Information Notice No. 94-23: Guidance to Hazardous, Radioactive and Mixed Waste Generators on the Elements of a Waste Minimization Program


March 25, 1994

                                   MIXED WASTE GENERATORS ON THE ELEMENTS OF A
                                   WASTE MINIMIZATION PROGRAM


All NRC Licensees.


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.

Description of Circumstances

On May 28, 1993, EPA published, in the Federal Register (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
guidance to fulfill a commitment it made in a report to Congress entitled,

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      March 25, 1994   Page 2 of 3

"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.


In the past, the predominant practice used by facilities generating hazardous
waste has been "end 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.
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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.

/s/'d by JTGreeves

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

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 2
IN 94-23
      March 25, 1994   Page 1 of 1

NRC Information Notices and Generic
Letters on the Storage of Radioactive Waste

1.Generic Letter 81-38:  "Storage of Low-Level Radioactive Waste at Power
Reactor Sites"

2.Generic Letter 85-14:  "Commercial Storage at Power Reactor Sites of
Low-Level Radioactive Waste Not Generated by the Utility"

3.Information Notice 89-13:  "Alternative Waste Management Procedures in
Case of Denial of Access to Low-Level Waste Disposal Sites"

4.Information Notice 90-75:  "Denial of Access to Current Low-Level
Radioactive Waste Disposal Facilities"

5.Information Notice 90-09:  "Extended Interim Storage of Low-Level
Radioactive Waste by Fuel Cycle and Materials Licensees"

6.Information Notice 93-50:  "Extended Storage of Sealed Sources"


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