Commentsfrom David M. Friedman, Delisting Coordinator, August 19, 2004

Comment 1: Data Validation -Based on our comment letter dated February 12,

2004, BWXT revised the S/A Plan to indicate that the analytical data

will be validated in accordance with EPA Region III, Innovative

Approaches to Data Validation (June 1995). This document contains

several validation levels which were designed to be appropriate for

various data uses. Therefore, the plan should specify the validationlevel for organics and inorganics appropriate for this project. Werequest that data of this type be validated at a minimum level of M-2for organics and IM-1 for inorganics.

Response 1: The following sentence will be added to the end ofthe first paragraph in

Section VII to reference the requested validation levels:

“Organic compounds will be validated at level M-2 and inorganiccompounds at level TM-i .“

Comment 2: Dioxin/Furan analysis -Table 4, Analytical Methods, Sample

Containers, and Preservation Requirements, lists SW-846 Method8280A as the analytical method to be used for the analysis of dioxinsand furans. We request that the more sensitive SW-846 Method 8290

or EPA Office of Water Method 1613 be used, since the data from thisanalysis will be used in a risk assessment.

Response 2: The analytical method listed for dioxins and thrans on both Table 4 and

Table 10 will be changed to the more sensitive SW-846 Method 8290 as

requested.

Comment 3: TCLP analysis - On page lof the S/A Plan, in the next to last

paragraph, the plan states, “Note that organics that are not detectedin the total analyses do not need to be analyzed in the TCLP andmultiple pH extracts.”

We request that the organic constituents listed under 40 CFR §261.24be analyzed in the TCLP leachate, even if they are not detected abovethe reporting limit in the total analysis. In the EPA Delisting Program

Guidance Manualfor the Petitioner, March 23, 2000, Exhibit 2

(Analyses for Constituents of Concern and Hazardous Waste

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constituent is not detected in the total constituent analyses...”

Response 3: The text of the referenced paragraph will be modified to include analysis

of TCLP leachate for organic compounds listed under 40 CFR §261.24 as

requested. Changes to the paragraph in question are shown below in bold

font:

“The TCLP extractions and the multiple pH extractions will be analyzed

for all constituents, except total sulfide, total oil and grease, and the

Resource Conservation and Recovery Act (RCRA) characteristics of

ignitability and corrosivity. Note that the extracts will not be analyzed

for pesticides and herbicides, which are excluded based on waste

process knowledge. Also note that organics that are not detected in the

total analyses, except those listed under 40 CFR §261.24, do not need to

be analyzed in the TCLP and multiple pH extracts. In Phase 1, however,

organics listed under 40 §CFR 261.24 (except pesticides and

herbicides) will be analyzed in the TCLP and multiple p11 extractions,even if they are not detected in the total analyses.”

Other Changes to the Text and Tables

During the process ofrevising the Sampling and Analysis Plan (SAP) and preparing for

the upcoming sampling event, additional changes were made to the plan to clarify

ambiguities or correct minor inconsistencies in the draft version ofthe plan. Thesechanges are noted below:

The FEP sludge is a two-phase material (i.e., is a mixture of solids and water) and

the SAP did not specify whether the samples would be treated as a solid or liquidmatrix for sample preparation and analysis. While this question is not at issue for

the TCLP or multiple pH extraction tests, there is ambiguity concerning the

preparation ofsamples for analysis of total chemical concentration. In order to

clarify this point, the text on page 1 and footnotes on Tables 1 and 4 have been

modified to indicate that the samples for total concentration analysis will be

prepared and analyzed as a solid matrix (i.e., as for a soil). This selection was made

as a practical matter, as the large sample volumes necessary to prepare and analyze

the samples as a liquid matrix would make it impractical to complete the Phase I

field event using the proposed sampling technique, given the wide range of

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The sodium bicarbonate/carbonate solution is identified in current EPA delistingguidance as an acceptable extract fluid for this procedure. This change is noted on

page 1 of the text and in the footnotes to Tables 1 and 4.

3. Although organics that are not detected in the total analyses (except those listed

under 40 CFR §261.24) do not need to be analyzed in the TCLP and multiple pH

extracts, the notations on the analytical tables did not extend this exemption beyond

VOCs and SVOCs to PCBs, dioxins, furans, and formaldehyde as was clearly

intended in the text. Therefore, the appropriate notations have been added to Tables

1 and 4 to remedy this inconsistency.

4. Page 2 of the text stated that “Each pond will be divided into four approximately

equal surface areas, and the center of each area will be sampled.” Based on earlierin-situ measurements of the FEP sludge depths in 1993, it is clear that there areareas within both ponds where the sludge layer is so thin that sampling those areas

would not be productive. Therefore, the text in this section has been modified to

state that (changes in bold font) “Each pond will be divided into four approximately

equal surface areas, and the approximate center of each area will be sampled.Sample locations somewhat off the center of a subsection may be selected to

improve the efficiency of sample collection by avoiding areas where the sludgeis less than 2 feet deep.”

5. The units for detection limits and reporting limits for metals on Table 5 were

incorrectly listed as 1g/L for water or TCLP extracts and ig!kg for solids. The

units are correctly listed on the revised table as mg/L for water or TCLP extracts

and mg/kg for solids.

6. The holding time for total analysis of Appendix IX dioxins and furans on Table 4

was corrected from 14/40 days to 28/40 days (number of days until TCLP

extraction/number of days from TCLP extraction until determinative analysis).

7. The previous draft of the plan stated that all cores collected from sample locations

would be frozen. It is anticipated that multiple cores will be collected from each

sample location, particularly in Phase 1, to provide adequate sample material to

perform all the analyses listed on Table 1 ofthe plan. Therefore, it is necessary to

freeze only one core from each Phase 1 sample location, the core from which the

VOC sample is collected. The remaining unfrozen cores from each sample location

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is not a useful indication of whether the samples have been properly preserved. Incases when samples are held overnight prior to submittal to the laboratory, they are

kept in a large refrigerator on site, so cooling of samples is not a concern See textrevisions in Sections III.G and V.

9. The frequency of the field blank collection was reworded in Section V.C to state

that “One field blank will be collected per source of water used for equipment

cleaning or one per sampling event, whichever is greater. The field blank(s)

will be analyzed for total concentrations of all the chemical parameters.

10. Due to the large number of sample containers (greater than 100 for Phase 1), the

requirement for chain-of-custody seals on individual sample containers wasremoved from the plan. See revised text in Section III.G.

Experience in perfonriing the Phase 1 sampling has led to the following changes to make

the Phase 2 sampling implementation more practical:

11. If VOC sampling is needed in Phase 2, the previous version of the plan would have

had VOC samples being collected from 52 locations at the two ponds, with 52 cores

being frozen, which would have been impractical. Therefore, in the event that VOC

analyses are needed in Phase 2, only one VOC sample will be collected from each

10,000-square-foot section. The VOC sample will be collected from the location

with the thickest sludge. Based on the 1993 sludge depth map, the likely location ofthe thickest sludge in each section can be identified. New Exhibits 7-F and 7-G

show the sampling locations relative to sludge thickness, and they identify which

location in each section would be used to collect a VOC sample, should that be

necessary. Analyzing VOCs from the thickest sludge in six or seven locations per

pond will provide a sufficiently representative sampling ofthe sludge. See revisedtext in Section II.B.l.

12. The random sampling locations in Pond FEP 1 Section 7 and Pond FEP 2 Section 2

have been revised to provide more sampling from areas of thicker sludge. The

original random sampling points for these areas were located too close to the pond

sides, where the sludge is probably thin. Sampling only in areas of thin sludgecould potentially pose practical problems for obtaining a sufficient quantity of

sludge. Therefore, new sets of random numbers were used to revise the sampling

locations in these sections. The revised sets of random numbers are shown in

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sampling section is too thin to sample, then the composite analytical samples for

that section will be comprised from just the remaining 3 sampling locations.

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