RECEIVED - JUL 09 1999 - BUREAU OF RADIATlON CONTROL
WASTE CONTROL SPECIALISTS LLC
July 7, 1999
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 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).
WCS current authorization is for the following amounts:
Pretreatment Quantities
| Generator | Cs-137 Activity (mCi) | Approximate Weight (lb.) |
| Birmingham Steel | 10.2 | 816,979 |
| Bayou Steel | 28.7 | 494,000 |
| AmeriSteel | 118.5 | 3,963,626 |
| Newport Steel | 220.0 | 4,549,245 |
| TOTAL | 377.4 | 9,823,850 |
Additional materials have been generated at Newport Steel and 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 (TNRCC) in
accordance with 25 TAC § 289.202 (ff)(2)(E). The following K061 Cs-137 contaminated waste and associated
secondary generated waste will be RCRA stabilized to comply with all land disposal restrictions.
Additional Pretreatment Quantities from Newport Steel
| Generator | Cs-137 (mCi) | Approximate Weight(lb.) |
| Newport Steel | 275 | 8,400,000 |
1. WCS certifies it is licensed to possess, treat or transfer cesium-137 contaminated incident-related
material.
2. WCS certifies 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.
3. WCS certifies the total cesium-137 activity contained in emission control dust and other incident-related materials to be transferred to a hazardous waste disposal facility will not be transferred
until specifically approved by the TDH and will provide a copy of that approval when received.
WCS certifies the CS-137 activity will not exceed the total activity associated with the inadvertent melting incidents.
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.
5. If the stabilized material has been packaged, WCS certifies 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.
6. WCS certifies the stabilized material 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 concentrations of cesium-137 that exceed 130
picocuries per gram of material, above background.
7. WCS certifies 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 µrem per
hour or 0.20 µSv per hour, above background.
8. WCS certifies that unpackaged stabilized material for to be disposed 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.
9. WCS certifies the emission control dust and other material from electric arc furnaces or foundries
to be disposed at a hazardous waste disposal facility will not contain other radionuclides that are
not covered under an exemption.
Thank you for your attention to this matter. If you have any questions or need additional information please call me
at 888/789-2783.
Sincerely,
[signed]
David Lee Kania
Radiation Safety Officer
Cc: Eric Peus, WCS, Pasadena
William Dornsife, WCS, Pasadena
A. Paul Nowlin, WCS, Andrews
Richard Grondin, WCS, Andrews
Mark Turnbough, MT & Associates
Allen Messenger, AM Environmental
Michael Woodward, Hance, Scarborough, Woodward & Weisbart