wCS

Attachment 1Rev. 11/15/00

Attachment 2

WASTE CONTROL SPECIALISTS, LLC

(WCS)

ANDREWS, TEXAS FACILITY

w C s Waste Control Specialists LLC

AuditSourceT' www.tsdaudits.com

AUDIT INFORMATION REPORT: MARCH 2000

Attachment 3

TABLE OF CONTENTS

1.0 INTRO D UC TIO N ................................................ 1.1 Scope of the Evaluation ................................... 1.2 Com pany Profile ......................................... 1.3 S ite H istory ..............................................

2.0 FACILITY SETTING ............. 2.1 Location & Description 2.2 Surrounding Land Use 2.3 Topography & Climatology 2.4 Geology & Hydrology .... 2.5 Accessibility ...........

SUMMARY OF PERMITS, LICENSES, AND APPROVALS .............. 3.1 Authorized W astes .................................. 3.2 Prohibited W astes .......................................

WASTE MANAGEMENT SYSTEMS AND OPERATIONS ................ 4.1 Current and Proposed Operations ..........................

4.1.01 Use and Management of Containers .............. 4.1.02 Tank Systems ............................... 4.1.03 Surface Impoundment ....................... 4.1.04. W aste Piles .................................. 4.1.05 Land Treatment ............................... 4.1.06 Landfills .................................... 4.1.07 Incinerators .................................. 4.1.08 Drip Pads ... ................................ 4.1.09 Injection W ells ................................ 4.1.10 Thermal Desorption ............................ 4.1.11 Solvent Distillation .......................... 4.1.12 Fuel Blending ................................ 4.1.13 W astewater Treatment ...................... 4.1.14 Miscellaneous Units ............................

4.2 Laboratory and Receipt Control ........................... 4.2.01 Laboratory .............................. 4.2.02 Receipt Control ...............................

4.3 W aste Tracking ..................................... 4.4 Past Unit Operations ................................

RESIDUALS MANAGEMENT .................................. 5.1 Residuals Generated ............................... 5.2 On-Site Management of Residuals ..................... 5.3 Off-Site Management of Residuals .....................

........... 3 .1

........... 3.1

........... 3.1

S4.1 S. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 .1 4.1 S. . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 .5

S~4.5 .. 4.8 .......... .... 4 .8

................. ..................................................... 4.8 ........................ ..................................................... 4.8

.................. .................................................... 4.10 ........................ .................................................... 4.10 ........................ .................................................... 410

........................ .................................................... 4.10 ........................ .................................................... 4.10

........................ .................................................... 411 ........................ .................................................... 4.11

4.11

........................ .................................................... 4.11 ..... 4.11 S. . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 .1 1 .......... ........................................... 4.12

.. ....................................... ............ 4.13 .... ................................................... 4.13

.. . . . . . . . . . . . . . . . . . . . . . . . .. . . 5 .1

.. . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 .1

S. . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 .1 ....... .... ... .... ...5 .1

R EG U LATO RY C O M PLIA NC E .......................................................................................... 6.1

6 .1 A gency C ontacts 6.1.................................... .. ..... ........ ............... ............. 6 .1

6.2 Sum m ary of Agency Inspection Report(s) ............. .... . . ................ ................. .............. . .6.1

6.3 C E RC LA A uthorization .............................. ........ ....................... ................ 6.2

6 4 Current Site-Specific Litigation .... .................. ........... .... .............. ....... ...... 6.2

6.5 Reportable Quantity (RQ) Releases & Contingency Plan Responses ........................................... .. 6.2

6.6 RC RA Facility Investigation .................................... .............................................. 6.2

6.7 Review of AIRS, CERCLIS, PCS, RCRIS, and TRIS Databases .............. ............................... 6.2

7.0 RISK MANAGEMENT, RISK REDUCTION PLANS, PROGRAMS, AND PROCEDURES ....................................... 7.1

7.1 Environmental Management Systems .............. ........................................................... 7.1

7.2 Training .................................................................................................. 7.2

7.3 Emergency Procedures and Contingency Plans ........................................................ ......... 7.2

7 .4 Inspections ............................................................................ ............ ....... 7 2

7.5 Security ..................................................................... ............................ 7.2

7.6 Environmental M onitoring ........................ ............................................ ............... 7.2

7.6.01 Air Emission Control & Monitoring ................................................................... 7.2

7.6.02 Storm W ater Discharge Control & Monitoring ........................................... ............... 7.3

7.6.03 G roundwater M onitoring 7............................................................. .............. 7.3

7 .8.04 S ite S urveys ........ 7............................................................ .............. 7 .4 7.7 Health and Safety Programs .........................

7.4

7.8 Maintenance ................................ 7.5

7.9 Housekeeping ................................... 7.5

7.10 Record Keeping Requirem ents ............................................................. ................. 7.5

7.11 Fire P rotection S ystem s ................................................ ................... ......... ..... . . 7.5

8.0 FINA NC IA L A NA LYSIS ................................. ......... .... ....... ...... 8.1 Financial Resources & Ratios ............................ .... : ....... 8.2 Closure Costs and Financial Assurance ........................ . ....... ... 8.3 Insurance ...... ... .. ..... ..... .......

8.4 Company Financial Statements ............................ ............

8.1 8.1

.... 8.4 S. . .. . . . . . . . . . . . . . . . . . . . . . . . 8 .4

.. . . . . . . . . . . . . . . . . . . . . . . . . . . . ý . . 8 .5

3.0

4.0

S. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. I. . . . . . . . . . . .. . -. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .

S. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . S. . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 1

S. . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 -1

2.1

S.. . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 .2 S. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 .3

S. . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 -3

12.

5.0

6.0

................................... ............I .....................

................................... ........I ......................... ................. ................. ...................................

.1 .........................

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NOTICE

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While a concerted effort has been made to prepare an accurate and representative report of the subject facility, the

accuracy of any review of this nature is necessarily limited by the completeness and accuracy of the information provided

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substance including, but not limited to, smoke, vapor, soot, fumes, acids or alkalis, chemicals and waste.

1.0 INTRODUCTION

1.1 Scope of the Evaluation

The AuditSourceTM Audit Information Report for each waste management facility contains consistent types of

information which can be found in the same section of each individual informational report and is prepared under direction

of the facility described. This format has been developed to allow generators to make a comparison between facilities

which perform similar waste management activities. The AuditSourceTM Baseline Audit Report, available only from

AuditSource, summarizes the findings of an on-site audit and is based on the factual observations accumulated during

an on-site inspection, literature reviews, electronic database searches, discussions with company representatives, and

interviews with regulatory agency inspectors. The AuditSourceTM Audit Information Report and Baseline Audit Report

represent point-in-time reviews of this facility's environmental, financial, operational, and managerial practices including

on-site audits conducted in 1997, 1998, and in March 2000. AuditSource prepares technical reports of treatment,

storage, disposal, and recycling facilities (TSDRFs) for dissemination to their current and prospective clients. These

reports are copyrighted and available exclusively from orthrough AuditSource and can be acquired from the office noted

below:

Edmond, Oklahoma 405-715-2523 dhensch@sisna.com

0 Enid, Oklahoma 580-242-0144 envegr@ionet.net

www.tsdaudits. coom

Audit Process

The audit process consisted of an initial request for documents from the state agency (TNRCC) which has jurisdiction

over the facility's operations. AuditSource reviewed permit documents and compliance inspection reports available by

the TNRCC and files associated with the operation of the facility. AuditSource also interviewed regulatory agency

personnel regarding the compliance history and status of the facility and reviewed and compared regulatory information

and documentation supplied by the facility to the applicable state and federal regulations. In addition, AuditSource met

with facility management, and obtained copies of the facility layouts, permits, approvals, plans, policies, and procedures.

During this document review, AuditSource prepared specific questions relating to the facility's past, present, and

anticipated future operations. In addition to these facility-specific questions, AuditSource used audit protocols

specifically developed for waste treatment, storage, disposal & recycling operations, as applicable. All inquires, including

those set out in the audit checklists, were tailored to fit the individual facility operations. The AuditSourceTM Baseline

Audit Report is based upon objective check lists, conversations with facility management, operational staff, and

observations made at the facility during the site inspection.

1.2 Company Profile

Waste Control Specialists LLC (WCS), formed in 1995, completed construction in early 1997 of the initial phase of its

facility in West Texas for the processing, treatment, storage, & disposal of RCRA & TSCA wastes, and the 1st wastes

were received on-site in February 1997. Subsequently, WCS has expanded to include the management of low-level and

mixed radioactive wastes and thermal desorption.

In November 1997, the Texas Department of Health (TDH) issued a license to WCS for the treatment and storage, but

Waste Control Specialists, LLC - Andrews, Texas: March 2000

AuditSource rmAudit Information Report: Copyright 2000 11

AuditSourceTM AUDIT INFORMATION REPORT

WASTE CONTROL SPECIALISTS, LLC

ANDREWS, TEXAS FACILITY

not disposal, of low-level and mixed radioactive wastes. The current provisions of this license generally enable the facility

to accept such wastes for treatment and storage from U.S. commercial and federal facility generators, including the

Department of Energy (DOE) and other governmental agencies. WCS has also been issued a permit by the TNRCC to

establish a research, development, and demonstration facility in which 3 rd parties could use the facility to develop and

demonstrate newtechnologies in the waste management industry, including possiblythose involving low-level and mixed

radioactive wastes. WCS has also obtained additional authority to dispose of certain categories of low-level radioactive

materials, including naturally-occurring radioactive material (NORM) and exempt-level materials (radioactive materials

that do not exceed certain specified radioactive concentrations and which are exempt from licensing). Although there

are other categories of low-level and mixed radioactive wastes which continue to be ineligible for disposal under the

increased authority, WCS continues to pursue additional regulatory authorizations to expand its treatment and disposal

capabilities for low-level and mixed radioactive wastes.

The facility is located on a 1,338-acre site in West Texas owned by the company with 11.3 MM yds 3 of permitted airspace

landfill capacity for the disposal of RCRA and TSCA wastes. Following the initial phase of the construction, WCS had

- 400,000 yds 3 of airspace landfill capacity and expects to begin construction during 2000 for the next 240,000 yds3 of

capacity. As part of its current permits, WCS has the authorization to construct separate "condominium" landfills, in

which each condominium cell can be dedicated to an individual customer's waste materials. WCS owns - 15,000

additional acres of land surrounding the permitted site, a small portion of which is located in New Mexico.

In 1999, WCS donated part of their land holdings in New Mexico to local political jurisdictions for the construction of the

Lea County (Municipal) Landfill.

The site has superior geological characteristics which make it an environmentally-desirable location and is located in a

relatively remote and arid section of West Texas. The ground is composed of triassic red bed clay for which the

possibility of leakage into any underground water table is considered highly remote.

While the West Texas facility operates as a final repository for wastes that cannot be further reclaimed and recycled,

it also serves as a staging and processing location for materials that require other forms of treatment prior to final

disposal as mandated by EPA or other regulatory bodies. The facility, as constructed, provides for waste treatment,

stabilization, container storage, treatment facilities for hazardous, toxic and dioxin wastes, drum to bulk, and bulk to drum

materials handling and repackaging capabilities. Treatment operations involve processing wastes through one or more

thermal, chemical or other treatment methods, depending upon the particular waste being disposed and regulatory and

customer requirements. Thermal treatment uses a thermal destruction technology as the primary mechanism forwaste

destruction. Physical treatment methods include distillation, evaporation and separation, all of which result in the

separation or removal of solid materials from liquids. Chemical treatment uses chemical oxidation and reduction,

chemical precipitation of heavy metals, hydrolysis and neutralization of acid and alkaline wastes, and basically results

in the transformation of wastes into inert materials through one or more chemical processes. Certain of such treatment

processes may involve technology which WCS may acquire, license or subcontract from third parties.

Once treated and stabilized, wastes are either (i) placed in the landfill disposal site, (ii) stored on-site in drums or other

specialized containers or (iii) shipped to 3rd-party facilities for further treatment or final disposition. Only wastes which

meet certain specified regulatory requirements can be disposed of by placing them in the landfill, which is fully-lined and

includes a leachate collection system.

WCS's target customers are industrial companies, including chemical, aerospace and electronics businesses and

governmental agencies, including the DOE, which generate hazardous and other wastes and customers outside a 500

mile radius can be handled via on-site rail lines.

At December 31, 1999, WCS employed - 120 persons.

Waste Control Specialists, LLC - Andrews, Texas: March 2000

1.2 AuditSource "Audit Information Report: Copyright 2000

2.0 FACILITY SETTING

2.1 Location & Accessibility

WCS is located in the add/semiarid West Texas high desert, near the Texas/New Mexico border, - 30 miles west,

northwest of of Andrews, Texas in Andrews County, and 1/2 miles north of State Highway 176. The western edge of

the site is about 250' east of the New Mexico state line.

Commercial Incineration & Thermal Desorption FacilitiesCommercial RCRA & TSCA Landfills

The City of Andrews is - 35 miles north of Midland - Odessa and on State Highway 385. Eunice, New Mexico, the

nearest community, is 6 miles west of the facility. A TxDOT traffic survey conducted on Highway 176 near the New

Mexico border indicates a moderate volume of vehicles traveling on the highway per day. The TxDOT estimates 1,950

vehicles use the road per day and that 30% of that is made up of large trucks associated with oil and gas activities.

The facility is expected to process and dispose of - 2,750 yds3 of hazardous and non-hazardous wastes per day. In order

Waste Control Specialists, LLC - Andrews, Texas: March 2000

AuditSource TmAudit Information Report: Copyright 2000 2.1

we td. con"tTO 10d0twtWaste Control SpeclaUsts

to stay in constant operation, 91 trucks carrying 30 yd 3 bins' would enter the facility daily (if all wastes arrived by over-the

road vehicles). Construction activities and employee transportation would add an additional 75 vehicles per day, an

increase from 1,950 to 2,116 vehicles a day (an increase of < 9%). Large truck traffic would increase from 585 trucks

(30% of 1,950) to 701 (91 carrying wastes + 25 carrying construction materials) and constitutes < a 20% increase.

Due to the high amount of oil field activities occurring in and around Andrews County, the residents of the area are

accustomed to large truck traffic. According to the design engineer in the Odessa office of the TxDOT, Highway 176 is

constructed with an 8' shoulder which is adequate to build a turning lane into the facility for vehicles entering the facility

from the east. Trucks traveling from the west should not cause any traffic problems crossing the westbound lane of 176

and the department has placed warning signs to alert highway traffic of the facility entrance. The district representative

of the TxDOT has agreed to assist WCS with the design and construction of modified turning lanes, if any problems arise.

COMMENT:

During the 10/98 audit, the turning lane off of Highway 176 into the facility was observed to have been constructed and

operational.

2.2 Surrounding Land Use

The property owned by WCS includes 1,338 acres within a •

15,215 acre tract and no residences exist in close proximity.

The nearest residence is 1 mile east of the facility, resides .,

on the company's land in an existing ranch house, but it is not

occupied. The nearest occupied residence is in or near

Eunice, - 6 miles west of the facility. The 1990 population of

Andrews County is 14,338 and the Eunice population is 2,676.

Land surrounding the facility for a 2-mile radius shown in the

following drawing is predominantly agricultural and there are

no sensitive receptors (schools, hospitals, etc.) within 3 miles

of the plant. The nearest river or stream is the Nueces and is

located > 10 miles away from the site. The nearest public Site View and Surrounding Land Use (02/00)

drinking water supply is located - 6 miles away in Eunice,

New Mexico and serves a population of - 11,061 people, including WCS. This water is supplied by a pipeline west of

Hobbs, New Mexico, - 20 miles north.

2.3 Topography & Climatology

The area on which the WCS Facility sits is gently rolling low

hills with little vegetation. Low depressions dot the desert

ranch land and areas of run-off erosion channels are

occasionally encountered. Spring, Summer, and Fall,

prevailing winds are generally from the South and Southwest.

December through May is slightly different as the winds shift,

and are variable from either North or South, for the period of

March through May, with winds usually to the South.

Hot summers and dry winters characterize this high desert

setting. The average yearly precipitation is - 14" with an

evaporation rate of more than 63". Most precipitation is

received via infrequent storms with most precipitation runoff

settling in depressions and evaporating rather quickly. The

clay rich sandy soils absorb the balance of the rain water.

The source of this information is the "Site Selection Report" provided by WCS. As an editorial note, very few loads of hazardous waste are delivered

in 30 yd3

containers as most bulk loads are delivered in 20 yd3 containers. However, this facility has rail capability which should lower the number

of over-the-road vehicles.

Waste Control Specialists, LLC - Andrews, Texas: March 2000

22 AuditSource "'Audit Information Report: Copyright 2000

There are no major streams or rivers within 10 miles of the area and topography of the site is relatively flat with little

drainage relief. The tract is within segment 2311 of the Rio Grande River Basin and any surface sheet flow falling into

the general vicinity is towards the New Mexico/Texas border in dry gulches. The site is not located within the FEMA

(Federal Emergency Management Agency) 100-year flood plain. In general, the active portions of the facility are located

on a topographic high, mitigating the potential for flooding. The average slope of the ground surface is < 2%.

2.4 Geology & Hydrology

The most shallow groundwater observed during the geologic investigation, except for a small area ponded on top of the

redbed, occurs > 150' below ground surface. The uppermost portion of this saturated zone occurs in the redbed clays

Waste Control Specialists, LLC - Andrews, Texas: March 2000 AudltSource TM Audit Information Report: Copyright 2000 2.3

and silts. Monitoring wells installed in this zone have lowyields. The maximum estimated rate of groundwater movement

in the shallow Dockum, based on the monitoring wells installed in the landfill area is < 5' per year.

There is > 80' of Dockum formation between the area of waste placement and these saturated soils. Given the low

average permeability of the redbed, the desert climatology, and landfill design and operational specifications, there is

a low potential for leachate from the wastes to impact groundwater. The 1st saturated soils down-gradient of the landfill

waste management area is monitored as further assurance the landfill does not adversely affect groundwater resources.

At ground surface there is a fine sand which is generally underlain by a soft to very hard caliche and both cemented and

uncemented sands and gravels. In limited areas there are pockets of sand and gravel immediately over the redbed. The

facility is not located over a major aquifer. The upper-most aquifer is a siltstone body located in the Chinle formation

which is part of the Dockum group, a thick massive predominantly clay formation. The saturated siltstone is a local

feature with the Chinle that does not have sufficient yield to be usable (- 0.05 gpm). The 1 st usable groundwater occurs

in the lower Dockum Group at a depth > 800', the Santa Rosa aquifer. The Santa Rosa is a minor aquifer that contains

- 2,500 mg/I total dissolved solids and is not a potable water source. The sodium content of the Santa Rosa prevents

it from being used as a source of irrigation water. The Santa Rosa is separated from the WCS landfill by > 800' of low

permeability clays and silts with some sandstones. Geologists theorize the Santa Rosa was recharged - 35,000 years

ago when it outcropped in New Mexico. There is no recharge occurring vertically through the Dockum Formation to the

Santa Rosa aquifer at the WCS site. The soils above the Dockum Formation consist of the Trinity Group (Antlers

Sandstone), Caprock Caliche and eolian deposits. This perched groundwater was determined to be limited in volume

and area and will be removed and beneficially used as part of landfill development.

The 1 st continuous water bearing zone beneath the active portion of the facility, which is also designated as the

uppermost aquifer by the TNRCC and the EPA, occurs in a Triassic age formation which is predominantly a very low

permeability clay (Dockum Formation). During the site investigation, the bulk of the Dockum samples exhibited hydraulic

conductivity's of < 1 x 10,7 cm/sec. There are silt stone and sandstone zones within the predominant clay Dockum

formation which have permeabilities that range from 1 x 10-7 to 1 x 104 cm/sec.

The near-surface geology beneath the facility is uniform in nature. The groundwater in the Dockum formation does not

discharge to surface water within 5 miles of the site. There are no surface water bodies except for stock tanks within

5 miles of the site. No surface water drains from the site except under very low probability rainfall events. There are no

lakes within 2 miles of the facility.

There are no active geologic processes including erosion, submergence, subsidence, active or surface faulting, karst

formation, or flooding which will adversely affect the storage and processing activities. However, this portion of Texas

is subject to minor earthquakes.

The buffer zone around the landfill is > 1 mile and in certain directions > 4 miles to the nearest property which is not

controlled by the facility. This buffer zone distance is well in excess of TNRCC rules and guidelines.

Waste Control Specialists, LLC - Andrews, Texas: March 2000

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Waste Control Specialists, LLC -Andrews, Texas: March 2000 AuditSource T Audit Information Report: Copyright 20002.6

3.0 SUMMARY OF PERMITS, LICENSES, AND APPROVALS

The following table lists the major permits, licenses and approvals maintained by the WCS Facility. Based on the

information provided to AuditSource during the audit process, it appears the facility has the permits required to engage

in the waste management practices utilized during the on-site audit.

Permit Summary

Permit Name No. Date Issued Expiration Date Issuing Agency

Radioactive Material License L04971 06/15/98 11/30/04 Tx Dept. of Health

RC RA, HSWA, &Air HW-50358 08/05/94 08//04/04 TNRCC

TPDES (State NPDES) 04038 12102/99 09/01/02 TNRCC

TSCA na 12/02/94 12/02/99 EPA

3.1 Authorized Wastes

WCS is permitted to manage a wide variety of RCRA, TSCA, Texas Class 1, 2, & 3 non-hazardous industrial wastes.

WCS has also authorized to accept low-level radioactive waste. The following table lists the authorized RCRA wastes.

Authorized EPA Waste Codes: "D" Coded Wastes [See 40 CFR Part 261, Subpart C]

D001 D002 D003 D004 D005 D006 D007 D008 D009 D010 D011 D012 D013 D014 D015 D016 D017 D018 D019 D020

D021 D022 D023 D024 D025 D026 D027 D028 D029 D030 D031 0032 D033 D034 D035 D036 D037 D038 D039 0040

D041 D042 D043

Authorized EPA Waste Codes: "F" Coded Wastes [See 40 CFR § 261.31]

F001 F002 F003 F004 F005 F006 F007 FO08 F009 F010 F011 F012 F019 F020

F021 F022 F023 F024 F025 F026 F027 F028 F032 F034 F035 F037 F038 F039

Authorized EPA Waste Codes: "K" Coded Wastes [See 40 CFR § 261.32]

K001 K002 K003 K004 KD05 K006 K007 K008 K009 K010 K011 K013 K014 K015 K016 K017 K018 K019 K020

K021 K022 K023 K024 K025 K026 K027 K028 K029 K030 K031 K032 K033 K034 K035 K036 K037 K038 K039 K040

K041 K042 K043 K044 K045 K046 K047 K048 K049 K050 K501 K052 K060

K061 K062 K064 K065 K066 K069 K071 K073

K083 K084 K085 K086 K087 K088 K090 K091 K093 K094 K095 K096 K097 K098 K099 K100

K101 K102 K103 K104 K105 K106 K107 K108 K109 Kl10 K111 K112 K113 K114 K115 K116 K117 K118

K123 K124 K125 K126 K1131 K132 K136 K1140

K141 K142 K143 K144 K145 K147 K148 K149 K150 K151 K156 K157 K158 K159 K160

1K161 K169 K170 K171 K172

Authorized EPA Waste Codes: "P" Coded Wastes [See 40 CFR § 261.33(e)]

P001 P002 P003 P004 P005 P006 P007 P008 P009 P010 P011 P012 P013 P014 P015 P016 P017 P018 P020

P021 P022 P023 P024 P026 P027 P028 P029 P030 P031 P033 P034 P036 P037 P038 P039 P040

P041 P042 P043 P044 P045 P046 P047 P048 P049 P050 P051 P052 P053 P054 P055 P056 P057 P058 P059 P060

P061 P062 P063 P064 P065 P066 P067 P068 P069 P070 P071 P072 P073 P074 P075 P076 P077 P078 P080

P081 P082 P083 P084 P085 P086 P087 P088 P089 P092 P093 P094 P095 P096 P097 P098 P099

P101 P102 P103 P104 P105 P106 P108 P109 P110 P1ll P112 P113 P114 P115 P116 P118 P119 P120

P121 P122 P123 P124 P125 P126 P127 P128

P185 P188 P189 P190 P191 P192 P194 P196 P197 P198 P199

P201 P202 P203 P204 P205

Waste Control Specialists. LLC - Andrews, Texas March 2000 AuditSource "MAudit Information Report: Copyright 2000 31

Authorized EPA Waste Codes: "U" Coded Wastes [See 40 CFR § 261.33(f)]

U001

U021

U041

U061

U081

UlOl

U121

U141

U161

U181

U201

U221

U241

U002

U022

U042

U062

U082

U102

U122

U142

U162

U182

U202

U222

U242

U003

U023

U043

U063

U083

U103

U123

U143

U163

U183

U203

U223

U243

U004

U024

U044

U064

U084

U104

U124

U144

U164

U184

U204

U224

U244

U005

U025

U045

U065

U085

U105

U125

U145

U165

U185

U205

U225

U245

U006

U026

U046

U066

U086

U106

U126

U146

U166

U186

U206

U226

U246

UO07

U027

U047

U067

U087

U107

U127

U147

U167

U187

U207

U227

U247

U008

U028

U048

U068

U088

U108

U128

U148

U168

U188

U208

U228

U248

UO09

U029

U049

U069

U089

U109

U129

U149

U169

U189

U209

U229

U249

U010

U030

U050

U070

U090

Ul10

U130

U150

U170

U190

U210

U230

U250

U011

U031

U051

U071

U091

Ulll

U131

U151

U171

U191

U211

U231

U012

U032

U052

U072

U092

U112

U132

U152

U172

U192

U212

U232

U381 U382 U383

U401 U402 U403

U364 U365 U366 U367

U384 U385 U386 U387

U404 U407

U271

U328

U353

U372 U373

U389 U390 U391 U392 U393 U394

U408 U409 U410 U411

U277 U278 U279 U280

U375 U376

U396

U359

U377 U378 U379

U400

3.2 Prohibited Wastes

The facility is specifically prohibited from accepting: pressurized gasses, including those contained in compressed gas

cylinders; pyrophorics; explosives, as defined by the DOT under 40 CFR Part 173; liquid organic peroxides; infectious,

biological, etiological, or pathogenic wastes; and municipal garbage or putrescible wastes. Radioactive wastes which

require specific licensing or permitting under Chapter 401 of the Texas Health and Safety Code and the rules of the

TNRCC, Texas Department of Health, or Texas Railroad Commission; and/or any other rules of state or federal

authorities may be accepted for storage & treatment on-site, but the waste may not be disposed of on-site.

Note: The facility can store, treat, and dispose of some land disposal restricted (LDR) waste once the waste has been

treated to meet the LDR Standard under 40 CFR Part 268. LDR waste which cannot be treated by the facility can be

stored on-site until shipment to another TSDF

Waste Control Specialists, LLC - Andrews, Texas: March 2000 3.2 AudltSource T Audit Information Report: Copyright 2000

U013

U033

U053

U073

U093

Ul 13

U133

U153

U173

U193

U213

U233

U014

U034

U054

U074

U094

Ul 14

U134

U154

U174

U194

U214

U234

U015

U035

U055

U075

U095

Ul15

U135

U155

U175

U195

U215

U235

U016

U036

U056

U076

U096

U116

U136

U156

U176

U196

U216

U236

U017

U037

U057

U077

U097

Ul 17

U137

U157

U177

U197

U217

U237

U018

U038

U058

U078

U098

Ul18

U138

U158

U178

U198

U218

U238

U019

U039

U059

U079

U099

Ul19

U139

U159

U179

U199

U219

U239

U020

U040

U060

U080

U100

U120

U140

U160

U180

U200

U220

U240

Radioactive Material Authorized

Radioisotope Form of Material Maximum Activity Authorized Use

Any radioactive material (includes Activities of groups as specified under 25 TAC radioactive waste, byproduct material as §289.254(d)(1) not to exceed the following: defined at Texas Health & Safety Code Solid or Liquid Group I: 200 Ci Receipt & processing of radioactive

,§401.003(3)(B), uranium ore received as Group I: 2,000 Ci material received as waste waste, NORM waste, &Jor oil & gas Group I1: 20,000 Ci NORM waste) Group IV: 200,000 Ci

Any radioactive materal Sealed Sources Total activity not to exceed 1,000 Ci lntenm storage of radioactive materal A r a I received as waste

Peorýit No. FiT4Z52358

Texas Natural Resource Conservation Commission

Austin, Texas

PE-RMIT?1 FOR INOUSTRIAL SOLID WASTE VLANAGEMENT SITE issued

urdef provisicns of TEXAS HEALTIH AND SAFT`EY CODE ANN. Chapter 361 (Vemozr)

Name of Permictee:

Site C%7'rer:

Registered Agent '-Or Sez-ice.

Cia-ssifricattOn 0-4 Site.

iA Permit No. TXD 96308$'-6L_

ISWR Registration No. 25835

Wasta Control Speri-aIýszst~, l P. 0, Box 1994 Pa~sadcn-a, Tex--- 7-75:1

M.E!! Tinslev 800' Rankin Road Yz

Alb.qer.'".New 57>

HMt--oejl Grove .,.zcnand Grun-'

Ho~to" Tea-77002

nazsCl-osn 1, Class an,-: 3 *Waste SnýoaL,! Proce-ss>'1

3-id 5ispcsanl- Cz & sit

Th:e per-n-1::"s is auS~ :0:-e,- a- n-.' di:3pozc of .~as Ac f! nzrsce ".i-n. n cr- : n tin-er znijn w

7Tnls -e -- *

.sxa. zl-.:ing :. nI:n2teet. 7:- e - ~ o cz .e'.3S Clesan: A'I'-c

7h is P ert z: iI v a I - C. t Ca n c e Ie , nur~ c- . r r o a~ u, mc s e:

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REG1ON 6

S4 (rAVFNUE ,ITE 12) " * DALLAS, TX 752 2733

NGV 2 2

(CRytIIFID AI• -.. K•_ TRN RFC{_RLFIPT RFQI'ESTEDI

Mr A Paul Nowlin Facility Manager Waste Control Specialists, [.LC P 0 Box 1937 Pasadena, Texas 77501

Dear Mr Nolin

The Fn, ironrnental Protection -encF' EP..\ apo;o cd Waste (ontrol Specialists. Inc (W'S) to land dispose polychlonnated biphenvl P( 1) on l)ecember 2 11ý04 1hat appro-,al expires on December 2, 1999. A proposed re-authorizationrl O)theriappro,,ai ýka. 'ssued on June 10), 999 A Public Notice A-as published in the Andrevv s ('ourtv Nev;s iIn July !09 c) hich opened a 45-dav comment period The comment period Josed on September 1900 ') opublic comments .oere received during the cormment period The 1i1A\ has dete rmined that the taci i:'; has met all ofithe requirements under 40 CFR 761, Subparl C" (Mark ing ot'P(llb and PUB Items), Subpart D (Storage and Disposal), Subpart Ii (Financial \;surance). Subplr J (General Recoids and Reports), and Subpart K (PCB Waste Disposal Records and Reports) for approval of a PUB land disposal facility Based upon our evaluation of the facility and Its compliance hisTOrV, PFPA concludes that the operation of this facility Awil1 not result in an unreasonabile risk to human health and environment from PCBs

This approval is hereby re-authorized subject to the conditions stated herein. This reauthorization shall become effective on the date ofthis letter, and shall expire at midnight five years after the date of this letter Please re-apply for renev al at least six months before the expiration date If you have questions, please contact Mr William J Gallaizher, Jr , Chiet, ()K,TX RC(RA Permits Section, at ('1 4) o5-6775

Sincerely v' rs.

Robert E Hannesschlager. P F Acting Director Multimedia Planning and

Permitting Division

Enclosure

cc Texas Natural Resource Conservation Cornmmission

Waste Control Specialists, LLC - Andrews, Texas: March 2000 3.4 AudiftSource rAudit Information Report: Copyright 2000

Iii I

Texas Departnient of Health)

BUreau of Radiation Control

RAD)IOACTIVE NIATERIAL LIC'ENSE

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I o ' X Bk( ),\I)Ykk \ ( \ NN IjI~kS[- 1)

I Ill )I�II l�

V'

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cC~cCd 1000( 1 I fC~CLI.d P\ 'A .(4C

Waste C~ontrol !z5peciaists, LLU Andrews, I exas: March 2000J AuditSource TMAudit Information Report: Copyright 2000 3

'� C � - (-I *A� <

f I I

3.5

4.0 WASTE MANAGEMENT SYSTEMS AND OPERATIONS

4.1 Current and Proposed Operations

The facility layout is relatively compact with the stabilization building, container storage area, bulk storage areas, aqueous

(leachate) storage tanks, and rail receiving area all being centrally located near the administrative building, laboratory,

and facility entrance. The active landfill (Condo Unit 1) is located just a few hundred yards north of the other units. The

thermal desorber and rail receiving area are immediately south of the lab / administrative building.

The facility consists of a variety of operations designed to receive, store, treat, and dispose of non-hazardous, hazardous,

and PCB wastes. The complex includes an administrative building, equipment maintenance building, laboratory,

sampling/inspection racks, truck parking area, security building, leachate treatment facility, 1 secure landfill, a stabilization

building, a container (drum) storage facility, a bulk container storage building, and 2 bulk storage pads.

WCS receives waste in bulk and container quantities by truck and rail. Normal operating hours are from 8:00 a.m. to

5:00 p.m., Monday through Fridays.

Facility Services Summary

Waste Types Managed

Hazardous Waste (HW) None X Yes

PCBs No Detection X < 50 ppm (non-TSCA) X 50 to 499 ppm X > 500 ppm Limit

Radioactive None X NORM X Low Level X Exempt Level High Level

X Household HW X Class I / Type I I Industrial Non-Hazardous X Class Il/Type I Non-Hazardous Non-Hazardous X Class Ill/Type III Non-Hazardous Municipal Solid Waste X Medical Waste

Mon Tuesday Wednesday Thursday Friday Saturday Sunday

Operating Hours 8:00 am - 5:00 pm

Receiving Hours 8:00 am - 5:00 pm

Comments: The inbound loads dictate the amount of hours the facility operates. Occasionally, the facility works on Saturdays.

4.1.1 Use and Management of Containers

WCS has received permits to store containers in 3 separate areas including a Container Storage Warehouse (CSW) for

drums and boxes, Bin Storage Areas (BSAs) for bulk wastes, and 2 staging areas in the Stabilization Building.

Container Storage Warehouse (CSW)

Waste Control Specialists, LLC - Andrews, Texas: March 2000 AuditSource

TM Audit Information Report: © Copyright 2000 4.1

Containers are directed to the truck dock at the front of the

CSWwhere2 staging areas exist outside on eitherside of the

building. Each area is designed to manage 50 pallets of

containers which are sampled prior to being labeled and

placed in designated storage areas (CSA-1 through CSA-10).

Containers are not opened or sampled in the CSW. Prior to

moving a container into a CSA, it is inspected for leaks and

container condition. A Waste Safety Sheet for the material is

used to determine the appropriate CSA.

Containers in storage units are placed on pallets and may be

stacked < 2 pallets high. Containers are either placed onto Container Storage Warehouse (03/00)

pallets and conveyed by forklift or transferred directly by forklift

to a pallet in the storage area. Alternatively, they may be directly transported to the Stabilization Building drum staging

area to be scheduled into the stabilization process. A total of 275,000 gallons of wastes can be stored in the segregation

areas as described in the table, below.

Buffer Zones. RCRA requires container storage facilities

managing ignitable & reactive wastes to maintain a 50' buffer

zone between the property boundary and containers storing

ignitable or reactive waste. The CSW is located well within

the facility in order to maintain the required buffer between

ignitable and reactive waste and the facility boundary.

Container Storage Aisle Spacing. The RCRA permit

stipulates aisle space (24") must be maintained between

containers and the configuration of the CSAs facilitate good

management practices. WCS, during all 3 on-site audits by L AuditSource, has appeared to consistently maintain

adequate aisle space. cSW - Interior (10/98)

Preparedness and Prevention, The CSW is equipped with

an automatic fire protection system (a sprinkler system fed by a fire water storage tank system providing fire fighting

water for the entire plant). The diesel powered firewater pumps are capable of being automatically or manually operated.

Secondary Containment. The entrances into the CSW are protected by 9" high roll-over berms to prevent the water

generated by the activation of the sprinkler system for 20 minutes from escaping the building. Each CSA is surrounded

by a minimum 6" curb. The floors slope into the middle of each unit to provide for rapid detection and removal of liquids,

as well as separation from other units. The floor is constructed of epoxy coated concrete.

I Container Storage Area Information

Waste Control Specialists, LLC - Andrews, Texas: March 2000 AudltSourceTM Audit Information Report: © Copyright 20004.2

Segregation Containment Status Maximum Storage Capacity

Area Capacity [gail Constructed Yet to be Constructed [Gallons] [55 -gal Drums equivalents]

CSA-1 11,195 / 28,600 520

CSA-2 9,556 / 28,600 520

CSA-3 10,376 / 28,600 520

CSA-4 9,556 / 28,600 520

CSA-5 11,195 / 28,600 520

CSA-6 10,275 " 26,400 480

CSA-7 8,771 / 26,400 480

CSA-8 9,523 / 26,400 480

CSA-9 8,771 / 26,400 480

CSA-10 10,275 / 26,400 480

Bin Storage Areas (BSAs)

BSA-1 (under roof) BSA-2 BSA-3

+-1% Slope 1% Slope 1% Slope I DND][E]WWWF7H[3UD DWDWJW'[3[

Containment Sumps (located on each side of containment area)

404.4'

The Bin Storage Areas contain 9 storage compartments (BSA-1 - BSA-9). The Container Storage Building (BSA-1) is

enclosed providing shelter to ignitable materials 2 while BSA-2 through BSA-9 are external3 . The BSAs are used to store

solid wastes before and after stabilization. Bulk solids are primarily contained in 20 - 30 yd3 roll-off bins. The maximum

storage for each bin storage area is 1,080 yd3 (assuming 30 yd 3 per bin) for bulk wastes, and 30,000 gallons (assuming

6 transport vehicles carrying sludge at 5,000 gallons a truck). Prior to moving a container into a BSA, it is inspected for

leaks and container condition. The Waste Safety Sheet is used to determine the appropriate storage area.

Buffer Zones. The BSAs are well within the facility in order to maintain the required buffer zone.

Container Storage Aisle Spacing. Although there is no citation in the permit for the BSAs for aisle spacing, the bulk

containers in storage have consistently been maintained with adequate aisle spacing (e.g., > 24").

Preparedness and Prevention. Fire protection is provided

by fire extinguishers and fire fighting water via hoses.

Secondary Containment. BSA-1 is protected by 9" high roll

over berms to prevent water generated by the sprinkler

system for 20 minutes from escaping the building. BSA-2

through BSA-9 are protected by 6" rollover berms to prevent

liquids from entenng or exiting the containment areas. Each

BSA has 3 separate segregation areas separated by roll-over

berms. Each section has 2 leak detection channels and

collection sumps located in the 2 outside aisles. All sections

within BSA-1 are composed of epoxy-covered concrete and

are enclosed with a metal building, may contain 36 - 20 - 30

yds' bins, and may also stage 6 loaded tote bin transport BSA_1 (10o8)

vehicles. BSA-1 is also authorized to store 540 yd 3 or

109,073 gallons of PCBs. The 25-year, 24-hour storm event was used in sizing the containment capacities for Sections

BSA-2 through BSA-9.

2 WCS has temporanly deferred the storage of ignitable wastes in BSA-1 as the sprinkler system originally proposed has not yet been installed.

3 WCS has only constructed BSA-1 through BSA-3 thus far.

Waste Control Specialists, LLC - Andrews, Texas: March 2000 AuditSourceTM Audit Information Report: © Copyright 2000 4.3

140'

Roll-Over Containment Berms

Bin Storage Areas

Unit Secondary Containment Storage Capacity Constructed? Volume [gallons] Gallons 20-yd

3 equivalents Yes No

BSA-1 111,414 1,080

BSU -1 BSA-2 21,816 1,080 3,240 50

BSA-3 21,816 1,080

BSA-4 21,816 1,080

BSU-2 BSA-5 21,816 1,080 3,240 50

BSA-6 21,816 1,080

BSA-7 21,816 1,080

BSU-3 BSA-8 21,816 1,080 3,240 50 V

BSA-9 21,816 1,080 1 1 1 j

Secondary Containment Volume of BSA-2 through BSA-9

Floor Surface Area 20,904 ft2

Permitted Volume 1,080 yd3

108 yd3

10% of Permitted Volume 2,916 ft

3

Secondary Containment Based on Storage Volume 0.14 in.

25 yr/24 hour storm 4.7 in.

Secondary Containment Required (Storage Volume + 25 yr/24 hour storm) 4.84 in

Secondary Containment Volume Provided 6.0 in.

Drum Staging Area (Stabilization Building)

The Stabilization Building is designed with 2 drum staging

areas for storage of containenzed materials needing stabilization. Each area is designed to contain 224 drums (56 "

pallets stacked 2 high) equaling 12,320 gallons. Both areas

are equipped with 6" high secondary containment curbs and

are sloped to the center for easy detection and cleanup of

spilled materials and are enclosed within the building.

Buffer Zones. The drum staging areas in the Stabilization

Building are contained well within the property boundaries Drum Staging Area in Stabilization Building (03/00)

meeting the requirements for buffer zones.

Container Storage Aisle Spacing. During all of the on-site audits, aisle spacing requirements appeared to be met.

Preparedness and Prevention. Fire protection in this area is provided by fire extinguishers and portable emergency

response equipment.

Secondary Containment. The containment volume is calculated to be 0.15" based on 10% of the maximum storage

volume. A minimum of 6" is provided, exceeding the minimum requirements and, during all audits, the system appeared

to be in good condition.

Radioactive Waste Container Management

Since the 1997 audit, WCS has installed a containment unit for the management (processing) of containerized radioactive

waste. This unit is called a PermaCon unit and allows operators to open radioactive containers in a confined

environment for on-site treatment. WCS's line of business in this area has twice exceeded the unit's capacity and the

facility is in the planning phases of expanding the unit for the 3 ' time. WCS currently (03/00) is considering constructing

a larger containment unit around the existing unit to encompass the existing 2 stabilization tanks on the east side of the

Waste Control Specialists, LLC - Andrews, Texas: March 2000 4.4 AuditSourceTM Audit Information Report: © Copyright 2000

Stabilization Building. When it is completed, the internal unit will be dismantled and removed.

The following process operations on radioactive waste occur

within the processing area: inspection, repackaging, sorting,

compacting, residual liquid removal (solidification), and

decontamination operations.

Primary radiation protection within the radioactive waste

processing area is accomplished by controlling each process

locally, independent from other processes. Exhaust from

specific process areas/stations is accomplished using

portable HEPA filtered exhaust systems. Exhaust points are

monitored using air monitors. Area radiation monitors are

also installed in to alert personnel to high level radiation.

Temporary shielding in the form of sheets, shielding blankets,

and lead shot blankets are utilized to protect personnel during PermaCon (10/98)

occasional processing activities with high radiation levels.

COMMENTS:

a. During the 10/97 & 10/99 audits, the secondary

containment systems in all container management

areas was found to be in excellent condition and no

cracks or coating deterioration was noted within the

entire system. During the 03/00 audit, it was

apparent the coatings have been repaired as needed

and facility personnel were additionally discussing

taking entire areas of the CSW out of service for

repair.

b. Several companies claim to have waste material

health & safety sheets, but the WCS Facility appears

to have an active program with sheets on the waste

in the operating area for operator use. Furthermore,

the sheets reviewed in the CSW appeared to be in

use during the (10/98) audit. CSW Floor Repair Project (03/00)

c. During the 10/98 & 03/00 audits, the floor in the BSA

appeared to be in very good condition

d. Prior to the 10/98 audit steel plates had been

installed in the Stabilization Building to protect the

floor from gouging.

4.1.2 Tank Systems

WCS has 3 separate tank systems. The 1st, the Stabilization

& Encapsulation tanks, are used to treat wastes prior to on

site land disposal. The 2nd tank system is the Leachate

Storage & Treatment system used for the management of on

site generated wastes (i.e.; leachate)4. The 3Vd tank system is

the one utilized in the newly (CY 2000) installed indirect

thermal desorption system. Stabilization Building (10/98)

Stabilization and Encapsulation Tank System

Treatment of hazardous and non-hazardous wastes at WCS consists of a stabilization and encapsulation process used

This tank system is not necessarily required to be permitted, but are operated under the provisions of 40 CFR §262.34.

Waste Control Specialists, LLC - Andrews, Texas: March 200W AuditSourceTM Audit Information Report: © Copyright 2000 4.5

to meet RCRA Land Disposal Restrictions (LDRs) requirements for land disposal, as necessary. The system consists

of 4 open top, rectangular tanks (MT-1 through MT-4)5. The mixing tanks are used to stabilize and encapsulate

hazardous wastes and to remove free liquids from non-hazardous and hazardous wastes to meet the applicable (LDRs).

The stabilization process is effective in stabilizing wastes meeting LDR requirements for organic materials and for

stabilizing (solidifying) free liquids. All tanks are enclosed within a metal building and equipped with sufficient secondary

containment.

Drum Staging Mix Tank Area Drum Crushing Area Mix Tank Area Duplicate Drum Staging

rV ECH I~Return Air 5" Curb \r'AoIN 6" Curb Leak Detection

s-rE.. s:r ....' /.

\ co Nesrt ('Y, ) 4 . a

I'N XI'H GAP4i SrAL IN raT

I -SE AMS T.PtC.)

Stabilization Tanks Cross-Section

Stabilization Process. The stabilization process is designed

to ensure processed waste forms a stable solid product with

no free liquids. Stabilization is accomplished by using lime, fly

ash, cement, or equivalent material as the primary treatment

reagents. Additional reagents may be used in order to assure

compliance with the LDRs. The pre-stabilization analytical

procedures provided in the WAP are used to determine the

reagent ratios.

After waste is emptied into a tank, the reagents are added

and a backhoe is used to mix the waste until completely," I, '

blended. Once blending is complete, the backhoe transfers....................,,

the mixed wastes into a storage bin (roll-off box). When the

bin is full, a tarp is placed over it and it is taken to a BSA to Waste Stabilization Tank System (10/99) allow the materials to cure prior to disposal.

Simultaneously, a sample of the treated waste is collected

and tested to demonstrate conformance with applicable

LDRs. If the waste does not conform to the LDR standards,

the waste cannot be placed in the landfill until additional

treatment is conducted such that the material does meet the

LDR requirements.

Containerized waste may be also be emptied directly into the A

stabilization tanks (& properly emptied to meet the guidelines

for RCRA empty containers). The empty containers are

transferred to the drum crushing area for size reduction and

are placed in an empty bin located in the drum crushing area.

The bin is removed and taken to the landfill for disposal. All

emptied drums are crushed and placed in the landfill. WCS Drum Staging Area in Stabilization Building (03/00)

plans to install a drum shredder in the future to manage other

types of waste which are not easily removed from containers

(resins, tars, etc.) and for shredding plastic containers.

All containerized wastes are stored in the Stabilization Building prior to treatment, in 1 of 2 storage areas. The combined

Although all tanks have been constructed, only MT-1 and MT-2 are fully equipped and operational.

Waste Control Specialists, LLC - Andrews, Texas: March 2000 4.6 AuditSourceTM Audit Information Report: © Copyright 2000

volume of the staging areas is 24,540 gallons. During stabilization activities, equipment operators use fresh air

respirators as a protective measure.

Emission Controls. All stabilization tanks (currently in operation) are equipped with a ventilation system to remove

particulate emissions. Each tank is constructed with 2 ventilation slots running parallel to the length of the tank. Each

ventilation system is connected to a blower capable of producing an exhaust rate of 50,000 cfm designed to produce an

efficiency rating of 99% removal. The stabilization system is also designed so MT-1 can eventually be connected to a

thermal oxidation unit (TOU). Until the TOU is operational, stabilization is restricted to wastes < 85 ppm of organic

constituents. When the TOU is installed, MT-1 will be able to treat wastes with organic concentrations > 85 ppm.

Buffer Zones. The Stabilization & Encapsulation Building is well within the facility in orderto maintain the required buffer

between ignitable and reactive waste and the facility boundary.

Preparedness and Prevention. Fire protection is provided by fire extinguishers & portable emergency response

equipment.

Secondary Containment The stabilization tanks are enclosed within an external secondary containment system which

is inspected for free liquids daily (when in operation). If liquids are found, a sample of the residue is to be collected and

sampled to determine if the tank is leaking.

UPDATE INFORMATION (10198):

WCS has redesigned the stabilization tanks such that the entry of liquids into the secondary containment system (e.g.;

from general cleaning operations) have been eliminated or greatly reduced.

Leachate Storage and Treatment System

Leachate is produced from the operation of the landfill as a

result of rainwater falling on actively managed landfill areas,

as well as from yet unfilled constructed cells. The landfill is

designed with 2 composite liners and 2 leachate collection

systems to prevent the release of any leachate into the

environment. A significant portion of the rainwater falling on

the landfill is collected from the top of the actively managed

area before it has an opportunity to percolate into the waste

and down to the leachate collection and removal layer.

Rainwater falling on the actively managed landfill surface is

pumped by portable pumps from the surface of the landfill to

the storm water storage tanks. Rainwater reaching the Leachate Treatment Tanks (10/97) leachate collection, detection and removal layers is pumped

into drums (or a vacuum truck) for transfer to the leachate collection tanks.

Leachate Collection Tanks

The leachate collection tanks consist of 4 above-ground,

closed top, cylindrical tanks. Two (2) 100,000-gallon tanks

are used as primary storage tanks used for daily processing

of leachate. LT-1 is used for incoming leachate and LT-2 is

used for out-going (treated) leachate. Leachate is pumped

from the landfill into LT-4 (a surge tank) and then to LT-1.

When LT-1 reaches capacity, the water is sampled and tested

for all constituents composing waste code F039. If the

analysis indicates several constituents exceed LDR

requirements for land disposal, the leachate is processed

through the water treatment system and stored in LT-2.

The treated water is tested again for those constituents which Leachate Storage Tanks & Off-Loading Pad (03/00)

exceeded the LDR values, to verify the water is suitable for

Waste Control Specialists, LLC - Andrews, Texas: March 2000 AudltSourceTM Audit Information Report: © Copyright 2000 4.7

stabilization. As a 2 nd option, the water may be used in stabilization and the resultant waste must be tested for the

constituents associated with both the waste stream and the leachate (in exceedance of LDR values). LT-3 is used as

an auxiliary storage tank to collect any overflow from tank LT-1 and to store leachate while LT-1 is being tested.

Buffer Zones. Buffer zone requirements do not apply to this unit.

Preparedness and Prevention. Fire fighting equipment is not required for this unit.

Secondary Containment. Secondary containment is constructed of reinforced concrete with an epoxy coating. The

walls of the tank storage area are 4½' tall and consider the size of the largest tank and the 25-year, 24-hour storm event.

Leachate Storage & Treatment Tanks

4.1.03 Surface Impoundment

Surface impoundments are not utilized at the WCS Facility.

4.1.04. Waste Piles

Waste piles are not utilized at the WCS Facility.

4.1.05 Land Treatment

Land treatment units are not utilized at the WCS Facility.

Wastes arriving at the facility meeting LDR requirements may

be directly landfilled without further processing- Stabilized

wastes are transferred to the active cell from the stabilization

or storage areas and can be placed directly in the landfill.

Access to the working face of the active cell is by an access ..

ramp excavated down from the top of the active cell dividing

berm through the expansion area of the landfill (the area for

the next cell to be constructed). A ramp of compacted select F. .,.. .

waste (soil-like material) inside the active cell leads from the . .

top of the cell dividing berm down to the floor of the cell and

over to the working face. No wheeled vehicles are permitted RCRA / TSCA Landfill (10/98)

to drive directly on the drainage or protective materials until

covered by 2' of protective barrier. Each load is dumped at the edge of the working face and then spread in 6" - 8" lifts

for compaction by a tracked dozer.

Waste Control Specialists, LLC - Andrews, Texas March 2000 4.8 AuditSourceTM Audit Information Report: © Copyright 2000

Tank Capacity [gal]

LT-1 100,000

LT-2 100,000 Storage Tanks LT-3 300,000

LT-4 2,000

Chemical Treatment Tank 700

Clarifier Tank 3,000

Filter Feed Tank 900

Filtration Tanks (4 individual tanks) 20

Carbon Adsorption Tank 1,500

Effluent Storage Tank 100,000

Landfill Leachate Collection System

Leachate Collection System Components

Fine Gravel Upper Drainage Materials Two Layers of 7.5 oz Non-woven Geotextile

Gravel Filled Trench

Leachate Collection Trench Non-woven Geotextile

Slotted Pipe Conduit

The landfills are designed and constructed with both a

leachate collection and removal system/ leak detection

system. The purpose of the leachate collection and removal

system (LCRS) is to lower the hydraulic head on the liner and

to reduce the potential for migration of contaminants through

the liner and into the leak detection system, or into the

environment. Leachate collects in the drainage materials,

flows to a leachate collection trench. The pipe and gravel

trench convey the leachate to a gravel filled sump. A sump

pump placed inside a manhole riser located at the low point

of the sump removes the leachate from the landfill. The large

leachate riser pipes allow direct access to the leachate

collection system in the event of a problem which would

require cleaning of the lateral lines and also allows direct RCRA/TSCA Landfill (03/00)

visual inspection.

The purpose of the leak detection system is to detect leaks through the primary liner systems and to allow removal of

leachate, to reduce the hydraulic head on the secondary liner to reduce potential migration of contaminants. The leak

detection, collection, and removal system consists of similar components as the leachate collection and removal system.

A sand drainage material conducts liquid to a pipe and gravel conveyance trench which conveys the liquid to a gravel

sump where a pump inside of the pipe riser removes the liquid.

Waste Control Specialists, LLC - Andrews, Texas March 2000 AudftSourceTM Audit Information Report: © Copyright 2000 4.9

Landfill Wheel Wash

Truck wheels & tires which have been in direct contact with waste are washed when leaving the active cell. The wash

water is collected in a the unit and pumped periodically to the

leachate storage tank for management.

Storm Water Run-on/Run-off Control

In addition to general grading, run-on control is provided by

constructing berms around the perimeter of actives cells as

part of the construction process. Also, the caps of closed

cells are graded to provide drainage away from these areas.

Rainwater which falls into the active disposal cell is contained

within the cell and is subsequently managed as storm water. Landfill Wheel Wash (10/98) The water is tested for hazardous constituents & if none are

found, the water can be used to suppress dust inside the active cells.

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Groundwater Monitoringcorort r ~a

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Landfill Typical Detail Sections

Groundwater Monitoring

Eight (8) monitoring wells are placed northwest and 9 wells are also placed down-gradient of the site (southeast) to collect ground-water samples. The number of down-gradient wells will increase as the site develops.

Waste Control Specialists, LLC - Andrews, Texasý March 2000 4 10 AuditSource"0 Audit Information Report: © Copyright 2000

2000 UPDATE INFORMATION

WCS has received authority to re-utilize landfill leachate as a dust suppression in the hazardous waste landfill.

4.1.07 Incinerators

Incinerators are not utilized at the WCS Facility.

4.1.08 Drip Pads

Drip pads are not utilized at the WCS Facility.

4.1.09 Injection Wells

Injection wells are not utilized at the WCS Facility.

4.1.10 Thermal Desorption

On-Site / WCS Indirect Thermal Desorber (03/00)

During the 03/00 audit, WCS had installed an indirect thermal desorption (ITD) unit to treat a variety of organic

contaminated wastes. The facility processes de-watered, listed, or characteristic hazardous wastes utilizing high

temperatures to volatilize and recover hydrocarbons.

The ITD unit utilize a rotating, externally heat-jacketed trundle to vaporize hydrocarbons from contaminated soil or

sludges. The unit consists of 3 principal components: (i) the ITD unit wherein the hydrocarbon contaminated material

is indirectly heated, thereby causing the hydrocarbon contamination to vaporize; (ii) a condensation process system,

which causes the hydrocarbon vapor to condense to a liquid for recycling; and a flameless thermal oxidizer which

destroys remaining hydrocarbon vapors.

Waste Control Specialists, LLC -Andrews, Texas: March 2000 AudltSourceTM Audit Information Report: © Copyright 2000 4.11

The heat exchange system is comprised of a large fabricated steel shell which houses a rotating trundle. Hot gases pass

through the shell and around the outside surface of the trundle. Hydrocarbon contaminated soil, or other contaminated

materials, are loaded into the elevated end of the trundle by a conveyor belt,front end loader, or backhoe. As the trundle

revolves, the material is agitated by internal lifts and oars as it passes through the inside of the trundle by gravity flow

and is heated to temperatures from 200 to 12000 F. At these temperatures, the hydrocarbon contaminants in the waste

matrix transform into vapors which are vacuumed out of the heat exchange system into the condensing system, to the

flameless thermal oxidizer. The solids then drop out of the discharge door at the low end of the trundle and pass through

an enclosed conveyor for rehydration before final discharge. Samples of the solid matrix are tested at the end of the

process to confirm that the contaminants have been removed and the sol matrix is within an acceptable range. The solid

matrix is then either treated for metal contaminants (if necessary) or disposed of on-site.

The hydrocarbon vapors removed from the heat exchange system by vacuum are passed through a fan-cooled

condensing system. The vapors are condensed into liquids and collected in storage tanks and can then be recycled or

disposed, depending on the nature of the contaminant, the needs of the customer and the specifications required for

reuse. To date, the ITD unit has demonstrated their ability to process up to 192 tons of contaminated soil in a 24-hour

period with a 30% hydrocarbon saturation. However, the processing capacity varies significantly depending on the

moisture content, degree of contamination, waste matrix, and the contamination type.

Typical Feed Conditions

% TPH % Other (Typically Water) % Saturation

25 15 40

Although the table above describes the "typical" feed conditions, WCS has the ability to mix compatible streams together

for subsequent treatment in the ITD in order to formulate the ideal feed conditions, which vary according to physical

characteristics of each waste stream.

On-Site Technologies, the owner and operator of the ITD has developed a proprietary processes which are embodied

in the condensation process system unit. Within this component the hydrocarbon contaminant(s) are condensed from

the vapor state created in the dryer unit back into a liquid state via the proprietary processes and placed into storage for

recycling. This allows the client to realize actual savings from its ability to re-utilize the hydrocarbons.

COMMENT:

The unit was going through shake-down during the 03/00 audit and is expected to be fully operational within 90 days.

WCS has provided for secondary containment of the feed bin area, the back-hoe station, the building housing the ITD,

and the "ash" bin area. The unit and surrounding area were very clean and orderly during the audit.

4.1.11 Solvent Distillation

Solvent distillation is not utilized at the WCS Facility.

4.1.12 Fuel Blending

Fuel blending is not utilized at the WCS Facility.

4.1.13 Wastewater Treatment

Commercial wastewater treatment is not utilized at the WCS

Facility. The wastewater treatment unit for treating leachate

is a no-discharge unit and essentially recycles leachate to make it amenable for stabilization make-up water.

4.1.14 Miscellaneous Units

Miscellaneous units are not utilized at the WCS Facility.

4.2 Laboratory and Receipt Control

Radiation Quantification Instruments (10/98)

Waste Control Specialists. LLC - Andrews, Texas: March 2000

4.12 AuditSourceT' Audit Information Report © Copyright 2000

4.2.01 Laboratory

Before WCS can approve a waste for on-site management, detailed physical & chemical information about the waste

must be submitted by the generator. If the generator does not have the necessary information, or it is insufficient, WCS

will either require the generator to provide the additional data necessary to meet the applicable regulatory requirement,

perform the analysis necessary to provide a complete characterization, or will not agree to accept the generator's waste.

Before a waste may be accepted for management, the generator must provide:

the chemical and physical data listed on the Waste Acceptance form signed by an authorized agent of the

generating facility;

a representative sample of the waste stream;

a description of the process that generated the waste;

LDR Notification or other supporting documentation to confirm the information presented on the Waste

Acceptance Form.

At a minimum, the pre-approval information will include the following screens:

Minimum Pre-Approval Analyses

Parameter Rational for Selection

Determines the general characteristics of the waste. This includes visual and tactile comparison between other previously Physical Description sampled wastes or descriptions. This includes a description of the color, texture, layering, and amount of free liquids.

Water Reactivity Screen Determines whether the waste has a potential to react with water. This test does not apply to those wastes shipped already

mixed with water or that have no potential reactivity with water.

pH Measurement Will indicate the corrosive nature of the waste and the type of pre-treatment required before disposal.

Indicates the fire producing or explosive potential of the wastes. This test can be applied to all waste liquids, semi-solids, Flammability Potential Screen or solids. This test is not necessary if the physical description confirms the waste identity information clearly indicates the

waste is not ignitable.

Determines if the waste has the potential to produce hydrogen cyanide gas upon acidification below pH 2. This test is not Cyanide Screen required if the shipped waste does not have the potential to contain cyanide based on the Pre-Acceptance Waste

Acceptance Data.

Determines if the waste has the potential to produce hydrogen sulfide gas upon acidification below pH 2. This test is not required if the waste has no potential to contain sulfides.

Levels of radioactivity of the incoming waste will be determined by screening each load using a gamma ray scintillation detector or equivalent detector. Screening procedures will be conducted in accordance with the techniques specified by Radioactivity the manufacturer of the detection device. A waste discrepancy exists if the observed level of radioactivity is significantly

above background levels.

Paint Fitter Liquid Test Used to determine if free liquids are present.

pH Screen Indicates the pH range and the general corrosive nature of the waste. pH screen may not apply to certain waste types, e.g., organic waste, or insoluble solid waste.

Annually, a minimum of 10% of the incoming hazardous waste streams, to be landfilled, are randomly sampled &

analyzed for conformance with the specific regulated

hazardous constituents contained in the waste stream. These

data in combination with the generator supplied LDR

information is used to verify conformance with LDR

requirements.

4.2.02 Receipt Control

Once a waste has been approved for management at the

facility, the waste may be scheduled into the plant using the

following procedures:

pre-arrival notification (normally prior to the waste

load leaving the generator site or 24 hours

whichever is greater);

Bulk Sampling Station (03100)

Waste Control Specialists, LLC - Andrews, Texas: March 2000 AudftSourceT Audit Information Report: © Copyright 2000 413

upon arrival, document inspection and manifest verification;

visual inspection and sampling of the waste load;

analysis of sample(s) for verification of Waste Data Sheet information; and

distribution of waste to specific storage, processing, or disposal areas.

All waste received into the facility is sampled for a lab analysis

in order to verify the manifest is accurate and to ensure the

material matches the identity of the waste originally profiled to the facility, and to ensure the waste is compatible with the normal operation of the facility. Depending on the type of

material, receiving may be accomplished in several areas:

Containerized waste is received in the CSW. The containers are off-loaded, inspected, and sampled On-site Rail Siding (10/98)

according to the Waste Analysis Plan 6;

Bulk solids delivered in over-the-road vehicles are weighed in at the sampling station where a sample of incoming loads is taken; and

Rail loads are sampled at the railcar unloading station.

WCS analyzes incoming load samples (containerized waste & bulk waste) for "mandatory parameters." Once the waste clears load acceptance, containerized waste is then be processed and bulk loads are directed to the appropriate unit.

All inbound waste shipments enterthe facility through 1 entrance gate. Entry is allowed once scheduling and manifesting criteria are evaluated. Bulk tanker shipments are sampled at the sampling station & then unloaded at the BSA, stabilization building, or landfill. Incoming loads are sampled in a manner appropriate for the container and contents.

WCS receives low-level radioactive waste and mixed waste which has been packaged according to DOT requirements and packages not meeting the DOT requirements will be repackaged.

Radioactive material may not be shipped to the facility unless

there is an order by the customer and WCS acknowledges

acceptance. After acknowledgment, the customer notifies the

facility of the time of shipment & the date and method(s) of

arrival. Confirming copies of the shipping documents are faxed or mailed on the day of shipment & accompany the shipment. Title to radioactive material is transferred to WCS upon acceptance at the facility or at the time of pick-up if

transport is by a WCS vehicle or other WCS-arranged

conveyance. Forms required by regulatory agencies or WCS

are completed by the customer prior to shipment or pick-up.

After preliminary acceptance, containers are staged on the unloading dock for inspection. Each container is inspected for Radiation Sampling for Rad Waste (10/98)

leakage, corrosion, or damage. Any container found to be leaking is immediately reported. The unloading area is surveyed for contamination & decontaminated, as necessary.

WCS radiation leak detection procedures ensure radioactivity has not escaped the shipping container. Before waste sampling, containers & delivery vehicles are t' "swept" to ensure no leakage has occurred. External radiation levels for packages may not exceed 200 millirem per hour on contact during handling and shipment, unless excepted by DOT.

6 All containers in lots of 10 or fewer will be sampled. In lots greater than 10 of the same material, the sample should consist of ten randomly selected

plus 10% in excess of 10. A maximum of 5 samples from the same profile will be composited.

Waste Control Specialists, LLC - Andrews, Texas: March 2000 4.14 AuditSourceTM Audit Information Report: © Copyright 2000

4.3 Waste Tracking

WCS utilizes a grid system for tracking all wastes disposed of

in the landfill and containers are tracked through an inventory

system. The facility does track containers to ensure they do

not exceed the 1 year storage "limitation" under HSWA. The

facility has also acquired a computerized waste tracking

system for tracking of waste management efforts.

COMMENT:

Since the 1987 audit, WCS has incorporated a tracking

system tied to bar codes. Upon arrival, containers are given

a tracking bar code so that the location and disposition of the

container can be maintained at all times

4.4 Past Unit Operations

CT-.013297

S01n 73442 WP- @01244

-- -dR~I,"' ... I .A

Since the WCS Facility is a new facility, there are no past unit operations.

Waste Control Specialists, LLC - Andrews, Texas- March 2000 AudltSourcelM Audit Information Report: © Copyright 2000 4.15

5.0 RESIDUALS MANAGEMENT

5.1 Residuals Generated

Residual wastes from on-site operations routinely generated at the

facility include empty drums, wheel wash water, landfill leachate,

contaminated rainwater, groundwater, contaminated personal protective

equipment (PPE), samples, oil from equipment, and office trash.

UPDATE INFORMATION (03/00):

the 03/00 Audit, WCS was installing a new "90-Day" storage pad near

the existing shed. The new pad is also covered, but is larger and is

designed to accommodate 10 different drums, each with different

characteristics - as each internal storage area has its own secondary

containment.

5.2 On-Site Management of Residuals

All of the above material is stored on-site prior to disposal and solid

wastes which can be disposed of on-site (e.g., contaminated "90-Day Storage Shed for Lab Wastes (10/98)

PPE) are disposed of in the landfill. Landfill leachate & other

aqueous wastes are managed on-site in tanks. Since the

1987 audit, the facility has installed a shed for temporary (< 90

days) storing on-site generated waste.

Landfill Leachate Management. Landfill leachate is

collected and sent to a wastewater treatment unit, which is a

no-discharge system and essentially recycles leachate to

make it amenable for stabilization make-up. However, facility

personnel noted that the leachate has not had constituents

above any level of concern which causes them to utilize this

treatment system and they have been able to utilize thei

leachate "as-is" in the stabilization process.

UPDATE INFORMATION (03100): New 90-Day Storage Area (03/00)

WCS has obtained authority to utilize their leachate as dust

suppression within the hazardous waste landfill. EPA has granted this authorization in very limited situations to RCRA

landfills where the facility can properly segregate the leachate within the confines of the landfill such that it does not leave

the landfill cell and, thereby, conflict with placement provisions of HSWA, This unique authorization allows the facility to

utilize leachate for dust suppression in the RCRA landfill in lieu of either storm water or purchased water.

Storm Water Management All storm water is collected in tanks and tested. If it is found to be free of contamination,

it is used as a dust suppressant in the landfill cells or in the waste stabilization system.

5.3 Off-Site Management of Residuals

WCS has entered into disposal contracts with various incineration, fuel, and wastewater disposal companies and will

add more off-site TSDs to manage the wastes currently not treated or disposed of on-site.

Waste Control Specialists, LLC - Andrews, Texas: March 2000 AuditSource

TMAudit Information Report: © Copyright 2000 5.1

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Waste Control Specialists, LLC - Andrews, Texasi March 2000 AudltSource

TM Audit Information Report: © Copyright 20005.2

6.0 REGULATORY COMPLIANCE

6.1 Agency Contacts

The following individuals and groups were identified as having some jurisdiction over the waste management activities

at the WCS facility near Andrews, Texas.

6.2 Summary of Agency Inspection Report(s)

Files from the TNRCC Region 7 office in Midland, Texas were reviewed in an attempt to identify compliance issues

detailed in recent agency inspections of the WCS facility. AuditSource found no records of any existing substantive

conflict between the facility and the regulatory agencies. Copies of correspo