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and Type II statistical errors; and (d) provides an early warning of a release. Please demonstrate how the proposed distance between monitoring wells is conservative, including descriptions of estimated contaminant plume widths. Any modifications to the proposed groundwater monitoring system (and associated sampling) should be accompanied by updates in the cost estimates, accordingly. The Applicant also stated that the operational and post-operational radiological monitoring program for the FWF and CWF described in the REMP will be revised to be consistent with the approved groundwater monitoring program prior to initiation of operations. Please revise the description of the monitoring program accordingly in the REMP in the license application materials. 4. Comment: Answered in TNOD1 response. 5. Comment: Answered in TNOD1 response. 6. Comment: The application in Volume 1A, page 8-8F states, “For the groundwater pathway, there is no connection between the WCS facilities and the non-WCS facilities…” There is no discussion of potential lateral pathways for leachate through the OAG or the shallow Dockum. Requested Action: Please refer to Requested Action in Section 8.1.1, Comment 2. Please discuss the potential for lateral transport to the accessible environment through the OAG or permeable zones in the Dockum above the 225-foot sandstone to or from WCS facilities and non-WCS facilities. Section 8.2.1 Describe the types, chemical and physical forms, quantities, classification, and specifications of the radioactive material proposed to be received, possessed, processed, and disposed of at the land disposal facility. Provide sufficient information about the wastes projected to be disposed of at the disposal site to allow for defendable modeling of potential radiological impacts associated with waste disposal. This description shall include any prior disposal containing radioactive material at the site. This description shall include performance criteria for form and packaging of the waste or radioactive material that has been previously received and will be received. [30 TAC §§336.707(6), 305.45(a)(8)(B)(ii)] & [THSC §401.112(a)(8)] 1. Overall Comment: Answered in TNOD1 response. 2. Comment: Answered in TNOD1 response. 3. Comment: Answered in TNOD1 response. Attachment 8 Second Technical Notice of Deficiency 1/30/2006 Page 5 of 23
4. Comment: Answered in TNOD1 response. 5. Comment: Answered in TNOD1 response. 6. Overall Comment: The Applicant has not provided information pertaining to the hazardous chemical constituents and the chemical properties of the proposed 70 federal waste streams. Requested Action: Although the Applicant indicates that this information will be available in a future RCRA application submittal, this information is needed in order to fully review the adequacy of proposed LLRW facility operating procedures and design. Please provide this information and modify facility design and operating procedures accordingly to include this information. 7. Comment: The 1998 Department of Energy report “The Current and Planned Low-Level Waste Disposal Capacity Report,” Revision 1 was used in developing the source term for the FWF in Appendix 8.0-2, Vol. 9. The 2000 Department of Energy report “The Current and Planned Low-Level Waste Disposal Capacity Report,” Revision 2 is the most current information on U.S. DOE LLRW and MLLRW, and represents the latest compilation of radiological estimates for U.S. DOE waste streams. In addition, the volumes and concentrations of the proposed 70 LLRW streams (Commercial and To-be-Determined categories) are significantly different in the 2000 report. Requested Action: Please modify the source term for the FWF to incorporate the most current information from 2000 DOE report. Please clearly identify the sections, pages, tables, and appendices from the 2000 DOE report used in the selection of the volumes and the concentrations for each of the proposed streams. In addition, please update all pertinent sections of the application that would be impacted by this change. Also, please provide a compact disk containing the spreadsheets used in the calculation of the source term, as well as all tables and summary sheets from those spreadsheets. 8. Comment: In Appendix 8.0-1, Table 8.0-1-3, and page 8.0-1-14, both indicate that rare-earth processing waste was considered as part of the Texas Compact inventory. This waste is considered naturally-occurring radioactive material (NORM) and cannot be disposed of as lowlevel radioactive waste in accordance with THSC §401.004(b). Requested Action: The Applicant’s response to this comment in TNOD1 is not clear. Waste generated from rare-earth processing would likely be classified as naturallyoccurring radioactive material (NORM) and therefore cannot be disposed of in a LLRW disposal facility. Please revise the Texas Compact inventory and the dose modeling to reflect exclusion of rare-earth processing waste that is not LLRW. 9. Comment: The application in Volume 10, page 8.0-1-3 states a total volume of 2.8 million Attachment 8 Second Technical Notice of Deficiency 1/30/2006 Page 6 of 23
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Kathleen Hartnett White, Chairman R
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Attachment 1 Second Technical Notic
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the federal government will assume
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institute condemnation proceedings
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8. Comment: The following oil and g
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Requested Action: Please provide a
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Leland. Furnish an affidavit of ide
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approximately 10 km from the site s
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three of the census tracts (CT-1, C
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than heterogeneity, in conclusions
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adiation? ;(4) How might low-level
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Although the table provides three c
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costs for increased preparation for
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24. Comment: In response to TNOD1,
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1. Comment: Volume 2A, Appendix 2.3
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excavation and the proposed FWF and
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The occurrence of OAG groundwater i
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over a geologic feature referred to
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Requested Action: Please discuss in
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first sandstone below the top of Do
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Demonstrate that the disposal site
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7. Comment: Answered in TNOD1 respo
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Requested Action: It is unclear fro
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Volume 1, Section 2.7.2, when Secti
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approximately 750 feet east of the
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Dutton AR. 1995. Groundwater isotop
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hydraulic conductivity (according t
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unit into that zone. Also, such flo
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confidence interval for the mean of
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Requested Action: Please submit rel
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have little or no value 500, 1,000,
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“non-detect,” but which in this
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Attachment 3 Second Technical Notic
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in Appendix E of API 650). Also, in
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evidence is available to support th
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issues noted above. Refer to the De
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Two strategies for limiting such vo
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additional analyses. 17. Comment: T
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intended service life considerably
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additional analyses. 36. Comment: T
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Requested Action: Please submit rel
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additional analyses. Section 3.6 3.
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that an “average condition runoff
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• Please provide an analysis whic
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11. Comment: Answered in TNOD1 resp
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• Appendix 4.2.3, Part 2.7-A.2 (R
Page 93 and 94: and could possibly detect the stabi
Page 95 and 96: Requested Action: Please provide th
Page 97 and 98: include concrete, rebar, grout, san
Page 99 and 100: 16. Comment: Volume 9A, OP-3.0, pag
Page 101 and 102: Section 5.2.3 A description of how
Page 103 and 104: waste is transferred from the rail
Page 105 and 106: Requested Action: The Applicant par
Page 107 and 108: The Applicant can only seek approva
Page 109 and 110: Requirements,” states that the us
Page 111 and 112: Format and Content of a license app
Page 113 and 114: individual responsible for making o
Page 115 and 116: Requested Action: Please provide me
Page 117 and 118: 4. Comment: Answered in TNOD1 respo
Page 119 and 120: Design Features and Operating Proce
Page 121 and 122: facility that include cloth PPE. (N
Page 123 and 124: Manager and because the Health & Sa
Page 125 and 126: 6. New Comment: Some pagination in
Page 127 and 128: Attachment 7 Second Technical Notic
Page 129 and 130: the period of institutional control
Page 131 and 132: In Paragraph 5.1.5.1 the Applicant
Page 133 and 134: commonly applied to radiological da
Page 135 and 136: dependent on the sample size availa
Page 137 and 138: set of data indicating a radionucli
Page 139 and 140: plan will establish precise actions
Page 141 and 142: (1.18 in/yr), the erosion of the ea
Page 143: ability of the site to meet perform
Page 147 and 148: 14. New Comment: The Applicant may
Page 149 and 150: adioactivity in effluents from the
Page 151 and 152: Requested Action: See comment 6 abo
Page 153 and 154: and shipment conditions and charact
Page 155 and 156: hazardous mixed waste constituents
Page 157 and 158: upon descriptions of volumes of was
Page 159 and 160: portion or all of the resident intr
Page 161 and 162: determination of 7,800 years for ve
Page 163 and 164: Attachment 9 Second Technical Notic
Page 165 and 166: pressures resulting from cost and s
Page 167 and 168: The WCS inspection service contract
Page 169 and 170: (1) Design review; (2) Peer review;
Page 171 and 172: not prevent the Applicant from subm
Page 173 and 174: 4. New Comment: Volume 11A, Appendi
Page 175 and 176: (1) Adjustment and calibration usin
Page 177 and 178: Attachment 10 Second Technical Noti
Page 179 and 180: 6. New Comment: Neither document de
Page 181 and 182: Attachment 11 Second Technical Noti
Page 183 and 184: Hydrology, Hydorgeology: • The Ap
Page 185 and 186: 13. New Comment: The application in
Page 187 and 188: Requested Action: Please provide a
Page 189 and 190: licenses.” Requested Action: Plea
Page 191 and 192: Requested Action: What is the basis
Page 193 and 194: would require that the full actual
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discounted dollars for two reasons.
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protection, and other necessary eng
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time value of money to meet full fu
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Note: Cost estimates as expressed i
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