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The facilities are designed to receive both compact states’ waste and federal waste for disposal, but can only take waste from outside the compact if the import rule is approved by the commission.
The final LLRW license was issued in September. TCEQ is reviewing a minor amendment application submitted by WCS, which includes revised disposal facility design and changes to the environmental monitoring program. On May 3, the TCEQ responded to the amendment with a notice of technical deficiencies “related to the commencement of final construction” and other issues.
The Texas Administrative Code states that a license may be approved if the TCEQ determines, among other things, that “issuance of the license will not be inimical to public health and safety nor have a long-term detrimental impact on the environment.”
The company already has a dump facility and is licensed for processing, storage and disposal of a broad range of hazardous, toxic and certain types of low-level and mixed LLRW.
Aside from securing the new license for LLRW, WCS was licensed for disposal of high-activity byproduct from the Fernald Project site, a Dept. of Energy facility in Ohio. The company has already disposed of canisters containing waste from uranium used in the World War II Manhattan Project.
Dornsife says WCS has one license for the LLRW waste and another for the DOE waste, which is designed to take mixed waste that must meet the same requirements of a hazardous waste.
The LLRW license allows the disposal facility to accept all of the waste classes that have been identified by the Nuclear Waste Commission as Class A, B and C, Dornsife adds.
Some opponents claim that proximity to the Ogallala aquifer, one of the largest in the country, could pose a danger to the water table. Not possible, Dornsife says.
“The aquifer is actually saturated 15 mi north of facility,” Dornsife says. He says it will be built on the red-bed clay formation, “a compact clay with low hydraulic conductivity.”
Dornsife says a team of expert consultants in geology have considered the site, and “in terms of hydrogeology,” it is one of the best sites they’ve seen.
The LLRW disposal cell will be about 30 ft below ground in red-bed clay with engineered covers. Dornsife says the nearest groundwater, in terms of what’s considered a productive groundwater source, is at least 700 ft below. “In terms of licensing the facility, we have assumed that the saturated layer, about 225 ft below surface, is supportive,” he adds.
The deepest performance-monitoring wells will be at about 225 ft below, he says.
Before that is a saturated layer, but it could not support a well, Dornsife says. The aquifer is 800 to 1,000 ft below and is nonpotable but productive, he adds.
Dornsife says that red-bed clay takes almost 100,000 years for any contamination to get to the 225-ft zone. And he says the site is in an arid region where evapotranspiration exceeds rainfall by a factor of five.
But concerns about the site’s geologic inadequacy persist.
A TCEQ staff memo dated Aug. 14, 2007, stated that the groundwater was likely to contact the waste from either of both of the water tables. Some TCEQ staff said the water could be as close as 14 ft from the bottom of trenches.
“That’s a problem and illegal,” Hadden says.
Arjun Makhijani, president of the Institute of Energy and Environmental Research, Tacoma Park, Md., says increasing potential volume and radioactivity by more than an order of magnitude over the presently licensed amounts without a detailed estimation of environmental impact would be unwise.
“This could be the new Yucca Mountain,” Hadden says.
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