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

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, 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, Crane
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

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

HSWA

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

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patc

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i

raw materials. and improvements In

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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

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

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.

"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

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

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

special nuclear material

licensees.93-100

93-80

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

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

Dedication

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

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

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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

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lOFC : LLDR*

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LLDR*

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LLDR*

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IMNS

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NAME: DOrlando

MWeber

JAustin

MBell

DATE: 12/079 I

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3 I 3 21/93 l

112/21/93 I / /94 I

lOFC : NRR*

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OGC*

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OSP*

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TechEd*

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IMOB*

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NAME: FCongel

STreby

RBangart

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EKrauss

KRamsey

DATE: 01/21/94 I

02/07/94

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Document Name: 94-23.IN