faith effort to
minimize" their waste generation. EPA
encourages small quantity generators to
develop waste minimization programs
of their own, to show their good faith
efforts.
This notice does not provide guidance
on the determination of the phrase
"economically practicable". As
Congress indicated in its accompanying
reporttoHSWA(S. Rep No 98-284,
98th Cong. 1st. Sess.. 1983)
"economically practicable" is to be
defined and determined by the
generator. The generator of the
hazardous waste, for the purpose of
meeting this certification requirement.
has the flexibility to determine what is
economically practicable for the
generator's particular circumstances.
Whether this determination Is done in a
combined fashion for all operations or
on a site-specific basis is for the
generator to decide.
m. Guidance to Hazardous Waste
Generators on the Elements of a Waste
Minimization Program, as Required
Under RCRA Sections 3002(b) and
3005(h)'
Waste minimization programs have
been implemented by a wide array of
organizations. The elements discussed
in this notice reflect the results of EPA
interactions with State governments and
industry waste minimization program
managers. Numerous state governments
have already enacted legislation
requiring facility specific waste
minimization programs (for example.
the enactment of the MIssachusetts
Toxics Use Reduction Act of 1989.
Oregon Toxics Use Reduction and
Hazardous Waste Reduction Act, and
Art. 11.9. Chap. 6.5. Div. 20 of
California Health and Safety Code.
October 1989.) Other states have
legislation pending that may mandate
some type of facility specific waste
minimization program.
EPA believes that each of the general
elements discussed below should be
IOn June 12. i0e., the EPA published a pMoposd
guidance an what constituted a "proam In place".
and solicitad public coamnnts. 33 Commants WWI
nceived in response to the draft guidance. most
comments suggsted clarifctons er ecanlo af
specifte points, whie some comements
saned
with poriosat tfhe, proposal Both th costs
and [PA's response to the comments
swummaizd In th Appeni to thX notie.
included in a waste minimization
program, although the Agency realizes
that each element may be Implemented
in different ways depending on the
needs and preferences of Individual
organizations or facilities. The generator
or treatment. storage, or disposal facility
should document its program (in
writing) so that it is available for
interested parties. EPA also believes that
the waste minimization program should
be signed by that corporate officer who
is responsible or ensuring RCRA
compliance.
The waste minimization program
elements are as follows:
A. Top management support. Top
management should support an
organization-wide effort. There are
many ways to accomplish this goal.
Some of the methods described below
may be suitable for some organizations.
while not for others. However, some
combination of these techniques or
similar ones will demonstrate top
management support:
-Make waste minimization a part of the
organization policy. Put this policy in
writing and distribute it to all
departments and individuals. Each
individual, regardless of status or
rank, should be encouraged to
Identify opportunities to reduce waste
generation. Encourage workers to
adopt the policy in day to day
operations and encourage new ideas
at meetings and other organizational
functions. Waste minimization.
especially when incorporated into
organization policy, should be a
process of continuous improvement.
Ideally, a waste minimization
program should become an integral
part of the organization's strategic
plan to Increase productivity and
_-
plicit goals for reducing the
volume and toxicity of wste streams
that are achievable within a
reasonable time frame. These goals
may be quantitative or qualitative.
Both can be successful.
-Commit to implementing
recommendations identified through
assessments, evaluations, waste
minimization teams, etc.
-Desigate a waste minimization
coordinator who is responsible for
facilitating effective implementation, monitoring and evaluation of the
program. In some cases (particularly
in large mrulti-facility organizations),
an organizational waste minimization
coordinator may be needed in
addition to facility coordinators. In
other cases, a single coordinator may
have responsibility for more than one
facility. In these cases. thi coordinator
a
-'I-, Attachment 1 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
operations and should be capable of
facilitating new ideas at each facility.
It is also useful to set up self- managing waste minimization teams
chosen from a broad spectrum of
operations: engineering, management.
research & development, sales &
marketing, accounting. purchasing, maintenance and environmental staff
personnel. These teams can be used to
identify, evaluate and implement
waste minimization opportunities.
-Publicize success stories. Set up an
environment and select a forum
where creative ideas can be heard and
tried. These techniques can inspire
additional ideas.
-Recognize individual and collective
accomplishments. Reward employees
that identify cost-effective waste
minimization opportunities. These
rewards can take the form of
collective and/or individual monetary
or other incentives for improved
productivity/waste minimization.
-Train employees on the waste- generating impacts that result from
the way they conduct their work
procedures. For example, purchasing
and operations departments could
develop a plan to purchase raw
materials with less toxic impurities or
return leftover materials to vendors.
This approach can include all
departments, such as those in
research & development, capital
planning, purchasing, production
operations, process engineering, sales
& marketing and maintenance.
B. Characterization of waste
generation and waste management
costs. Maintain a waste accounting
system to track the types and amounts
of wastes as well as the types and
amounts of the hazardous constituents
in wastes, including the rates and dates
they are generated. EPA realizes that the
precise business framework of each
waste generator can be unique.
There fore, each organization must
decide the best method to obtain the
necessary information to characterize
waste generation. Many organizations
track their waste production by a variety
of means and then normalize the results
to account for variations in production
rates.
Additionally, a waste generator
should determine the true costs
associated with waste management and
cleanup, including the costs of
regulatory oversight compliance.
paperwork and reporting requirements, loss of p~rouction potential, costs of
materials found in the waste stream
(perhaps based on the purchase price of
those materials), transportationl
treatment/storage/disposal costs, employee exposure and health care, liability insurance, and possible future
RCRA or Superfund corrective action
costs. Both volume and toxicities of
generated hazardous waste should be
taken Into account. Substantial
uncertainty in calculating many of these
costs, especially future liability. may
exist. Therefore, each organization
should find the best method to account
for the true costs of waste management
and cleanup.
C. Periodic waste minimization
assessments. Different and equally valid
methods exist by which a waste
minimization assessment can be
performed. Some organizations identify
sources of waste by tracking materials
that eventually wind up as waste, from
point of receipt to the point at which
they become a waste. Other
organizations perform mass balance
calculations to determine input and
outputs from processes and/or facilities.
Larger organizations may find it useful
to establish a team of independent
experts outside the organization
structure, while some organizations.may
choose teams comprised of in-house
experts.
Most successful waste minimization
assessments have common elements
that identify sources of waste and
calculate the true costs of waste
generation and management. Each
organization should decide the best
method to use in performing a waste
minimization assessment that addresses
these two general elements:
-Identify opportunities at all points in
a process where materials can be
prevented from becoming a waste (for
example. by using less material, recycling materials in the process.
finding substitutes that are less toxic
and/or more easily biodegraded. or
making equipment/process changes).
Individual processes or facilities
should be reviewed periodically. In
some cases, performing complete
facility material balances can be
helpful.
-Analyze waste minimization
opportunities based on the true costs
associated with waste management
and cleanup. Analyzing the cost
effectiveness of each option is an
Important factor to consider.
especially when the true costs of
treatment, storage and disposal are
considered.
D. A cost aJlocation system. Where
practical and implementable, organizations should appropriately
allocate the true costs of waste
management to the3 activities
responsible
-I
tw the waste 4n
the first place (e.g.. identifying specific
operations that generate the waste, rather than charging the waste
management costs to "overhead"). Cost
allocation can properly highlight the
parts of the organization where the
greatest opportunities for waste
minimization exist; without allocating
costs, waste minimization opportunities
can be obscured by accounting practices
that do not clearly identify the activities
generating the hazardous wastes.
E. Encourage technology transfer.
Many useful and equally valid
techniques have been evaluated and
documented that are useful in a waste
minimization program. It is important to
seek or exchange technical information
on waste minimization from other parts
of the organization/facility, from other
companies/facilities, trade associations/
affiliates, professional consultants and
university or government technical
ssistance programs. EPA and/or State
funded technical assistance programs
(e g.. Minnesota Technical Assistance
Progam-MnTAP California Waste
Minimization Clearinghouse. EPA
Pollution Prevention Information
Clearinghouse) are becoming
increasingly available to assist in
finding waste minimization options and
technologies.
F. Program implementation and
evaluation. Implement
recommendations identified by the
assessment process. evaluations, waste
minimization teams, etc. Conduct a'
periodic review of program
effectiveness. Use these reviews to
provide feedback and Identify potential
areas for improvement.
IV. Additional Resources Available to
Generators and Others on Waste
Minimization Programs
EPA and the States have worked
cooperatively to put in place a variety
of technical information and assistance
programs that make information on
source reduction and recycling
techniques available directly to industry
and the public.
EPA has developed information
sources that can be used to provide
information directly to industry or
through State technical assistance
programs. EPA maintains a Pollution
Prevention Information Clearinghouse
(PPIC). which is a reference and referral
source for technical, policy, program, legislative and financial information on
pollution prevention. PPICs telephone
number is (202) 260-1023; the facsimile
number is (202) 260-0178. EPA also
publishes a pollution prevention
newsletter and produces videos and
Attachment 1
IN 94-23 March 25, 1994 Federal Register / Vol. 58, No. 102 I Friday, May 25, 1993 / Notices
31118 literature on waste minimization that
are available to the public.9
Examples of general documents that
assist organizations with more detailed
guidance on conducting waste
minimization assessments and
developing pollution prevention
programs are the Waste Minimization
Opportunity Assessment Manual. EPA
625/7-88/003, July 1988.10 and the
Facility Pollution Prevention Guide, EPA/600/R-92/088. 1 Another general
document that introduces the concept of
waste minimization is Waste
Minimization: Environmental Quality
with Economic Benefits, EPA/530-SW-
90-044, April 1990.12 EPA has also
developed numerous waste
minimization and pollution prevention
documents that are tailored to specific
manufacturing and other types of
processes, and periodically sponsors
pollution prevention workshops and
conferences.
EPA also promotes technical
assistance to industry indirectly by
supporting the development of State
technical assistance programs. State
personnel often have the primary day to
day contacts with industry for many
RCRA program matters. Examples of
State technical assistance programs are;
Minnesota Technical Assistance
Program-MnTAP and California Waste
Minimization Clearinghouse. EPA also
provides partial funding for the National
Roundtable of State Pollution
Prevention Programs, an organization of
State technical assistance and regulatory
program representatives that meets
regularly to discuss technical and
programmatic waste minimization
issues. The Roundtable uses the PPIC as
a central repository for technical
exchange and publishes proceedings on
state waste minimization activities.
EPA's Office of Research and
Development also funds several
different types of waste minimization
research and demonstration projects in
a variety of point ventures with States
and industry, and publishes industry.
specific pollution prevention
guidances.' 3
'To be added to the newsletters mailing list.
write: Pollution Prevention News. U.S. EPA. PM-
222B.401 M St. SW.. Washington. DC 20460.
"Available from the National Technical
Information Service; telephone (7033 4a7-4850: the
publication number is PB 92-216 285 and the cost
is S27.00.
" Available by calling the CEMU Publications Unit
at EPA's Cincinnati. OH office at (513) 569-7562.
"3 Available by calling the RCRA Information
Center; telephone (2021 260-4327.
"Contact the CEFU publications unit at EPA's
Cincinnati. OH office, telephone (513) 569-7562.
for a list of available pollution prevention
publications.
Additionally, at least 29 states
reported in their Capacity Assurance
Plans (October 1989) that they have in
place some type of technical assistance
to organizations that seek alternatives to
treatment, storage and disposal of waste.
V. Conclusion
EPA is committed to the elimination, reduction, and/or recycling of waste as
the first steps in our national waste
management strategy. Only through
preventing pollution in the first place
will our nation be able to ensure both
a healthy, vibrant economy that can
prevail In a competitive worldwide
economy. and a healthy environment
that provides us with the resources we
nee and use in our everyday lives. As
a result of the approach Congress has set
in both the national policy of RCRA and
in the Pollution Prevention Act, generators of waste must shoulder some
of the responsibility to implement waste
minimization measures, which will
assist in prevention of risks to today's
and tomorrow's environment.
Generators have demonstrated the
usefulness and benefits of waste
minimization practices. EPA believes
that as more organizations implement
their waste minimization programs and
demonstrate their usefulness and
benefits, many other organizations will
be encouraged to seek greater
opportunities to incorporate waste
minimization in their operations.
Today's guidance on the elements of
effective waste minimization programs
may help encourage regulated entitles to
investigate waste minimization
alternatives, implement new programs, or upgrade existing programs. Although
the approaches described above are
directed toward minimizing hazardous
waste, they are also important elements
in the design of multi-media source
reduction and recycling programs for all
forms of pollution.
Dated: May 18. 1993.
Carol M. Browner, Administrator.
Appendix
Response to Comments on EPA's Draft
"Guidance to Hazardous Waste Generators
on the Eements of a Waste Minimization
Program"
One respondent objected to the nonbinding
approach of the guidance, stating that some
basic definition of program acceptability
should be specifically given. This respondent
stated that the approach would encourage
only a voluntary effort to implement waste
minimization programs. However, most
respondents supported the approach and
encouraged EPA to retain this approach in
the final guidance. These respondents stated
that the flexlbllit inherent in the apprch
should assist organizations in implementing
effective waste minimization programs
appropriate to specific circumstances and
processes.
While RCRA makes it clear that the waste
minimization certification provisions are
mandatory and enforceable, the Agency
believes that it is the intent of Congress to
allow for flexibility in implementing facility
specific waste minimization programs. In
etting forth the wate minimization
approach given in this Interim final
guidance. EPAW believes it has acted in a
manner that fllows Congressional intent.
Because of this the Agency does not believe
it is necessary to describe the approach in the
interim final guidance text as "nonbinding"
because such a term would be redundant; the
guidance is nonbinding by being guidance.
However, while the specific elements are
guidance, the certification requirements of
sections 3002(b) and 3005(h) are mandatory.
The nature of the guidance does not reduce
in any way these mandatory certification
requirements.
Another respondent stated that EPA's
definition of waste minimization is too
restrictive in allowing only source reduction
and recycling activities to define waste
minimization. While activities of this nature
may be the most desirable. Congress clearly
stated the overall goal was to "minimize the
present and future threat to human health
and the environment." Therefore. better
treatment and proper disposal could be
considered a part of waste minimization. By
not defining treatment and disposal as part
of waste minimization, the commenter
believed that EPA may be discouraging
improvements which could be
environmentally beneficial.
The Agency has clearly stated Its position
that a waste management hierarchy exists
where source reduction and
environmentally-sound recycling are the
primary and secondary priorities of the waste
management hierarchy and together define
waste minimization. Treatment and disposal
are alternatives of last resort to waste
minimization, not substitutes for it. EPA
disagrees with the respondent's suggestion
that defining waste minimization as source
reduction and recycling could discourage
improvements in treatment and disposal
technologies On the contrary EPAbelieves
that the main thrust of the RCRA program has
been to improve treatment and disposal
technology. The Agency believes that the
intent of the HSWA National Policy was to
move beyond treatment and disposal
approaches to prevention approaches. It is on
this basis that the Agency concludes that
treatment and disposal are not (nor should
they be) part of waste minimization.
Guidance Element A: Top Management
Support and Facility Coordination:
This element of the proposed guidance
stated that top management should ensure
that waste minimization is a company-wide
effort: Several techniques were proposed that
should be used to demonstrate top
management support.
Several respondents stated that employee
education and feedback as well as
management support is Important to the
success of a waste minimization plan. The
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 management support is an important element
of any waste minimization program.
However, the Agency believes that each
organization should decide what the
parameters of that support will be. based
upon its organizational structure. For
example. in some organizations, support may
take the form of a directive from top
management formally establishing waste
minimization teams. In other organizations.
support might be in the form of extending the
scope of existing quality circles to include
waste minimization. What is appropriate for
ons organization might not be appropriate for
others.
Many respondents also recommended that
the policy should ackowledge that in some
cases individual facility coordinators may be
inappropriate, especially for companies with
numerous small andor similar facilities.
Respondents suggested that in these cases, a
national or regional coordinator may be more
appropriate. EPA believes that the key
function of a coordinator is to facilitate and
maintain plant planning and operations. The
most successful programs have an on-site
person who deals with day to day tasks
necessary to keep the program on track and
consistent with organizational goals. Some
organizations with multiple facilities also
have a coordinator whose function is to
facilitate communication and informational
flow between facilities and top management
and ensure that adequate support is
available. Nevertheless, EPA believes each
organization should determine how best to
fulfill the functions of managing and
coordinating waste minimization activities.
Finally, one respondent stated that EPA
should recognize that the setting of
aggressive goals by upper management to
demonstrate commitment may prove
counterproductive when these goals are not
realized. The Agency believes that the setting
of specific, realistic goals is very Important
to the success of a waste minimization
program. However. each organization must
determine what these goals are as well as
how they are achieved and the timetable for
their achievement. These goals can be
qualitative and/or quantitative, but can only
be successful If management fully supports
employee efforts to achieve them. Both types
of goals can be successful.
Guidance Element B: Characterizing Waste
Generation and Waste Accounting:
This element of the proposed guidance
stated that a waste accounting system to track
the types, amounts and hazardous
constituents of wastes and the dates they are
generated should be maintained.
Some respondents recommended that EPA
should clarify that waste accounting systems
must be unique to each facility and that this
uniqueness Is a function of the size of the
generator as well as waste characteristics and
volumes, processes, and other circumstances
surrounding waste generation. Therefore.
since no two waste accounting systems can
be precisely alike, EPA will not mandate any
specific type of waste accounting system.
The Agency agrees that each waste
accounting system should be facility-specific
and should be designed to accommodate
each of the parameters mentioned by the
respondent In fact. EPA did not specify
particular waste accounting systemns In the
I
proposed guidance for precisely those
reasons. However It
Important that each
facility and/or organization have a system
e
that identifies and chacterizes all waste
streams and their sources, whatever form the
system takes. The Agency believes that there
are key parameters that waste accounting
systems should address. Among these are
identification of all wastes in terms of
volume and toxicity as well as sources of all
wastes. EPA also believes that It Is critical to
account for the costs of managing the wastes.
including the amounts and costs of raw
materials or other by-products found In waste
streams and the costs of compliance with the
regulations for treatment, storage, and
disposal of hazardous wastes.
One respondent indicated that tracking of
the rates of waste generation is not
mentioned as a program element and that the
rates of waste generation are more relevant
than the dates of generation as was stated in
the draft guidance. The Agency agrees that
rates of waste generation are more likely to
be relevant than the dates of waste generation
when tracking waste generation. However, both are important to providing a clear
picture of the sources and quantities of
waste. Therefore, the interim final guidance
has been changed accordingly.
Guidance Element C Periodic Waste
Minimization Assessments:
This element of the proposed guidance
stated that periodic waste minimization
assessments should be conducted to identify
opportunities for waste minimization and to
determine the true costs of waste.
One respondent suggested that the section
on periodic waste minimization assessments
should contain a flexibility clause stating that
there are a number of different ways to
accomplish a waste minimization
assessment. The respondent stated that some
of the methods described in the draft
guidance may be suitable for some
organizations but not others. In particular.
many materials that become wastes do not
originate fom "loading dock matterials" as
stated In the draft guidance. Also, some
wastes are listed as hazardous because they
are residues (by-products) from a pecifed
process or processes and as such would be
difficult to track from the "loading dock".
The Agency agrees that there are different
ways to complete a waste minimization
assessment. In some cases, the actual practice
of tracking raw materials through the
production process to the point where they
become wastes can be exceedingly complex.
such as In petrochemical plants where
integrally linked processes use multiple rawr
material Inputs. Each organization should
determine what level of anlysis is necessary
to provide adequate information to formulate
waste minimization alternatives. The waste
minimization team conducting a waste
minimization assessment can make this
determination.
The Interim final guidance has been
changed to clarify this point The interim
final guidance stresses that some level of
process tracking or materials balance should
be used to Identify sources and volumes of
waste. The interim final guidance stresses
that all approaches used should cover five
iey elements including: waste stream
characterization; Identification and tracking
of wastes; the determination of the true cost
of treatment, storage. and disposal; allocation
of costs to the activities responsible for waste
generation; and identification of
opportunities for waste minimization. (Note
that information developed in the waste
accounting and allocation system Is critical
to identifying waste minimization
opportunities.1
One respondent stated that this section
should specifically state that the purchasing
of materials and packaging that have been
designed to facilitate reuse and recycling
should be specified as an identified
opporunity for waste minimization.
The Agency arees that the use of
packaging that is designed to facilitate reuse
nd recycli
can be an opportunity in waste
minimization. However, numerous
suggestions for specific types of waste
minimization opportunities were received
from respondents The EPA acknowledges
that there are many examples of waste
minimization opportunities. However for the
ake of brevity they could not all be included
In either the draft guidance or Interim final
guidance.
Another respondent indicated that EPA
should state more forcefully in its interim
final guidance that finding substitutes to
toxic materials that poe less of a danger to
human health and the environment and that
are more easily degraded is an important
opportunity in waste minimization. The
Agency agrees that material substitution is an
important aspect of waste minimization, which has been appropriately emphasized In
the draft and interim final guidance.
Another respondent suggested that a waste
minimization assessment should commence
from the "point of receipt" of raw materials
rather that "from the loading dock" as
written in the draft guidance. The reason for
this is that loading docks are used for
shipping as well as receiving. The Agency
agrees and has changed the language of the
interim final guidance accordingly.
Guidance Element a~ A Cost Allocation
System:
This element of the proposed guidance
stated that departments and managers should
be charged "fully-loaded" waste management
costs for the wasts they generate. factoring
In liability compliance and oversight costs.
The guidance enoes
organizations to
Edevelop and maintain a system for
determining and monitoring wast stream
characteristics and costs. This information
provides a basis for identitying waste
minimization opportunities which is
discussed fAther In guidance element F.
Two respondents indicated that the entire
Cost Allocation Section should be deleted
from the guidance, stating that the guidance
is too specific, and that use of the phrase
"fuily-oaded waste management costs" in
the draft guidance implies cost accounting
procedures that may not be compatible with
exisng organizational accounting practices.
However. several ysh
dents stated that it
as appropriate for {PA to suggest that a
waste minimizaton p
ram include waste
management accounting costs with the
understanding that It Is nappropritte for
EPA to specify the actual methods to be used.
Attachment 1
- IN 94- 23 March 25, 1994 Federal Register / Vol. 58, No. 102 I Friday, May 28, 1993 / Notices
31120
Organizations thai have implemented
successful waste minimization programs
have incorporated cost accounting methods
which take into account direct and indirect
waste management costs, the costs of lost
production, raw materials, treatment, disposal as well as reduced cleanup and
liability costs. An understanding of the full
costs of waste generation and management is
often a critical element for justifying waste
minimization decisions.
The Agency does not believe that the cost
accounting procedures detailed in the Cost
Allocation Section are unduly specific as
might have been construed from the phrase
"fully-loaded waste management costs".
However, this phrase has been deleted from
the Interim final guidance and the concept
has been reworded as "a system to
appropriately allocate the true costs of waste
management to the activities responsible for
generating the wase in the first place to
clarify the Agency's
Intent
. EPA's Waste
M in imizAt io n Opp ortun lty Asess me nt
Manual (uly 1988), and Faclty Pollution.
Prevention Guide (May 1092) provide a
sample of a waste accounting system.
Guidance Element E: Encourage
Technology Trnnsfer
This element of the proposed guidance
stated that technology transfer on waste
minimization should be encouraged from
other parts of a company, from other firms, trade associations. State and university
technical assistance programs or professional
consultants.
Several respondents strongly supported the
exchange of waste minimization information
among all sources. One respondent stated
that variability among facilities requires that
judgements on the applicability of
technology be made on a facility-specific
basis with considerable Input from
production personnel at the facility. Another
respondent indicated that EPA should
include specific information on waste
minimization resources available to the
public from the EPA.
The Agency agrees that the exchange of
waste information among all sources is a key
factor In the transfer of technology and that
production personnel need to play a major
role In the application of appropriate
technologies. The interim final guidance has
additional wording to stress these points.
Additionally, a section detailing information
on waste minimization programs has been
added to the interim final guidance.
Guidance Element F: Program Evaluation:
This element of the proposed guidance
stated that a periodic review of program
effectiveness should be conducted and that
the review be used to provide feedback and
identify potential areas for Improvement.
In general, the respondents strongly
supportd periodic program evaluations that
can be used to Identify areas for
improvement and enhance the effectiveness
of waste minimization programs.
The Agency continues to support periodic
program evaluations as an element in this
guidance. To strengthen this section.
however, the name has been changed to
Program Implementation and Evaluation" in
order to give additional emphasis to
implementing as well as evaluating
opportunities identified by the assessment
process.
IFR Doc. 93-12759 Filed 5-27-93; 8:45 am]
WU
Attachment 2
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.
"Denial of Access to Current Low-Level
Radioactive Waste Disposal Facilities"
5.
"Extended Interim Storage of Low-Level
Radioactive Waste by Fuel Cycle and Materials Licensees"
6.
"Extended Storage of Sealed Sources"
Attachment 3
March 25, 1994 LIST OF RECENTLY ISSUED
NMSS INFORMATION NOTICES
Information
Date of
Notice No.
Subject
Issuance
Issued to
94-21
Regulatory Requirements
when No Operations are
being Performed
03/18/94
All fuel cycle and materials
licensees.
94-17 Strontium-90 Eye Appli- cators: Submission of
Quality Management Plan
(QMP), Calibration, and
Use
03/11/94
All U.S. Nuclear Regulatory
Commission Medical Use
Licensees.
94-16
94-15
94-09
94-07
Recent Incidents Resulting
in Offsite Contamination
Radiation Exposures during
an Event Involving a Fixed
Nuclear Gauge
Release of Patients with
Residual Radioactivity
from Medical Treatment and
Control of Areas due to
Presence of Patients Con- taining Radioactivity
Following Implementation
of Revised 10 CFR Part 20
Solubility Criteria for
Liquid Effluent Releases
to Sanitary Sewerage under
the Revised 10 CFR Part 20
Reporting Requirements
for Bankruptcy
Implementation of the
Revised 10 CFR Part 20
03/03/94
03/02/94
02/03/94
01/28/94
12/22/93
10/08/93
All U.S. Nuclear Regulatory
Commission material and fuel
cycle licensees.
All U.S. Nuclear Regulatory
Commission licensees author- ized to possess, use, manu- facture, or distribute
industrial nuclear gauges.
All U.S. Nuclear Regulatory
Commission medical
licensees.
All byproduct material and
fuel cycle licensees with
the exception of licensees
authorized solely for
sealed sources.
All U.S. Nuclear Regulatory
Commission licensees.
All byproduct, source, and
licensees.93-100
93-80
Attachment 4
March 25, 1994 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information
Date of
Notice No.
Subject
Issuance
Issued to
94-22
94-21
94-20
94-19
Fire Endurance and
Ampacity Derating Test
Results for 3-Hour Fire- Rated Thermo-Lag 330-1
Fire Barriers
Regulatory Requirements
when No Operations are
being Performed
Common-Cause Failures
due to Inadequate
Design Control and
Emergency Diesel
Generator Vulnerability
to Failure from Cold
Fuel Oil
Accuracy of Motor- Operated Valve Diag- nostic Equipment
(Responses to Sup- plement 5 to Generic
Letter 89-10)
Strontium-90 Eye Appli- cators: Submission of
Quality Management Plan
(QMP), Calibration, and
Use
Recent Incidents Resulting
in Offsite Contamination
03/16/94
03/18/94
03/17/94
03/16/94
03/16/94
03/11/94
03/03/94
All holders of OLs or CPs
for nuclear power reactors.
All fuel cycle and materials
licensees.
All holders of OLs or CPs
for nuclear power reactors.
All holders of OLs or CPs
for nuclear power reactors.
All holders of OLs or CPs
for nuclear power reactors.
All U.S. Nuclear Regulatory
Commission Medical Use
Licensees.
All U.S. Nuclear Regulatory
Commission material and fuel
cycle licensees.
94-18
94-17
94-16 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
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NAME: DOrlando
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DATE: 12/07/93
12/14/93
12/17/93
12/21/93 l
///94 OFC : NRR
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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