Section 120.897 - Waste Minimization Plan ContentA waste minimization plan shall include:
(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.]