V Responses

to EPA Region
III Comments

on the Final Effluent Pond Sludge Sampling and Analysis Plan BWX Technologies,
Inc. Mt. Athos Site, Lynchburg, Virginia September
30, 2004 Comments from David M Friedman, Delisting Coordinator, August
19, 2004 Comment

1:V 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. Response: The following sentence will be added
to the end of the first paragraph

in Section VII to reference the requested validation levels: “Organic compounds will be validated

at level M-2 and inorganic compounds

at level TM-i.” Comment

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. Response: The analytical method listed for dioxins and furans 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 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...” Response: 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 pH extractions, even if they are not detected

in the total analyses.” Other Changes

to the Text and Tables During the process
of revising 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 of the plan. These changes are noted below: I. The FEP sludge

is a two-phase material and the SAP did not specify whether the samples would be treated
as a solid or liquid matrix for sample preparation
and analysis. While this question

is not at issue for the TCLP
or multiple p1- extraction tests, there
is ambiguity concerning
the preparation

of samples 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. 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 chemical constituents selected for analysis. Accordingly,

the detection limits listed
in the “Solid” column
of Tables

5, 7, 8, 9 and 10 will apply to the analyses for total chemical concentration. 2. The SAP identified two alternate extraction solutions for the multiple pH extraction tests.
In order to remove any ambiguity about the exact pH of the second extract fluid, the alkaline solution
of sodium hydroxide between pH 10 and 12 has been replaced with a sodium bicarbonate
and sodium carbonate solution with

a pH of 10. The sodium bicarbonate/carbonate solution

is identified

in current EPA delisting guidance

as anacceptableextractfluidforthisprocedure.Thischangeisnotedonpage1ofthetextandinthefootnotestoTables1and4.3.AlthoughthetextoftheSAPstatedthat“organicsthatarenotdetectedinthetotalanalyses,exceptthoselistedunder40CFR§261.24,donotneedtobeanalyzedintheTCLPandmultiplepHextracts”,thenotationsontheanalyticaltablesdidnotextendthisexemptionbeyondVOCsandSVOCstoPCBs,dioxins,furans,andformaldehydeaswasclearlyintendedinthetext.Therefore,theappropriatenotationshavebeenaddedtoTables1and4toremedythisinconsistency.4.Page2ofthetextstatedthat“Eachpondwillbedividedintofourapproximatelyequalsurfaceareas,andthecenterofeachareawillbesampled.”Basedonearlierin-situmeasurementsoftheFEPsludgedepthsin1993,itisclearthatthereareareaswithinbothpondswherethesludgelayerissoshallowthatsamplingthoseareaswouldnotbeproductive.Therefore,thetextinthissectionhasbeenmodifiedtostatethat(changesinboldfont)“Eachpondwillbedividedintofourapproximatelyequalsurfaceareas,andtheapproximatecenterofeachareawillbesampled.Samplelocationssomewhatoffthecenterofasubsectionmaybeselectedtoimprovetheefficiencyofsamplecollectionbyavoidingareaswherethesludgeislessthan2feetdeep.”5.TheunitsfordetectionlimitsandreportinglimitsformetalsonTable5wereincorrectlylistedasig/LforwaterorTCLPextractsandjig/kgforsolids.Theunitsarecorrectlylistedontherevisedtableasmg/LforwaterorTCLPextractsandmg/kgforsolids.