December 18, 2000
Dale Burnett
Director, Waste Permits Division
Texas Natural Resources Conservation Commission
Mail code 126
P.O. Box 13087
Austin, Texas 78711-3087

RE: Letter from Richard Ratliff, Chief, Bureau of Radiation Control, Texas Department of Health to your office, dated November 30, 2000.

Dear Mr. Burnett:

Waste Control Specialists has received a copy of the subject letter and offers the following comments regarding it contents.

WCS does not agree that the Waste Acceptance Procedures (WARP) for radioactive material under our RCRA permit do not adequately address acceptance of non-NORM material. We believe that use of this procedure for non-NORM exempt material is conservative in that it will result in additional testing, specifically a radon emanation test, which is not necessary for non-NORM material.

Based on recent concerns expressed by the Bureau of Radiation Control (BRC), WCS has not been accepting surface contaminated equipment that is not rubblized and that can not be sampled/analyzed as uniformly contaminated bulk waste. As suggested in an August 18, 2000 letter from the BRC to WCS, we have been using the BRC guidance document entitled, "Basic Guidance for Determining That Material is Exempt from Regulation", for the review and approval for acceptance of exempt material for disposal at WCS.

We also believe that the comparison of our waste acceptance procedures to that used by the Texas Ecologists Robstown site is not appropriate. Compared to what is currently in place at the WCS site, they do not have a detailed TNRCC approved waste acceptance procedure under their RCRA permit, nor the qualified onsite personnel and equipment to assure that the waste meets all appropriate criteria before acceptance. They also do not have an onsite radiation protection program that applies to acceptance and handling of all exempt material.

If you have any concerns or questions regarding this letter, you may contact me at 717-540-5220.

Sincerely,
William P. Dornsife
Vice President-Nuclear Affairs

cc:
TDH, Richard Ratliff, Chief, Bureau of Radiation Control
TNRCC, Alice Rogers, Section Manager, UIC and Radioactive Waste
TNRCC, Wade Wheatley, Section Manager, Industrial Hazzards and Waste Permits