General Comments

Comment: The listing description for F006 is, “Wastewater treatment sludges from

electroplating operations, except from the following processes...” It is, andalways has been, Agency policy that the mixture rule does not apply to the

liquid in a wastewater treatment unit that manages unlisted liquid waste,

even if that liquid generates a hazardous sludge that settles to the bottom ofthe unit. This policy, however, does not apply if the sludge is dredged up or

scoured from the bottom of the unit as a result of operation of the unit, andphysically mixes with the liquid. Since the F006 listing describes a“wastewater treatment sludge” and not a “wastewater” as the listed waste,

and in light of the above mentioned policy, EPA does not understand how

the wastewater in FEP No. 2 would be considered a F006 listed waste. We

note that the petition does not describe how or whether samples of this

wastewater will be collected and analyzed, and, therefore, the petition

would be considered to be seriously deficient with regard to this wastestream. If you intend to pursue delisting of the wastewater, we need

additional information explaining why you feel the F006 listing applies to

the wastewater, and how you intend to collect environmental data to show

that this waste should be delisted.

Response: BWXT was addressing a perception issue associated with the FEPs and their

delisting. BWXT concurs with the EPA’s interpretation.

Waste Description

Comment 1: In order to complete the profile of wastes entering the FEPs, please

describe any unanticipated discharges to the FEPs which have occurred

over the operating life of these units.

Response 1: There has not been an unanticipated discharge to the FEPs during their

operating life. Periodically BWXT has experienced excursions ofthe facilities

VPDES permit; however, these exceedences have been short-lived and wereminor exceedences of a permitted discharge parameter i.e. possibly an elevated

pH or Fluoride measurement.

Comment 2: Please explain the method used to estimate the volume of sludge currently

residing in the FEPs.
Comment 3: The Sludge Sampling Plan indicates that after freezing, the sample core

will be sprayed with deionized water to remove the outer surface layer of

ice that forms from contact with the tube. This step appears unnecessary.The FEP sludge is expected to contain water.

Response 3: The intent ofspraying deionized water was to remove the outer layer ofsludge

that smeared along the sides ofthe tube, and thereby prevent one sludge layer

from influencing the next layer. In the revised plan, the entire sludge depth will

be considered one sample, and therefore this action will not be needed.

Comment 4: The Sludge Sampling Plan indicates that any water from the aluminum

pan (in which the frozen cores are allowed to thaw) will be decanted.

Again, this step appears to be unnecessary since the sludge is expected to

contain liquid.

Response 4: The text about decanting water from the aluminum pan has been removed from

the plan.

Comment 5: The Sludge Sampling Plan does not describe the collection ofsamples to

support the analysis of volatile organic compounds (VOCs). Grab samples

are typically collected for this type of analysis. Homogenization of samples

during the sample preparation phase of the plan would not be compatible

with VOC analysis.

Response 5: The revised plan stipulates that sludge aliquots for VOC analysis will be

collected before the sludge is homogenized. As soon as the sludge is extruded

from the sampling tube, the VOC aliquot will be collected from the middle

portion ofthe sludge core and placed in the appropriate sample container.

Sample Container and Eguipment Preparation

Comment 6: The Sludge Sampling Plan does not identify the type of sample containers

that will be used.

Response 6: Table 4 ofthe revised plan lists the sample containers that will be used.

Comment 7: The Sludge Sampling Plan does not indicate which/how sample

preservatives will be used, or the amount ofsample preservative that will

be used.

2
Response 8: Table 4 ofthe revised plan specifies the maximum sample holding times.

Comment 9: Prior to the sampling event, BWXT (or its contractor) must determine the

number of sample containers that will be needed and the sample volumes

to be coliected. BWXT needs to make sure that adequate waste is available

for waste sample analysis, and field and laboratory control samples.

Response 9: Table 4 ofthe revised plan lists the number and sizes ofsample containers that

will be used.

Sample Labeling

Comment 10: The Sludge Sampling Plan did not provide information on how sample

container labels, sample log sheets, chain-of-custody records, and field log

books will be used to document sampling activities. The Sludge Sampling

Plan indicates only that samples will be transported after chain-of-custody

forms have been completed. The Sludge Sampling Plan needs to describe

how field activities will be recorded, and what forms wifi be used to record

information.

Response 10: A section on Field Documentation has been added to the plan that specifies how

field activities will be recorded. More details about field documentation are

provided in the Data Collection Quality Assurance Plan, which is appended to

the plan.

Sample Shipment

Comment 11: It is recommended that a chain-of-custody seal be placed over each sample

container top after the sample is collected. At the very least, it is

recommended that a chain-of-custody seal be placed over the shipping

cooler lid to verify the absence of sample tampering during shipment.

Response 11: The revised plan specifies that a custody seal will be placed on each sample

container top after the sample is bottled.

Comment 12: It is recommended that the cooler be delivered on the day samples are

prepared (i.e., the day frozen samples are thawed and homogenized). The

Sludge Sampling Plan did not identify when coolers will be delivered to the

laboratory.

3
samples will still be usable.

Sample Analysis

Comment 13: The petition and Sludge Sampling Plan indicate that TCLP analyses will be

performed for metals and organic compounds. It is unclear whether theTCLP extract will be analyzed for the full suite of Appendix VIII

constituents (as appropriate) or only those constituents listed in 40 CFRSection 261.24.

Response 13: The plan has been revised to specify analyses for all the chemical constituents,

except total oil and grease and total sulfide, on the TCLP extracts, in accordance

with the guidance in “EPA RCRA Delisting Program, Guidance Manual for the

Petitioner,” March 2000.

Comment 14: During the Phase 1 sampling event, at least one sample from FEP Nos. 1

and 2 must be analyzed using a multiple leachate testing protocol. This

protocol requires the testing of all constituents using TCLP procedure but

substituting the specified extraction fluid with, (a) distilled deionized water,

and (b) an alkaline solution of sodium hydroxide with a pH between 10and 12.

Response 14: The revised plan includes testing during Phase 1 of one sample from each pond

for the two additional pH extractions.

Comment 15: The petition and Sludge Sampling Plan must be revised to include analysis

of the FEP sludge samples for total sulfide.

Response 15: The plan has been revised to include analysis ofthe sludge samples for total

sulfide.

Comment 16: The petition and Sludge Sampling Plan must be revised to include analysis

of the FEP sludge samples for total oil and grease content.

Response 16: The plan has been revised to include analysis ofthe sludge samples for total oil

and grease content.

4
Preparation Cleanup Analytical

Method Method Method

Total Appendix IX volatiles 5035 NA 8260B

Total Appendix IX herbicides 8151A 3620B 8151A

TCLP Appendix IX semivolatiles 1311/3510 3640A 8270C

Response 17: Table 4 ofthe revised plan specifies the laboratory methods that will be used for

sample preparation, cleanup, and analysis.

Detection Limits

Comment 18: The Sludge Sampling Plan did not provide detailed information regarding

analytical detection limits and is, therefore, incomplete. Detection limits

are laboratory and instrument-specific. In order to properly evaluate theanalytical methods that will be used, the laboratory needs to generate its

detection limits to assure that it meets the project DQOs with respect

to sensitivity and detection. For example, Method 6010 is probably

appropriate for most of the target metals and can typically detect

concentrations significantly below the delisting maximum allowable

concentrations. However, this method may not be suitable for selenium orlead if the laboratory is required to reach the delisting health-based levels.

The Sludge Sampling Plan must provide laboratory-generated detection

limits, using the methods and instruments that will be used during the

actual analysis.

Response 18: Tables 5 through 10 ofthe revised plan lists the laboratories’ standard reporting

limits for the specified analytes and methods.

Data Validation

Comment 19: The petition must include provisions specifying third party data validation

for all analytical data. Data validation should be performed in accordance

with the Region III Modifications to the National Functional Guidelines for

Data Review. Please refer to the list of references in the attached

“Region III QAPP Preparation Checklist” for the specific data validation

documents.

Response 19: The revised plan specifies that the analytical data will be validated by Shaw

Environmental, Inc., following the EPA Region III guidance.

5
plans can be prepared either as separate plans or as one combined

document.

Response 20: The Quality Assurance Plan for BWXT environmental investigations, which

applies to the FEP sludge sampling, is appended to the revised plan.

Quality Control Samples

Comment 21: The Sludge Sampling Plan states that one field duplicate will be collected

during the field event. This frequency must be revised so that one field

duplicate is collected for every twenty (20) samples or each sample batch,

whichever is greater.

Response 21: The revised pian specifies that one sludge field duplicate will be collected for

every 20 samples or each sampling event, whichever is greater.

Comment 22: The Sludge Sampling Plan must include provisions for ensuring that

samples are maintained at 40 C until they are received by the laboratory.

Temperature blanks are one way to evaluate the potential effects of sample

transportation on data quality. One temperature blank is included in each

sample cooler. Upon receipt by the laboratory, the temperature of the

water in the temperature blank vial must be 4° C, plus or minus 2 degrees.

Response 22: The revised plan specifies that a temperature blank will be placed in each

sample cooler, and the cooler temperature checked by the laboratory upon

receipt.

Laboratory Quality Assurance

Comment 23: The Sludge Sampling Plan does not specify the analytical laboratory (or

laboratories) to be used for analysis of the sludge samples, nor does it

contain the analytical laboratory’s QA procedures. This requirement can

be addressed by, (a) including the laboratory’s QA manual and, (b) the

results of the laboratory’s most recent proficiency testing for each type of

analysis that it will be performing. However, in lieu of proficiency testing

results, we will accept a current certificate of accreditation for the specified

types of analyses from an organization such as NELAP (the NationalEnvironmental Laboratory Accreditation Program).

6
Comment 24: Section Xl (Conclusions), Subsection D states that, “The data to be

generated will demonstrate that the FEP Sludge does not exhibit any

hazardous waste characteristic.” The sampling and analysis proposed inthe petition does not address all of the hazardous waste characteristics.

Characteristics can be addressed by testing, or in some cases, by presentingother information which is sufficient to show that the subject waste could

not exhibit that particular characteristic based on process knowledge. Forexample, the characteristic of reactivity can be addressed in part by testingfor cyanide and sulfide; however, other categories of reactivity are usuallyaddressed through process knowledge. Iftesting is not done for a

particular hazardous waste characteristic, the final submission must still

specifically address that characteristic, and provide information to support

the conclusions that the waste does not possess the property described bythe characteristic.

Response 24: The revised plan includes analyses for cyanide and sulfide to address reactivity.

Testing for ignitability and corrosivity will also be performed.

7