Waste Control Specialists, LLC

Attachment C: Description of the WCS Andrews Facility
Waste Control Specialists, LLC (WCS) is a Pasadena, Texas-based environmental services firm that offers innovative and cost effective solutions for the safe management of radioactive and hazardous waste. WCS operates a state of the art facility in Andrews County, Texas, that has received permits for the treatment, storage, and disposal of radioactive, hazardous and toxic waste. WCS has formed joint waste management, research and testing partnerships with a variety of prominent waste management and research organizations in order to provide a full suite of safe, economical, and innovative services. WCS is jointly owned by KNB Holdings, Ltd. and Valhi. Inc., a diversified multinational corporation, with annual revenue of about $2 billion.

The WCS philosophy is to provide "customer friendly services" that are second to none. We encourage customers to audit our site operation prior to shipping waste to provide the necessary assurances that all waste management operations will be conducted safely, and to insure that future liability risks are acceptable.

The intent of this analysis is to demonstrate that radioactive and mixed waste from DOE facilities that contain radioactive materials which are below levels considered exempt from licensing under the Atomic Energy Act can be disposed in the RCRA permitted disposal cell (westem condo - 637,000 yd 3) at WCS. The western condo disposal cell is the only unit that is currently open.

The WCS Andrews facility is located in the extreme western part of Andrews County, Texas, adjacent to the border with New Mexico. The location is also about 30 miles east of the WIPP facility. The closest communities to the facility are the city of Andrews and the city of Eunice. The city of Andrews (1990 population 10,678) is approximately 30 miles east of the facility and is the major population center for Andrews County (1990 population was 14,338). The city of Eunice ( l 990 population was 2676) is located 6 miles west of the facility within the state of New Mexico. There are no residential areas, schools, day care centers, highway rest areas or national monuments within a five mile radius of the facility. The facility is located on a 15,915 acre company owned site (1500 acres in New Mexico), 1338 acres of which are fully permitted for the treatment, storage and disposal of RCRA and TSCA wastes (The permits allow acceptance of all RCRA and TSCA waste codes). The currently permitted disposal area can accommodate more than 11,000,000 yd 3 of waste.

The climate at the facility is classified as being arid to semi-arid and characterized by hot summers and dry winters. The average yearly total precipitation is approximately 14 inches. while the average yearly evaporation rate is approximately 63.25 inches per year. The prevailing winds from December to May are toward the north or south with wind velocities above 18 knots only 5 percent of the time. The wind velocity increases from March to May to approximately 12 percent above 18 knots and the wind direction slightly increases toward the South. During the months of June to November, the wind direction is predominantly to the south with wind velocity greater than 18 knots only 5 percent of the time. Tornadoes may pose a natural threat to the facility; however, the probability of a tornado impacting a building at the facility appears to be unlikely since Andrews County is in the area of lowest level of occurrence in Texas, and there is no record of a tornado in Andrews County. During the winter months, snow and icy conditions are possible, since the average monthly low temperature from November to February is below 32 degrees. However, as with most areas in Texas, snow and ice does not remain for extended periods of time, limiting it's effect on the facility. Norrnal operations at the facility are expected to continue throughout the winter months.

The Andrews site sits on an ancient erosional feature called the Redbed Ridge. This ridge is composed of a thick (about 800 to 1,000 foot) layer of continuous, predominately low permeability (about 10-8 to 10 -9 cm/sec red-bed clay, called the Dockum formation, that comes to within about 12-40 feet of the surface at the site. Migration times through this natural barrier have been conservatively calculated to be greater than 150,000 years. This clay layer protects the only aquifer at the site, the Santa Rosa Sandstone from any infiltration of water from the surface. The Santa Rosa aquifer is at least 900 feet below the surface and contains high levels of TDS and is considered to be non-potable. None of the rainfall that falls on the site now, and probably none of the rainfall that has fallen on the site during the entire Pleistocene and Holocene geologic time periods, has reached the Santa Rosa aquifer.

Surface deposits at the site, identified as the Antlers, Caprock Caliche, and Blackwater Draw Formations, are about 12-40 feet thick and consist primarily of eolian sand, caliche and a thin sand and gravel deposit at the base of the caliche. The high ratio of annual evapotranspiration to precipitation combined with the waste cell design (which includes removal of the surface deposits, excavation into the redbed clay, constuction of a 10 foot sidewall natural clay layer above the Dockum to the surface, and the RCRA engineered barriers) will preclude significant hydrogeologic transport from the cells to the surficial deposits even after the engineered cover ( 15 foot thick compacted clay with other engineered barriers) has hypothetically degraded.

Sandy and silty lenses in the upper part of the Dockum formation, appear to be hydrogeologically isolated and have been observed to exhibit very low rates of diffusive flow. The high iron oxide clays are expected to be very effective sorbants of radionuclides. These isolated sandy and silty lenses are unlikely to result in any off-site transport of radionuclides. At about 200 feet below the surface there is a layer of sand and silt that is saturated, but wells drilled into this layer are non-productive and is therefore not classified as an aquifer. Due to the low permeability of this layer, it serves as a ground water monitoring zone, and site monitoring wells drilled into this layer serve as an excellent natural early warning system for migration.

The Dockum surface is a smooth. gently rolling eroded surface which contains shallow depressions called "buffalo wallows". The only water wells in the vicinity of the site are shallow wells (typically windmills) used for stock watering, which tap into these shallow depressions and tend to collect water after a large precipitation events. These shallow wells contain high TDS and are typically only used for livestock watering or process water and the shallow formation is not classified as an aquifer.

There is no surface water or wetlands anywhere near the Andrews facility. The nearest potable groundwater aquifer is the Ogallala aquifer, which is located at least 10 miles northeast of the site and on the opposite side of the Redbed ridge. Potable water for site use is piped in from west of Hobbs, NM, about 20 miles northwest of the site. The only commercial activities within the vicinity of the facility consist of oilwell penetrations and a gravel and crushing operation located approximately 1 mile to the west of the facility. Adjacent land use is not expected to change during the active life of the facility. These activities will have no adverse impact upon the facility.

The following additional analyses have been performed on Andrews site:
- An evaluation has been performed with respect to its stability against potential seismic and fault activity. These studies show that there are no faults within the 3000 ft survey area with displacements in the Holocene time, and a review of probabilistic earthquake acceleration maps indicate that the project site does not fall within a seismic impact zone.
- An analysis has been performed to determine the effects ofthe 100 year flood with a conclusion that the 100 year flood has no effect upon the facility.
- An analysis has been performed to assess the potential for long term erosion at the site. Utilizing the highest estimated erosional retreat rates, it is extremely unlikely (if not impossible) that the WCS facility could be breached by erosion within the next 25,000 to 50,000 years, and more likely in excess of 100,000 years. The WCS facility is situated atop a prominent buried ridge (Redbed), which has not been breached by erosion, and has been a stable topographic feature, persisting as a drainage divide for at least the past 11 to 13 million years.
- An archeological survey was conducted with the results indicating that no cultural remains worthy of site designation were found and that the study area offered few enticements to prehistoric people or early settlers.
- A ecological study has been performed which has determined that there are no threatened or endangered species present at the site.

The nearest population center to the site is the town of Eunice more than five miles west of the site. Eunice has no municipal wells and brings water by pipe from Hobbs, New Mexico which is more than twenty miles northwest of the site. There are no municipal wells nearer to the site than those at Hobbs.

The Andrews facility may well be the best in the country from a waste isolation standpoint. The site has a suite of hydrogeologic features and processes that can be defined and are independent of one another. Representative data, low levels of model uncertainty, and low levels-of risk to human health and safety can be demonstrated and performance assessment analyses have shown that the site is in a natural state of compliance with 10 CFR 61 and NUREG 1573.

The facility has strong support from the local citizens in Andrews County and neighboring New Mexico, with little or no opposition. In fact, there has been an unprecedented level of acceptance of hazardous and low level waste management at the WCS facility. Since the industry base of Andrews County is oil and gas production, the citizens are very comfortable with and accepting of the risks of technology and understand the good geological characteristics of the site. This factor has been shown many times over to be one of the most difficult obstacles to overcome for a successful operation.

All waste that is currently authorized for disposal is placed in a RCRA cell with double plastic and clas liners and includes a double leachate collection system. The bottom of this cell extends

The facility includes an onsite EPA approved analytical laboratory that is capable of performing various testing required for verifying the characteristics of hazardous and TSCA waste and also determining that the waste meets the TCLP requirements after treatment. There is also a radiation counting laboratory that is capable of performing gamma spec and scintillation counting for confirmatory, survey, and general radiation protection purposes.

All waste is required to be shipped to the WCS site in DOT approved containers or meet DOT bulk shipping requirements. A uniform manifest will be required to document and certify the contents of the packages. The uniform manifest will be used to certify that all waste packages contain only radionuclides that meet the limits specified in TRCR Part 40. After receipt survey are performed, random samples may be taken on suspect packages based on external surveys, to verify compliance with all waste acceptance requirements. The WCS Waste Acceptance Criteria (WAC) requires that exempt level waste must meet all Part 61 waste characteristic requirements contained in TRCR Appendix 21-E (II) prior to disposal.

Exempt level waste that does not contain RCRA regulated materials. or meets the FCRA requirements for disposal, will be immediately transported to the WCS onsite RCRA/TSCA disposal cell for final disposition. The WCS RCRA/TSCA permit allows disposal of radioactive material that is not classified as low level radioactive waste. Once received, the waste will not leave the WCS licensed facility and will be handled only by appropriately trained WCS radiation workers and WCS transport vehicles under an approved radiation work permit.

Exempt level material containing RCRA materials that require treatment will be temporarily stored in the transportation containers in approved buildings awaiting staging for treatment and then moved to the Stabilization building for treatment and/or stabilization to remove the land disposal restrictions (LDR) prior to disposal. Treatment will be performed in accordance with the radiation safety program. Again the waste will not leave the WCS facility and will be handled only by appropriately trained WCS radiation workers and WCS transport vehicles under an approved radiation work permit.

The current RCRA requirements greatly exceed Part 61 in design and institutional control. This includes: a minimum of 30 verses 5 years for active maintenance, deed restrictions which prevent disturbing the cover after the facility has been closed, a 5 meter engineered cover which satisfies the Part 61 intruder barrier requirement for Class C waste. and a double lined-double leachate collection system RCRA engineered cell. The only area where RCRA requirements are different is that there is no requirement for long term government ownership.

Existing site permits and licenses require various financial assurance instruments that provide for site decommissioning and closure, site maintenance and monitoring after closure, liability protection. and cleanup and removal of waste stored on site if WCS cannot perform this activity. The radiation dose to the general public from all facility operations will be maintained ALARA and is expected to be far less than 1 mrem/yr. The radiation dose to the worker will aiso be maintained ALARA for all facility operations, and will be less than 1 mrem/yr from operations involving exempt level material treatment and disposal. All work will be performed under the existing radiation safety program and procedures. All workers are badged and trained as radiation workers.

Two categories of exempt level material have been specifically analyzed for the purpose of providing a bounding analysis for all exempt level material that is expected to be received at the WCS site. These are: (1) rare earth mixtures, compounds, and metals, at 0.2S% U and Th, which bounds most of the source material exemptions; and (2) major radionuclides at exempt concentrations, which also bounds most of the other specific exemptions.

A variety of analyses has been performed which demonstrates that disposal of these exempt level materials will result in an annual dose above background that is much less than 1 mrem/yr effective whole body dose to of any member of the public and to most of the workers. These analyses are summarized as follows:

- Infiltration through the RCRA cover has been conservatively calculated as being less than 0.00028 m/yr using the HELP model.

- Transport time to the nearest aquifer has been conservatively calculated as being greater than 150,000 years.

- Radioactive gas releases have been calculated to result in doses which are several orders of magnitude less than 1 mrem/yr.

- An intruder driller scenario has been calculated to result in doses which are about three orders of magnitude less than 1 mrem/yr.

- A RESRAD analysis, using site specific data and bounding exempt level waste streams, has been conducted which shows that the dose to the maximum exposed individual after disposal and site closure is insignificant.

- An analysis using the TSD-Dose model has been performed which shows that the dose to all workers will be less than 1 mrem, except for some high energy gamma emmitters like Co-60 and Mn-54 at the maximum exempt concentration with a dose of several mrem to the truck driver and receiving worker, assuming no radiation safety program.