March 6, 2001

WASTE CONTROL SPECIALISTS
1710 W BROADWAY
ANDREWS TX 79714

ATTN DAVID KANIA
RE: License No. L04971
Log No. 2001-01-0716


Dear Mr. Kania:

Agency staff have completed their review of your pre-operational monitoring plan and offer the following comments:

- WCS refers to an "11e(2)/ LLRW" facility throughout their plan. At the present time, TDH has no authority over the disposal of LLRW. WCS is advised to request information on LLRW disposal from TNRCC. References to LLRW throughout document should be removed;

- In Table 3.1, WCS lists "key" radionuclides for their monitoring program. Several of the listed radionuclides would not be expected to be found in 11e(2) material. The licensee should perhaps concentrate on the naturally occurring radionuclides which would be expected in 11e(2) material. Does the licensee expect monitoring interference or masking of byproduct radionuclide results from other disposal/ processing activities?

- Section 3.1. Performance assessments for waste facilities are done mostly for low-level radioactive waste sites. The performance of byproduct disposal impoundments is judged mostly on the basis of adequate site selection, design criteria, choice of building materials, and groundwater protection;

- Section 3.2. Non-radiological constituents of byproduct wastes are governed by §289.260(c)(17);

- Section 3.2. It is not clear how one can establish baseline for a site which may be impacted by the operation of a RCRA disposal facility. Baseline concentrations of radiological and non-radiological materials may change because of ongoing impacts from a RCRA facility and on the long term, such a facility might mask impacts from a byproduct disposal facility;

- Figure 5.1. This figure does not clearly show the location and orientation of the possible byproduct waste disposal facility. Thus, it is difficult to comment on the adequacy of sample location placement;

- Regulatory Guide 4.14 (USNRC, 1980) should also be consulted for guidance on the lower limit of detection for analytical programs;

- WCS's draft pre-operational program should delete and correct references to obsolete Texas radiation control regulations; and

- TDH Regulatory Guide 1.1 (withdrawn) and TNRCC Regulatory Guide 147 (withdrawn) provide a satisfactory outline for a pre-operational monitoring program. WCS's draft pre- operational program does not seem to include all of the radionuclides included in these documents. WCS should consult these regulatory guides and modify their pre-operational program accordingly.

No response or further action on your part is required regarding this action. If you have any question you may contact me at (512) 834-6688 ext. 2208.

Sincerely,
[signed]
Eugene (Gene) Forrer, Chief
Uranium/ NORM Program,
Division of Licensing,
Registration, and Standards
Bureau of Radiation Control

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