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does not include a map of railroad routes and road-railroad intersections. The discussion of rail shipments seems to conflict with other parts of the application that state that waste will not arrive by railroad. Requested Action: Please respond to the following transportation-related items: (1) Please define the term “Rail Shipment.” (2) Please add information from TXDOT and NMDOT regarding any proposed plans that will change traffic patterns along the proposed transportation routes, such as plans to build new roads or add stoplights to busy highway intersections. (3) For each likely waste client, provide data for the transportation plans (rail vs. truck, number of shipments, proposed route). Discuss how waste would be routed from the major interstate highways to the WCS facility, including routes through and around local cities (Andrews, Eunice, Hobbs, Seminole, Jal, Midland/Odessa). Provide a map showing these transportation routes. Explain how estimates for 700 additional truck shipments and 450 additional rail shipments were determined. Please refine this estimate as needed. For instance, please discuss what impacts may occur from additional waste transport associated with other facilities on the site; e.g., byproduct waste shipments from West Chicago. Discuss how the increased traffic is likely to affect road and railroad conditions and whether usage will affect road and railroad maintenance schedules. Please add this information to cumulative effects evaluation. Please mention the outcome of any meetings with regional planning organizations that deal with transportation issues. (4) Please add accident statistics data for Andrews County and Lea County, as requested, from TXDOT and NMDOT for Highways SH 176, US 385, FM 1788, FM 181, and FM 1967. Also, please provide more information on the model used to calculate the statistical probability for traffic accidents. Indicate whether this figure includes the entire route from source to the facility. (5) No further requests. (6) Please provide a map that illustrates all road-railroad intersections. Please clarify whether the proposed facility will involve rail shipments, and ensure that the application is consistent on this issue. 26. New Comment: In Section 2.3.3 of the SIA, it is noted that the Compact portion of the new facility is tax-exempt. Further, “[i]n lieu of the lost tax revenue arising from the conveyance of the Compact portion of the new facility to the state, WCS has begun contributing annually to the Andrews ISD Education Foundation. In order to assess the impacts to the local community, more information is required regarding this agreement. Requested Action: Please provide statements from the Andrews ISD Education Foundation detailing expectations regarding this agreement to compensate for lost tax revenue. If these funds are channeled through the Andrews Industrial Foundation, please provide an additional letter of explanation from the Andrews Industrial Foundation. Section 2.3.1 Describe and quantify area and site characteristics including air quality, meteorology, climatology, and natural hazards. [THSC §401.112(a)(1)] & [30 TAC §336.708(a)(3)] Attachment 2 Second Technical Notice of Deficiency 1/30/2006 Page 15 of 51
1. Comment: Volume 2A, Appendix 2.3.1 has provided four years of site-specific meteorological data. TCEQ has historically used five years of site-specific meteorological data in performing Site Specific Risk Assessments. Requested Action: Please add site-specific meteorological data for 2004 and 2005 to the meteorology section, and amend all data and summary tables in Volume 2A, Appendix 2.3.1 to include this information. Section 2.4.1 Describe and quantify area and site characteristics, including surface hydrology. [THSC §401.233(b)] & [30 TAC §336.708(a)(3)] 1. Comment: The application states that there are no “sustainable surface water bodies within five miles of the site” (Volume 1, Section 2.4.1). While it is not clear what is meant by the word “sustainable”, it is evident from a recent site visit by agency staff that surface water features such as Baker Spring and nearby playas contain water or evidence of water ponding. Requested Action: The Applicant has provided information on downstream surface and groundwater users and has provided a drought study. The Applicant also has identified several surface water bodies within five miles of the facility, but has not described the surface water bodies. These descriptions should include drainage basin maps of the surface water bodies, quantification of run-on and runoff under different storm events, and to what extent the occurrence of surface water may influence groundwater. • Please identify and describe all surface water bodies, of any description, that retain water for a number of days and occur within a radius of five miles of the proposed facility. These descriptions should include drainage basin maps of the surface water features, quantification of run-on and runoff under different storm events, and an explanation of why there is surface water given the high evapotranspiration rate. (Please refer to Site Characterization Handbook for Low Level Radioactive Disposal Facilities, DOE/LLW 67T, Appendix A, for additional guidance on these subjects). 2. Comment: Answered in TNOD1 response. 3. Comment: Answered in TNOD1 response. 4. Comment: Run-off from the diversion ditches appears to discharge flow into an existing ditch/stream at a greater amount than that under existing conditions. This increase in flow could lead to downstream gully erosion, which could possibly encroach onto the landfill. Releasing this run-off at flows equal to or less than existing conditions, or lining the existing ditch/channel with erosive resistant materials are suggestions which can minimize this downstream erosion and assure long term stability of the site. Attachment 2 Second Technical Notice of Deficiency 1/30/2006 Page 16 of 51
Page 1 and 2: Kathleen Hartnett White, Chairman R
Page 3 and 4: Attachment 1 Second Technical Notic
Page 5 and 6: the federal government will assume
Page 7 and 8: institute condemnation proceedings
Page 9 and 10: 8. Comment: The following oil and g
Page 11 and 12: Requested Action: Please provide a
Page 13 and 14: Leland. Furnish an affidavit of ide
Page 15 and 16: approximately 10 km from the site s
Page 17 and 18: three of the census tracts (CT-1, C
Page 19 and 20: than heterogeneity, in conclusions
Page 21 and 22: adiation? ;(4) How might low-level
Page 23 and 24: Although the table provides three c
Page 25 and 26: costs for increased preparation for
Page 27: 24. Comment: In response to TNOD1,
Page 31 and 32: excavation and the proposed FWF and
Page 33 and 34: The occurrence of OAG groundwater i
Page 35 and 36: over a geologic feature referred to
Page 37 and 38: Requested Action: Please discuss in
Page 39 and 40: first sandstone below the top of Do
Page 41 and 42: Demonstrate that the disposal site
Page 43 and 44: 7. Comment: Answered in TNOD1 respo
Page 45 and 46: Requested Action: It is unclear fro
Page 47 and 48: Volume 1, Section 2.7.2, when Secti
Page 49 and 50: approximately 750 feet east of the
Page 51 and 52: Dutton AR. 1995. Groundwater isotop
Page 53 and 54: hydraulic conductivity (according t
Page 55 and 56: unit into that zone. Also, such flo
Page 57 and 58: confidence interval for the mean of
Page 59 and 60: Requested Action: Please submit rel
Page 61 and 62: have little or no value 500, 1,000,
Page 63 and 64: “non-detect,” but which in this
Page 65 and 66: Attachment 3 Second Technical Notic
Page 67 and 68: in Appendix E of API 650). Also, in
Page 69 and 70: evidence is available to support th
Page 71 and 72: issues noted above. Refer to the De
Page 73 and 74: Two strategies for limiting such vo
Page 75 and 76: additional analyses. 17. Comment: T
Page 77 and 78: 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
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and could possibly detect the stabi
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Requested Action: Please provide th
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include concrete, rebar, grout, san
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16. Comment: Volume 9A, OP-3.0, pag
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Section 5.2.3 A description of how
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waste is transferred from the rail
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Requested Action: The Applicant par
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The Applicant can only seek approva
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Requirements,” states that the us
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Format and Content of a license app
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individual responsible for making o
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Requested Action: Please provide me
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4. Comment: Answered in TNOD1 respo
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Design Features and Operating Proce
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facility that include cloth PPE. (N
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Manager and because the Health & Sa
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6. New Comment: Some pagination in
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Attachment 7 Second Technical Notic
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the period of institutional control
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In Paragraph 5.1.5.1 the Applicant
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commonly applied to radiological da
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dependent on the sample size availa
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set of data indicating a radionucli
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plan will establish precise actions
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(1.18 in/yr), the erosion of the ea
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ability of the site to meet perform
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4. Comment: Answered in TNOD1 respo
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14. New Comment: The Applicant may
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adioactivity in effluents from the
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Requested Action: See comment 6 abo
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and shipment conditions and charact
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hazardous mixed waste constituents
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upon descriptions of volumes of was
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portion or all of the resident intr
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determination of 7,800 years for ve
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Attachment 9 Second Technical Notic
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pressures resulting from cost and s
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The WCS inspection service contract
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(1) Design review; (2) Peer review;
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not prevent the Applicant from subm
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4. New Comment: Volume 11A, Appendi
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(1) Adjustment and calibration usin
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Attachment 10 Second Technical Noti
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6. New Comment: Neither document de
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Attachment 11 Second Technical Noti
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Hydrology, Hydorgeology: • The Ap
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13. New Comment: The application in
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Requested Action: Please provide a
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licenses.” Requested Action: Plea
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Requested Action: What is the basis
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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
Page 201:
Note: Cost estimates as expressed i
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