RECEIVED TDH DEC 09 1998 BUREAU OF RADIATION CONTROL
<BR>
==============================
<BR><BR>
December 4, 1998
<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><BR>

Dear Ms. McBurney

<BR><BR>

Waste Control Specialists (WCS) requests agency approval to dispose of emission control dust and 
other material from electric arc furnaces or foundries, such as K061 listed hazardous wastes or other
 listed hazardous waste, as a result of inadvertent melting of a cesium-137 source in accordance with
  25 TAC ¤289.202 (ff)(2).
<BR><BR>
WCS original authorization was for the following amounts:
<BR><BR>
Pretreatment Quantities:
<TABLE>
	<TR>
		<TH>Generator</TH> <TH>Cs- 137 Activity (mCi)</TH> <TH>Approximate Weight (lb.)</TH>
	</TR>
	<TR>
		<TH>Birmingham Steel</TH> <TD>10.2</TD> <TD>816,979</TD>
	</TR>
	<TR>
		<TH>Bayou Steel</TH> <TD>28.7</TD> <TD>494,000</TD>
	</TR>
	<TR>
		<TH>AmenSteel</TH> <TD>118.5</TD> <TD>3,963,626</TD>
	</TR>
	<TR>
		<TH>TOTAL</TH> <TD>157.4</TD> <TD>5,274,605</TD>
	</TR>
</TABLE>
<BR><BR>

Authorization is required for the additional transfer of K061 Cs-137 contaminated wastes from 
License Number L04971 to the WCS hazardous waste disposal facility, Permit Number HW-50358, 
authorized by the Texas Natural Resource Conservation (Commission) in accordance 
with 25 TAC ¤289.202 (ff)(2)(E). The following K061 Cs-137 contanunated waste and associated 
secondary generated waste will be RCRA stabilized to comply with all waste treatment requirements 
of the Commission.
<BR><BR>
Pretreatment Quantities
<TABLE>
	<TR>
		<TH>Generator</TH> <TH>Cs-137 Achvity (mCi)</TH> <TH>Approximate Weight (lb.)</TH>
	</TR>
	<TR>
		<TH>Newport Steel</TH> <TD>220</TD> <TD>4,549,245</TD>
	</TR>
</TABLE>
<BR><BR>

1.	We certify that we are licensed to possess, treat or transfer the cesium-137 contaminated
incident-related material.
<BR><BR>
2.	We certify that the emission control dust and other incident-related material have been stored 
and transferred in accordance with operating procedures approved by the agency. A copy of our license is attached.
<BR><BR>



3.	We certify that the total cesium-137 activity contained in emission control dust and other

incident-related matenals to be transferred to a hazardous waste disposai facility will not be transferred 
until specifically approved by the TDH and will provide a copy of that approval when received. We certify the CS-137 activity will not exceed the total activity associated with the inadvertent melting incidents.

<br><BR>4.	A copy of the notification to the hazardous waste disposal facility of the impending transfer of the

incident related materials and a copy of the written agreement from the hazardous waste disposal facility to 
receive and dispose of the packaged or unpackaged material is attached.

<br><BR>5.	If the stabilized material has been packaged, we certify that the packaged stabilized material will

be packaged for transportation and disposal in non-bulk steel packaging as defined in the United States 
Department of Transportation regulations, Title 49 of the Code of Federal Regulations Section 173.213.

<br><BR>6.	We certify that stabilized matenal that will be packaged for transportation and disposal, at

a hazardous waste disposal facility, in non-bulk steel packaging, as defined in the United States Department of 
Transportation regulations, Title 49 of the Code of Federal Regulations Section 173.213, will not contain pretreatment 
average concentranons of cesium-137 that exceed 130 picocuries per gram of material, above background.

<br><BR>7.	We certify that the dose rate at 3.28 feet (1 meter) from the surface of any package containing

stabilized waste for disposal at a hazardous waste disposal facility will not exceed 20 &micro;rem per hour or 0.20 &micro;Sv per hour, 
above background.

<br><BR>8.	We certify that unpackaged stabilized material for disposal at a hazardous waste disposal facility

will not contain pretreatment average concentrations of cesium- 137 that exceed 100 picocuries per gram of material, above background.

<br><BR>9.	We certify that the emission control dust and other material from electric arc furnaces or foundries
for disposal at a hazardous waste disposal facility will not contain other radionuclides that are not covered under an exemption.


<br><BR>
Thank you for your attention to this matter. If you have any questions or need additional information please call me at 888/789-2783.

<br><BR>

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