UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION III 1650 Arch Street Philadelphia, Pennsylvania 1 9103 - 2029 August 19, 2004
John M. Storton, Advisory Enginee r Environmental Safety

Health & Safeguards Department BWX Technologies, I nc. Nuclear Products Division P.O. Box 785 Lyn chburg, VA 2 4505
- 0785 Dear Mr. Storton, We have reviewed the additional information dated June 15, 2004, which y ou submitted in supp ort of y our delisting petition. W e have the following additional comments on your Final Effluent Pond Sludge Sampling and Analy sis (S/A) Plan. 1. Data Validation
- Based on our comment letter dated February 12, 2004, BWXT revised the S/A Plan to indicat e that the analy tical data will be validated in accordance with EPA Region I II, Innovative Approaches to Data Validation (June 1995). T his document contains several validation levels which were designed to be appropriate for various data uses. T herefore, the plan should specify the validation level for organics and inorganics appropriate for this project. W e request that data of this ty pe be validated at a minimum level of M
- 2 for organics and I M
- 1 for inorganics. 2. Dioxin/Furan analysis
- Table 4, A naly tical Methods, Sample Containers, and Preservation Requirements, lists SW
- 846 Method 8280A as the analy tical method to be used for the analy sis of dioxins and furans. W e request that the more sensitive SW
- 846 Method 8290 or EPA Office of Water Method 1613 be used, since the data from this analy sis 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 analy ses do not need to be analy zed in the TCL P and multiple pH extracts. ” We request that the organic constituents listed under 40 CFR § 261.24 be analy zed in the TCL P leachate, even if they are not detected above the reporting limit in the total analy sis. I n t he EPA Delisting Program Guidance Manual for the Petitioner , March 23, 2000, Exhibit 2 (Analy ses for Constituents of Concern and Hazardous Waste Characteristics), the next to last bullet in this table includes total constituent and TCL P analy ses for the o rganic constituents listed under 40 CFR § 261.24.Itis the last bullet in this exhibit which addres ses the total constituent and TCL P 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 TCL P analy ses if the constituent is not detected in the total constituent analy ses... ” I would like to further request that y ou provide the Virginia Department of Environmental Quality (VADEQ) and me with a schedule for implementation of this project plan. Iwould appreciate receiving notification at l east 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 y ou 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 I II

cc: Mike Jacobi (EPA) Cy nthia Nadolski (EPA) Hassan Vakili (VADEQ)