(A) A waste minimization policy statement
that presents the generator's goals for achieving waste
minimization/reduction/elimination, and assigns responsibility to an individual
or group to accomplish the objectives. The plan shall be approved by the
highest official of the company or institution or his/her designee, and include
a statement committing to a defined implementation schedule.
(B) A summary report which characterizes the
generator's waste streams and assesses the opportunities for waste
minimization. The report shall include a systematic review of processes,
current applicable technologies, procedures and cost requirements. An
operational assessment of the generator's activities will be required in order
to collect the necessary data and compile the summary report. Sample assessment
forms and a flow chart illustrating the assessment overview can be found in the
Department's Low-Level Radioactive Waste Minimization
Guidance. The following assessment activities are expected to be
included in the waste minimization plan and will be used to evaluate the plan:
(1) A description of the facility and the
process or service that generates the waste. This may be accomplished by
reviewing design, operating and maintenance documentation.
(2) Identification and characterization of
the waste streams which result from the process or service. Potential sources
of information include process flow diagrams, analytical test data, waste
shipment manifests, radioactive material purchase and inventory
records.
(3) Prioritization of the
radioactive sources and waste streams to select one or more for minimization.
Concerns which should be addressed when making this selection will include:
- minimization potential
- reclassification potential
- compliance with current and future regulations
- potential liability
- volume and activity of the waste
- cost/benefit relationship
(4) Analysis and selection of a
technically-feasible minimization technique or technology. The process or
service that generates the waste will be analyzed relative to the candidate
techniques or technologies. If techniques or technologies have been developed,
and minimization is believed to have reached optimum levels, the summary report
will indicate what activities will allow minimization to continue.
(5) Analysis of the direct and indirect
capital costs and operating costs associated with the minimization activity as
compared to on-site storage and increasing disposal costs.
(6) Evaluation of both tangible and
intangible benefits and detriments of minimization.
(7) Evaluation of the progress or success of
the minimization effort. This action should be undertaken periodically after
minimization plans are instituted.
(8) An operational assessment whenever a new
product or substantial change in service is being considered.
(9) Procedures which rely on reduction of the
radioactivity of the waste through decay in storage. These should include the
following:
(a) Identification of the
radioisotopes and waste which can be considered for decay in storage, and
development of a written set of procedures outlining handling and processing
steps necessary to isolate those wastes.
(b) Identification of an area where the
storage for decay can occur, and evaluation of the size of the area to ensure
it is spacious enough to accommodate all wastes to be accumulated through the
entire decay cycle.
(c)
Identification of adjacent unrestricted areas to ensure adequate shielding is
available to maintain radiation levels below specified limits.
(d) Establishment of adequate security
measures for the storage for decay area.
(e) Establishment of a radiation survey
procedure to measure radiation levels in adjacent unrestricted areas at least
weekly.
(f) Development of written
procedures to monitor the waste in the storage for decay area to ensure it has
decayed to background levels prior to disposal.
(g) Maintenance of all records for all
storage for decay and disposal activities, especially radiation
surveys.
(C)
Specification of the considerations necessary to achieve the required goals.
These considerations shall include:
(1) The
scope of work necessary to develop and implement the program;
(2) A best estimate of the schedule for
implementing each identified task;
(3) Requirements for anticipated personnel,
materials and equipment;
(4) A
range of cost estimates of all program elements; and
(5) If a minimization program is already in
place, the measures necessary to allow minimization to continue at an optimum
level should be indicated.
(D) A statement describing how future
business plans will evaluate source and volume minimization for the expected
waste streams.
(E) A description of
the strategies to be used to measure the success of the minimization
program.
(F) A summary of employee
training activities which ensure that:
(1) All
employees who work with radioactive materials have basic knowledge of common
waste problems;
(2) All workers
involved directly with the minimization program have the necessary
technological skills.
[Note: Guidance for the preparation of a minimization plan
may be found in the Generator Guidance which is available from the
Department.]
