RECEIVED TDH BUREAU OF RADIATION CONTROL SEP O3 1998 ====== September 2, 1998 Ruth E. McBurney, C.H.P. Director Divislon of Licensing, Registration, and Standards Bureau of Radiation Control Texas Department of Health 1100 W. 49th Street Austin, Texas 78756 Attn: Phil Shaver RE: Waste Control Specialists, LLC License No. L04971 Dear Ms. McBurney: Waste Control Specialists (WCS) requests an amendment to our license number L04971 to: 1. Clarify when bioassays are required for license condition 30; 2. Change the frequency of Fecal Sampling to as detemlined by the RSO; 3. Clarify wording in the Rad Con manual for whole body counting. 4. Change the holding time requirements for processing waste; 5. Change the definition of interim storage; 6. Allow records from the WCS site to be retained at the Andrews, TX office; and 7. Include the BSA as an area to sample LSA I material. A more detailed description of these proposed changes follows: 1. License Condition 30 states that an airborne release in excess of ten times the limits of 25 TAC ¤ 289.202 (ggg) (2), Table II Column 3 requires a bioassay to be performed on all individuals. The cited reference is incorrect and should be Table I. The following is the proposed change to License Condition 30: "If air sample results indicate that an airborne release in excess of ten times the levels of 25 TAC ¤ 289.202 (ggg) (2), Table I Column 3 occurred to the restricted area or to any portion of the restricted area, the licensee shall within 72 hours of the exposure, perform bioassays on all individuais who may have received 10% or more of their annual exposure limit." 2. The Radcon Manual currently, under article 521 (5), lists the frequency for fecal analysis as "Fecal analysis as required by RSO but not less than annually;" we purpose to change this to "Fecal analysis as detemlined by RSO;". It is not an industry standard to perfomm baseline fecal samples. Fecal samples are usually perfommed after uptake of a non-soluble contaminant. 3. The Radcon Manual currently, under article 521 (4), indicates "A biennial whole body count is performed to qualitatively evaluate the radiation safety program." And then under article 521 (5) indicates "Whole body counts are perforned annually to qualitatively evaluate the radiation safety program;" For consistency we purpose a change to article 521 (5) to reflect "Whole body counts are performed biennially." 4. In License Condition 25 waste holding times are limited to 10 days for processing after placement within the Stabilization Building; 30 days for transfer out of the Stabilization building after placement within the building; 180 days for placement into interim storage or transferred from the initial date of receipt; and 60 days for return to generator for waste under 23.D.4. which supercedes commitments contained in the letter submitted on May 2, 1997 subpart Q. Many of the waste materials that will be accepted at the facility require processing prior to being placed in interim storage due to RCRA requirements. The RCRA permit allows holding of waste for 1 year prior to processing. It is requested that the current requirement be modified to coincide with the RCRA permit. This is needed to develop processing plans, install equipment, request modifications and permits needed for treatment of materials. It is requested that wastes be allowed in the stabilization building for 30 days prior to processing to allow sampling and development of treatment plans. It is further requested that materials be allowed to remain in the stabilization building for 90 days after treatment. This will facilitate the post-treatment RCRA stabilization sampling to ensure materials meet land disposal requirements. This will eliminate the need of moving materials multiple 'times to and from the bin storage areas and the container storage building thus meeting ALARA goals. Material that falls under 23.D.4 could be discovered during processing and exceed the time period currently in the license. It is requested to change this to 180 days from date waste is determined to meet License Condition 23.D.4. This would allow discovery, development of disposal options for the waste and the arrangement of shipment to the generator or another facility. The following is proposed for License Condition 25: "All waste holding times shall be limited to the following: A.All wastes shall be initially processed within 30 days of placement within the Stabilization Building. All waste shall be transferred out of the Stabilization building within 90 days of treatment in the Stabilization Building. B.All waste shall be placed into interim storage or transferred to an authorized recipient within 1 year of initial date of receipt; and C.All waste authorized under License Condition No. 23.D.4 shall be returned to the generator or an appropriately authorized waste processor within 180 days of determining waste is subject to License Condition No. 23.D.4. 5. In License Condition 15.C. the definition of interim storage begins with the word stabilized. The use of this adjective is unnecessary to describe the requirement for waste to be placed in storage and creates confusion since this term is also used to describe the treatment process utilized for mixed waste. The remainder of the definition adequately states the requirements for waste acceptance for interim storage. It is proposed that the word "stabilized" be deleted from this definition. 6. Currently all documents and records are required by the License to be stored at the WCS site, Subsite 000. It is requested that records be allowed to be transferred to the WCS Andrews office at 1710 West Broadway, Andrews, TX 79714. This will facilitate the ability to transfer records to microfilm, CD ROM, or other media for historical archiving. The Andrews office has better storage facilities, including a fireproof vault install for all records. The following is proposed for License Condition 10: "Copies of all documents and records required by this license shall be maintained for Agency review at Site 000 or at the WCS Andrews office at 1710 West Broadway, Andrews, TX 79714." 7. It is requested that the Bin Storage Area be added to the areas listed in License Condition 29 A to enable the sampling and maintenance of rolloff containers. The following is proposed for License Condition 29 A: "Waste containers containing radioactive waste meeting the requirements of low specific activity material, group I (LSA-I), as specified in Title 49 of the Code of Federal Regulations, Section 173.403, may be opened for sampling of the contents or container maintenance or repair in a PermaCon, the Container Storage Building, Bin Storage Building, or Stabilization Building." If you have any questions or need additional information please call me at 888/789-2783. Sincerely, [signed] David Lee Kania Radiation Safety Officer Cc: Ken Bigham, WCS, Pasadena William Dornsife, WCS, Pasadena Ron Hance, WCS, Andrews Richard Grondin, WCS, Andrews Allen Messenger, AM Environmental Michael Woodward, Hance, Scarborough, Woodward & Weisbart =============================================================================================== Texas Department of Health 1100 West 49th Street Austin, Texas 78756-3189 (512) 458-7111 Radiation Control (512) 834-6688 William R. Archer III, M.D. Commissioner Patti J. Patterson, M.D., M.P.H. Executive Deputy Commissioner March 15, 1999 WASTE CONTROL SPECIALISTS LLC ATTN DAVID LEE KANIA 1710 WEST BROADWAY ANDREWS TX 79714 Re: Radioactive Material License No. L04971 Log No. 1998-09-0423 Dear Mr. Kania: We are currently processing your request dated September 2, 1998, for an amendment of Radioactive Material License No. L04971. With the following exceptions your requests are acceptable and will be incorporated into your license. Before further action can be taken on the changes you have requested, we need the following changes in your submittal: - Number 3 of your proposed changes should be changed to reflect annual whole counting in both article 521(4) and article 521(5) of the Radcon Manual. - Title 25 Texas Administrative Code ¤289.202 requires that all records relevant to operations be maintained at the site of operations. As such we will not be able to comply with your request to authorize the transfer of records to the WCS Andrews office. Upon receipt of two copies of the information specified above we will resume the processing of the request. Please respond within 60 days of the date of this letter, referencing the above-mentioned license number in your reply. If you have any questions concerning this matter, do not hesitate to contact me at (512) 834-6688 ext. 2208. Sincerely, [signed] Eugene (Gene) Forrer Division of Licensing, Registration, and Standards Bureau of Radiation Control bcc: file EF: ef =============================================================================================== RECEIVED TDH RADIATION CONTROL APR O5 1999 ========== April 1, 1999 Eugene (Gene) Forrer Division of Licensing, Registration, and Standards Bureau of Radiation Control Texas Department of Health 1100 W. 49th Street Austin, Texas 78756 RE: Waste Control Specialists, LLC License No. L04971 Log No. 1998-09-0423 Dear Mr. Forrer: This letter responds to the two items listed in your March 15, 1999 letter regarding the license amendment application submitted September 2, 1998. Waste Control Specialists (WCS) requests the following changes to the September 2, 1999 submittal. Item 3. The Radcon Manual currently, under article 521 (4), indicates "A biennial whole body count is performed to qualitatively evaluate the radiation safety program." And then under article 521 (5) indicates "Whole body counts are performed annually to qualitatively evaluate the radiation safety program." For consistency we purpose a change to reflect annual whole body counting in both articles. WCS withdraws the proposed amendment to Condition 10 and requests to store inactive records, records greater than 2 years old, in the WCS Andrews of fice at 1710 West Broadway, Andrews, TX 79714. If you have any questions or need additional information please call me at 888/789-2783. Sincerely, [signed] David Lee Kania Radiation Safety Officer cc: Ken Bigham, WCS, Pasadena William Dornsife, WCS, Pasadena Paul Nowlin, WCS, Andrews Richard Grondin, WCS, Andrews Mark Turnbough, MT & Associates Allen Messenger, AM Environmental Michael Woodward, Hance, Scarborough, Woodward & Weisbart