RECEIVED TDH JAN 04 1999 BUREAU OF RADIATION CONTROL =================== December 30, 1998 Ruth E. McBurney, C.H.P. Director Division 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 Specialist LLC requests an amendment to the above referenced Class C license. This amendment includes: 1. A clarification to condition 22(D) to indicate the processing allowed includes the treatment of materials as described within the WCS TNRCC Permit. 2. An increase of the limit of the volume of waste present in the Stabilization Building from 3 675 cubic feet to 8,000 cubic feet in condition 23(A)(3). 3. A change to allow bulk unpackaged waste to be inventoried by actual volume within the transport container in condition 23(B). 4. Removal of the 10-day processing requirement and 30-day waste transfer requirement in the Stabilization Building, condition 25(A). In addition, this document officially submits the current resumes listing all pertinent education, training, and experience for the Management Oversight Representatives, Environmental Health and Safety Manager, Radiation Safety Supervisor, and the Laboratory Manager, as required in license condition 14. However, the management organization structure has been modified and the title of the Environmental Health and Safety Manger is now the Health and Safety Manager. The WCS organization chart has been rewritten to divide the Environmental Health and Safety Manager position and responsibilities into two separate positions; the Health and Safety Manager, and the Quality Assurance Manager, Environmental Compliance. Both positions report directly to the Facility Manager. Additionally, the Health and Safety Officer has been removed and those responsibilities are included in the responsibilities of the Health and Safety Manager. A copy of the organizational chart is included with this letter. The educational requirements for the Health and Safety Manager have been changed to an associate degree in industrial/occupational safety, radiological safety, physical science, or sixty (60) hours of related study and four (4) years experience in industrial/occupational safety in the fields of hazardous waste management, environmental science, radiological health, and/or related sciences. The educational requirements for the Quality Assurance Manager, Environmental Compliance remain the same. The Management Oversight, Health and Safety Manager, Radiation Safety Supervisor and Laboratory Manager positions have been filled with the following individuals whose resumes are included with this letter: Jesse Walker, Health and Safety Manager Lynn Parker, Radiation Safety Supervisor Steve Schneider, Laboratory Manager Michael Woodward, Management Oversight William Dornsife, Management Oversight Allen Messenger, Management Oversight Mark Turnbough, Management Oversight ITEM 1: The process described within condition 22(D)(1) is not consistent with the TNRCC permit for onsite treatment of hazardous waste at WCS. This has caused WCS to be disqualified on proposals where reviewers were looking for a particular wording. WCS requests the process described in condition 22(D)(1) include the word "treatment" and a definition for treatment be added to condition 22 or condition 15. Two procedures are attached for the treatment of materials in the Permacon or equivalent enclosure. The recommended wording for condition 22(D)(1) is: "Solidification, stabilization, and treatment of liquid or solid radioactive waste using media acceptable to low-level waste disposal sites utilizing a 55 gallon Enrico Barrel Mixer, or equivalent. This use is restricted to the Stabilization Building; and" The recommended wording, consistent with the TNRCC permit, of a definition for treatment is: "Treatment: Material processed by chemical fixation, oxidation, reduction, ph adjustment, or other means to meet land disposal requirements." ITEM 2: Material in the Stabilization Building is primarily material in transit to other buildings and K061 waste for processing. Since the K061 waste is not required to be processed inside the Permacon Structure, there is more available space in the Stabilization Building for processing waste. WCS would like to allow 8,000 cubic feet of material in the Stabilization Building without increasing the total volume allowed on site. Condition 23(A)(3) should be increased from 3,675 cubic feet to 8,000 cubic feet of waste. ITEM 3: Bulk unpackaged waste, i.e. material in rolloff bins, is material that is usually disposed of on a "per cubic foot" or "unit weight of the material" and the container is returned to the owner. Bulk unpackaged material is required to be very low activity by DOT and materials are protected from rain by an easily removal cover, usually canvas. Due to the container construction and low activity of materials, the volumes are easily verifiable. WCS requests a change in condition 23(B) that would allow bulk unpackaged waste to be inventoried by actual volume within the transport container. The recommended wording for condition 23(B) is: "Any waste container shall be counted as a full container in the volume inventory unless it can be readily verified as empty or actual volume readily determined for bulk unpackaged waste." ITEM 4: WCS proposes to remove the time requirements in condition 25(A) for processing all waste within 10 days of placement within the Stabilization Building and transferring waste out of the Stabilization Building within 30 days. This was a self-imposed time requirement that requires material to be unnecessarily moved and handled, which causes additional radiation exposure to our personnel. Eliminating condition 25(A) will reduce personnel exposure and facilitate a more practical means of tracking waste. Please contact me at 888/789-2783 if you have any questions or need additional information concerning the proposed changes. Sincerely, [signed] David Lee Kania Radiation Safety Officer Enclosures: Resumes WCS Organizational Chart OP-1.2.18 - Treating Mixed Waste in the Permacon (new) OP- 1.4.4 - In Drum Treatment Operations (revised) Cc: Ken Bigham, WCS, Pasadena William Dornsife, WCS, Pasadena Ron Hance, WCS, Andrews Richard Grondin, WCS, Andrews Mark Turnbough, MT & Associates Allen Messenger, AM Environmental Michael Woodward, Hance, Scarborough, Woodward & Weisbart file