UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103-2029

August 19, 2004

John M. Storton, Advisory Engineer

Environmental Safety Health & Safeguards Department

BWX Technologies, Inc.

Nuclear Products Division

P.O. Box 785

Lynchburg, VA 24505-0785

Dear Mr. Storton,

We have reviewed the additional information dated June 15, 2004, which you submitted 

in support of your delisting petition. We have the following additional comments on your Final 

Effluent Pond Sludge Sampling and Analysis (S/A) Plan.

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 validation level for organics 

and inorganics appropriate for this project. We request that data of this type be validated 

at a minimum level of M-2 for organics and IM-1 for inorganics.

2. Dioxin/Furan analysis - Table 4, Analytical Methods, Sample Containers, and 

Preservation Requirements, lists SW-846 Method 8280A as the analytical method to be 

used for the analysis of dioxins and furans. We request that the more sensitive SW-846 

Method 8290 or EPA Office of Water Method 1613 be used, since the data from this 

analysis will be used in a risk assessment.

3. TCLP analysis - On page 1of the S/A Plan, in the next to last paragraph, the plan 

states, “Note that organics that are not detected in the total analyses do not need to be 

analyzed in the TCLP and multiple pH extracts.” 

We request that the organic constituents listed under 40 CFR §261.24 be analyzed in the 

TCLP leachate, even if they are not detected above the reporting limit in the total 

analysis. In the EPA Delisting Program Guidance Manual for the Petitioner, March 23, 

2000, Exhibit 2 (Analyses for Constituents of Concern and Hazardous Waste 

Characteristics), the next to last bullet in this table includes total constituent and TCLP 

analyses for the organic constituents listed under 40 CFR §261.24. 
It is the last bullet in this exhibit which addresses the total constituent and TCLP for any 

other organic constituents of concern that could potentially be present in the waste

[emphasis added] where the guidance states that, “You do not need to conduct TCLP 

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

I would like to further request that you provide the Virginia Department of Environmental 

Quality (VADEQ) and me with a schedule for implementation of this project plan. I would 

appreciate receiving notification at least fourteen (14) day prior to the actual sampling event, so 

that we can attempt to arrange to have someone on site to observe the implementation of the 

sampling plan.

If you have any questions or concerns, please feel free to contact me at 214/814-3395, or 

at the above address.

Sincerely,

David M. Friedman

Delisting Coordinator

Waste and Chemicals Management Division

EPA Region III

cc: Mike Jacobi (EPA)

Cynthia Nadolski (EPA)

Hassan Vakili (VADEQ)