RECEIVED TDH FEB 04 1999 BUREAU OF RADIATION CONTROL
<BR>
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<BR><BR>
February 3, 1999<BR>
<BR>
Ruth E. McBurney, C.H.P.<BR>
<BR>
Director
<BR>
Division of Licensing, Registration, and Standards<BR>
Bureau of Radiation Control<BR>
Texas Department of Health<BR>
1100 W. 49th Street<BR>
Austin, Texas 78756<BR>
<BR><BR>
Attn: Phil Shaver<BR><BR>
RE: Waste Control Specialists, LLC, License No. L04971
<BR><BR>

Dear Ms. McBurney




<BR><BR>
Waste Control Specialists (WCS) requests an amendment to License Condition 22 to authorize the use 
of the Commodore Mobile Demonstration Unit (CMDU2) to process 1-Kg batches of liquid and solid mixed 
wastes (RCRA/ radioactive) for a treatability study within the confines of the WCS "PERMACON".  
Additionally we request wording which authorize mixing within a drum, box, or pan in accordance with
 other conditions in the license.
<BR><BR>
WCS's Radioactive Material License number L04971, Condition 22, requires WCS to submit all processes
 to the Bureau of Radiation Control for authorization/ approval. This letter explains the process to
  be performed and includes the Project Work Plan's detailed instructions for operation of the unit.
   Upon successful completion of this treatability study WCS may construct a full-scale production 
   unit.
<BR><BR>
The treatability study will include a total of approximately twenty 1-Kg batches of liquid and solid
 mixed wastes (RCRA/ radioactive) to be processed by CMDU2, which chemically destructs halogenated 
 compounds by application of solvated electron chemistry. The materials will include soils (sludges),
  solvents, oils, and metals contaminated to various degrees with TCE, PERC, chlorobenzene, freon, 
  and metals (including sodium and potassium).  Approximately seven differing waste streams will 
  be processed.
<BR><BR>
The CMDU2 utilizes solvated electron chemistry to destruct halogenated compounds. This chemistry 
takes advantage of the release of free radicals (electrons) when an active metal, sodium, 
is dissolved in a suitable solvent anhydrous ammonia. Since anhydrous ammonia is not liquid at 
ambient temperatures, the system operates under pressure (less than 200 psig). The system is 
characterized as "closed", with no normal operating releases of materials to the environment. The total
 inventory of ammonia on site will be approximately 200 pounds, contained in two 100-pound DOT cylinders.
  Ammonia is moved to and from the system using these cylinders.
<BR><BR>
The Project Work Plan included with this letter details the step by step instructions for operation of the
 equipment, including: (A) System Startup, Readiness Checks, (B) Waste Batch Processing, Liquid Matrices,
  (C) Waste Batch Processing, Sludges, Soils, and Miscellaneous Solids, (D) Matenal Removal, (E) System 
  Decontamination - Dry Method, and (F) System Decontamination - Flush Method.
<BR><BR>
A description and four drawings of the CMDU2 are attached. The first, FS-1. is an overall piping diagram 
of the CMDU2 unit layout. Drawings Pl-1, Pl-2. and Pl-3 are detailed versions of the components in FS-1.
 An electronically generated picture of the unit as currently configured, and as set up at a recent 
 treatability study site, is included to provide an idea of the size of the equipment and process needed 
 to be implemented at WCS pnor to treating the waste.
<BR><BR>
The CMDU2 will be operated within the PERMACON. PERMACON ventilation will be provided by HEPA filtered exhaust
 units that are monitored for particulate radioactive contamination. The radiation safety program in accordance
  with the WCS license will control processing radioactive material.
<BR><BR>
The recommended wording for condition 22(D)(1) is:

<DD>"Solidification, stabilization, and treatment of liquid or solid radioactive waste using media acceptable to low-level waste disposal sites by:

<DD>A 55 gallon Enrico Barrel Mixer, or equivalent;
<DD> A Solvated Electron Technology processing system or equivalent; and/or
<DD> Mixing within a drum, box, or pan. This use is restricted to the Stabilizanon Building; and"

<BR><BR>

If you have any questions or need additional inforrnation please call me at 888-789-2783.

<br><BR>

Sincerely, <BR>
David Lee Kania  <BR>
[signed] <BR>
Radiation Safety Officer 
<br><BR>

Enclosures:

<DD>CMDU2 Description & Schematic Piping Diagrams
<DD>CMDU2 Work Instruction
<DD>CMDU2 Picture (color on floppy disk)
<DD>OP-1.2.18 - Treating Mixed Waste in the Perrnacon (previously submitted 12/30198)

<br><BR>
Cc:	Ken Bigham, WCS, Pasadena <BR>
William Dornsife, WCS, Pasadena <BR>
Ron Hance, WCS, Andrews <BR>
Richard Grondin, WCS, Andrews <BR>
Mark Turnbough, MT & Associates <BR>
Allen Messenger, AM Environmental <BR>
Michael Woodward, Hance, Scarborough, Woodward & Weisbart <BR> <BR> <BR> <BR>