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DLL.Q. II--- 3CV

Name: D

Delisting Petition

BWX Technologies, Inc

Naval Nuclear Fuel Division

March 6, 2002

In Partnership with

the Environment
1.6 Regulatory Concerns with “F006 Listed” Sludge

1.7 NNFD’s Need to Delist the FEPs

1.8 FEP Delisting Petition Methodology

2.0 Wastewater Treatment Systems

2.1 General

2.2 FEPs History

2.3 Historical LLR and PA Wastewater Treatment Systems

2.4 Replacement of Clarification Systems with Microfiltration Systems

2.5 LLR Waste Treatment System

2.6 PA Waste Treatment System

2.7 Grit Blast Waste Treatment System

2.8 Water Production Waste Treatment System

2.9 Sanitary Waste Treatment System

2.10 Once-Through Non-Contact Cooling Water

3.0 Manufacturing Operation Process Descriptions

3.1 Overview

3.2 Production Processes Generating Non-Radioactive Wastewater

3.2.1 Metal Processing and Pickling

3.2.2 Metal Anodizing

3.2.3 Copper Dissolution

3.2.4 Hafnium and Inconel Processing and Pickling

3.2.5 Aluminum Pickling and Anodizing

3.2.6 X-Ray Processing

3.2.7 Grit Blasting and Water Jet Cutting Operations

3.2.8 Water Treatment

3.2.9 Sanitary (Domestic) Waste Generation

3.2.10 Once Through Non-Contact Cooling Water
g

)

3.3.6 Atomic Energy of Canada Limited (AECL) Target Fabrication

3.3.7 Fuel Assembly Area

3.3.8 Metallographic Laboratory

3.3.9 Laundry

3.4 Lynchburg Technology Center
home to the Lynchburg Technology Center (LTC).

1.2 Overview of BWXT Activities

Since its formation some 45 years ago to present, NNFD has been involved in the production and

as cmbly of components primarily for the United States Government. This work requires the

p0:-session and use of Special Nuclear Material (SNM), primarily unirradiated enriched uranium.

Ovr the years, BWXT has expanded its workscope to include the recovery and purification of

scrp uranium and uranium downblending. These operations are currently being performed and regulated under Nuclear Regulatory Commission (NRC) License SNM-42.

NNFD is primarily a metal fabricator (SIC 3443), which involves the fabrication of metal

components from stock metals through various machining processes, welding, grinding, pickling, cleaning, and final assembly. Secondary to this is the recovery of uranium fuel, the research and

development of uranium fuel manufacturing techniques, and downblending operations. Support facilities for the Mt. Athos site include a steam plant, water treatment facilities, and wastewater

treatment facilities.

The LTC consists of McDermott Technologies, Inc. Research & Development Division (MTI)

and BWXT Services Division (BWXS). MTI focuses on non-destructive analyses, ceramics, fuel

cell energy systems. BWXS operates hotcells and the Nuclear Environmental Laboratory.Operations at the LTC are widely diversified, changing frequently to meet research and

laboratory testing needs. Solid waste and wastewater generated at the LTC are delivered or piped

to NNFD for processing, treatment, recycling, and/or disposal.

1.3 Description of Waste Streams

The liquid waste streams treated at the NNFD Wastewater Treatment Facilities are categorized

as wastewater generated from industrial processing operations and wastewater generated from

non-industrial processing operations. Industrial processing wastewater streams consists of the

following:

• Non-radioactive spent acid and rinsewater from the pickling and anodizing ofmetal

components and wastewater from copper dissolution.

• Radioactive spent acid solutions from uranium recovery and downblending operations,

wastewaters from chemical and metallurgical analyses, wastewaters from fuel

fabrication, and wastewater from laundry operations.
water).

1.4 Delisting of Non-Radioactive “F006 Listed” Sludge

In 1990, the Virginia Department of Waste Management (DWM) identified the sludge generated

from neutralization of non-radioactive spent acid and rinsewaters, call the Pickle Acid (PA)

Waste Treatment System, as a “F006” listed hazardous waste. At that time, NNFD began

handling the dewatered sludge (or filter cake) generated from the PA Waste Treatment System as

a listed hazardous waste. Prior to the 1990 “F006 listing” ofthe PA filter cake, dewatered sludge

was placed in two onsite landfills, Landfill 1 and Landfill 2.

NNFD performed sampling and analysis of the filter cake which indicated that the sludge did not

contain any of the constituents characteristic of a “F006 listed” waste. Therefore, in 1994 NNFD

submitted a delisting petition to address the current and past generation of the sludge generatedfrom the PA Waste Treatment System. NNED’s strategy, which was supported by EPA

headquarters, was to delist both the past and current sludge, thereby addressing the past listed

hazardous waste management issues as well as current hazardous waste management. In 2000,

BWXT was granted a federal delisting of the current generation of filter cake (sludge). The

delisting was adopted by the Commonwealth of Virginia on May 1, 2000.

The PA Waste Treatment System includes the addition of lime to form calcium fluoride andvarious metal hydroxide solids after pH adjustment in the basic range. These solids are removed

from the liquid waste stream by clarification, filtration, and dewatering equipment. The majority

ofthe sludge was accumulated as a filter cake from the PA Waste Treatment System. Since no

treatment process is 100% efficient, a small portion ofthe solids are currently and were

previously not removed by treatment equipment and were deposited as a sludge in the Final

Effluent Ponds (FEPs). This petition seeks to exclude all “F006” sludge accumulations in theFEPs from the hazardous regulation that was generated prior to May 1, 2000.

NNFD is confronted with a unique hazardous and radioactive waste management situation.

Analytical data demonstrated that both the past and current generation of PA filter cake was non

hazardous. NNFD operations are highly constrained by program specifications and have

remained virtually unchanged since the 1 960s. The PA solids generated prior to the 2000

delisting are essentially identical to the currently generated solids; however, the previouslygenerated PA solids were excluded from the 2000 delisting approval.

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PA suspended solids. Both FEPs have received, at some point in their history, the 

F006 listed

and the low-level radioactive (LLR) suspended solids that were not removed by their respective

treatment systems.

1.6 Regulatory Concerns with “F006 Listed” Sludge

Bfore September 2000, the radioactive and hazardous (mixed) waste issues at NNFD were

managed under the auspices of NRC regulations with support from the Commonwealth of

Virginia Department of Environmental Quality (DEQ). At the end of September, the

Commonwealth of Virginia was authorized by EPA for the regulation of mixed waste. NNFD is

now confronted with managing the sludge in the on-site landfills and the FEPs under the

hazardous waste regulations as well as its NRC license. NNFD’s issues are as follows:

• Landfill 1 was closed in 1976, is considered to be closed and is not an issue under the

hazardous waste regulations. However, the NRC has requested that a portion ofthe

material in Landfill 1 be removed as part of the agency’s timeliness and

decommissioning policy. The reopening of the Landfill 1 creates a number of hazardous

waste management issues.

• Landfill 2, which ceased operation in 1990, is subject to hazardous waste regulations. The

NRC has released Landfill 2 and requested that it be capped to meet decommissioning

closure criteria. BWXT is proceeding with the RCRA closure of Landfill 2.

• The FEPs are subject to the hazardous waste regulations (they received F006 solids from

the WWTP) and will be subject to NRC facility decommissioning rules at the end ofthe

Plant life. The FEPs are an integral part ofNNFD’s VPDES permitted WWTP and there

is no plan to remove them from service.

NNFD has met with EPA and the DEQ to develop management strategies to address theseregulatory issues. The strategies are to submit a RCRA closure plan for Landfill 2 to DEQ for

review and approval and to delist Landfill 1 and the FEPs. This submittal is addressing the

delisting ofthe FEPs.

1.7 NNFD’s Need to Delist the FEPs

The FEPs are surface impoundments that provide equalization ofthe liquid effluent for pH and

total suspended solids to assist in compliance with the Facilities’ existing Virginia PollutantDischarge Elimination System (VPDES) permit. Delisting ofthe FEPs is necessary to relieve an

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benefits:

• Eliminate the need to apply the VHWMR to the operation.• Allow for the continued operation ofthe FEPs with periodic sludge removal and disposal

as radioactive waste.

• Allow for the eventual closure ofthese ponds under the oversight of the NRC, at the end

of the Plant life.

1.8 FEP Delisting Petition Methodology

A process description ofthe manufacturing processes that contribute to the FEPs will be

presented. Chemicals and chemical substances utilized in the various manufacturing processeswere identified, including a chemical composition review (based on MSDS Sheets) of various

chemical substances.

A list of chemical cohstituents for which the accumulated sludge are to be analzyed was

developed as follows:

• Chemicals used in the manufacturing process that are known to pose or potentially pose a

threat to human health or the environment were added to the list of chemicals inAppendix VIII of 40 CFR 261.

o Chemicals that are not discharged to the Waste Treatment Facility, such as refrigerants

and lubricants, are not included to the list of chemicals used in the manufacturing

process.

• Chemicals listed in Appendix VIII of 40 CFR 261 that were not used and/or discharged

to the FEPs were eliminated from analysis.

This delisting petition describes the methods used for collecting and analyzing representative

samples of the solids in the FEPs and the groundwater around the FEPs. The analysis will show

that the FEPs and the solids in the FEPs:

• Do not contain regulatory levels ofthe constituents for which it was listed as hazardous.

• Do not exhibit the characteristics of hazardous waste as defined by 40 CFR 261.

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impoundments. At the end of the Plant life the FEPs will be decommissioned and closed inaccordance with NRC and Virginia DEQ criteria.

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waste streams are categorized as radioactive or non-radioactive wastewater. Treated wastewatergenerated from non-industrial processing operations is discharged to FEP 1 while treated

wastewater generated from industrial processing operations is discharged to FEP 2. The contributing waste treatment systems and other significant discharges into each FEP are identified as follows:

• FEP 1: Industrial Processing Operations Wastewater Discharges

V Pickle Acid (PA) Waste Treatment System (Non-Radioactive)

V Low Level Radioactive (LLR) Treatment System

V Grit Blast Waste Treatment System (Non-Radioactive)

• FEP 2: Non-Industrial Processing Operations Wastewater Discharges (Non-Radioactive)

V Water Production (Deionized and Make-up Non-Contact Cooling Water) Waste Treatment System (including photographic wastewater)

V Sanitary Waste Treatment System

V Once Through Non-Contact Cooling Water (no treatment system is required).

Thc manufacturing areas that contribute to each wastewater stream are presented in Figure 2-1, at the end ofthis Chapter.

A summary ofthe estimated wastewater flow contributions from significant manufacturing areas is presented in Table 2-1.

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Metal Pickling and Processing 332,000

Metal Anodizing 150

Copper Dissolution Rinse Solutions 20,000

Hafnium/Inconel Pickling 750

Aluminum Pickling/Anodizing 100

ACEL Target Fabrication 15,000

LLR Waste Treatment System (Radioactive Waste Streams)

Uranium Recovery and Downblending (2) 220,000

CRF Operations and Chemistry Lab (2) 60,000

Fuel Assembly Area, Metallurgy Lab and 150 000 Laundry

Research Test Reactor and Targets (RTRT) 100,000

LTC Laboratories 20,000

Uranium Recovery Roof Drains Intermittent (3)

Grit Blast Waste Treatment System (4)

Grit Blast Wastewater 120,000

Water Production Waste Treatment System (4)

DI and Service Water Wastewater 1,475,000

X-Ray Film Processing Wastewater 25,000

Spring Water <3,000

Sanitary Waste Treatment System

Sanitary Wastewater 947,000

Other Significant Discharges to FEP 1

Once Through Non-Contact Cooling Water 7,000,000

Notes: (1) Average monthly flowrates are based on flow data from calendar year 2000.

(2) These manufacturing areas comprise Uranium Processing Services.

(3) Calculated to be approximately 5,000 gallons for a I” rain event.

(4) Wastewater flow evaluated in “F006” Delisting Petition, Approved in 2000.

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Time Interval Wastewater Streams

1973-1979 All (Low Level Radioactive, Pick1 Acid, Sanitary, Misc.)

FEP 1 1980-1992 Pickle Acid, Sanitary, and Water Production

Water Production and Once Through Non-Contact Cooling 1 993-Present Water

1979 All (Low Level Radioactive, Pickle Acid, Sanitary, Misc.)

FEP 2 1980-1992 Low Level Radioactive

1992-Present Low -Level Radioactive, Pickle Acid, and Grit Blast

FEP 1 was put into service in 1973, with a nominal capacity of 2,000,000 gallons. The pond

received treated wastewater from all waste treatment systems from 1973 through 1979. In 1979FEP 2, at a nominal capacity of 1,900,000 gallons, was placed into service. Both ponds were

constructed using a clay/soil liner. Treated wastewater from all waste treatment systems was

routed to FEP 2 while accumulated sludge was removed from FEP 1. After cleaning operations

were completed in 1980, the effluents from the waste treatment systems were divided.

From 1979 to 1992, FEP 1 received treated wastewater from the PA Waste Treatment System,

the Sanitary Waste Treatment System, and the Water Production Waste Treatment System. FEP2 received treated wastewater only from the LLR Waste Treatment System. In 1992, the PAtreatment effluent was diverted to FEP 2. In 1992, the sanitary treatment process was improved

and the treated effluent no longer discharged to FEP 1. The Sanitary Waste Treatment Systemdischarges directly into the Final Mixing Chamber (refer to Figure 2-1).

2.3 Historical LLR and PA Wastewater Treatment Systems

The former LLR and PA wastewater treatment systems were operational from 1972 through

1991. The LLR and PA waste streams were treated in separate but similar systems. Wastewater

was pumped into one of two fiberglass equalization tanks. Lime slurry (Ca(OH) 2)and equalized

wastewater was continuously fed to a mixed neutralization tank. For the PA treatment system,the mixture was subsequently transferred to an agitated reaction tank that provided additional

residence time for the lime to neutralize the acidic solution and for calcium fluoride and metal

precipitates to form. For the LLR treatment system, the neutralization tank was provided with a

time delay control to wait before discharge to accomplish the neutralization and precipitation

reactions. A polymer was mixed with the neutralized wastewater to enhance flocculation of

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remained in the treated effluent settled out in the FEPs. The effluent from the FEPs was mixed

with other remaining treated effluents prior to discharge to the James River in accordance withthe current VPDES permit.

2.4 Replacement of Clarification Systems with Microfiltration Systems

The Memtek Advanced Microfiltration Systems were put into operation in 1992 to replace the

clarifiers as the primary method of solids removal (concentration) from neutralized LLR and PA

Wastewater Treatment Systems. The systems were installed as a means of significantly reducing

the volume of filter cake produced from the neutralization of the LLR and PA wastewater.

Sludge generation was reduced since the volume of lime slurry added was reduced from a large

volume (required for complete neutralization of the acidic wastewater) to a small volume

(required to form calcium fluoride). Liquid sodium hydroxide is utilized for the neutralization of

the acidic wastewater; thus, resulting in a significant reduction in the volume of sludge produced

for both the PA and LLR waste treatment systems.

2.5 LLR Waste Treatment System

The LLR Waste Treatment (WT) System receives small quantities of radioactive materials,

generating nuclear safety concerns. To manage the nuclear safety issues, the LLR Waste

Treatment System is operated to maintain a dynamic uranium-235 inventory (mass balance) for

the entire facility. Flow from the Uranium Processing Services enters the Recovery Side

Retention Tanks while flow from all other radioactive wastewater enters the Plant Side RetentionTanks. Although the Retention Tanks provide no actual treatment function, they are utilized to

measure the uranium-235 mass added to the LLR WT System dynamic inventory when the Tank

volume is discharged. Refer to Figure 2-2 for a process flow schematic of the LLR WT System.

Wastewater discharged from the Retention Tanks is collected in equalization tanks. Each

equalization tank is air sparged before processing to provide mixing ofthe contents for uniform

chemical concentration (specifically acidity and fluoride) for the remaining treatment process.

From the equalization tanks, the wastewater is pumped to a fluoride reaction tank (formerly the

LLR Neutralization Tank) where lime slurry is added (in an approximate amount to consume the

free fluoride present in the waste stream).

Chemically treated wastewater is pumped from the fluoride reaction tank to the LLR Memtek

Microfiltration System. Liquid caustic is added in a series ofreaction tanks of the Memtek

system to neutralize the wastewater to a pH of approximately 10.5. This neutralization allows the

precipitation of calcium fluoride and the coincidental precipitation of metals (zirconium,

aluminum, uranium, etc.). From the Memtek reaction tanks, flow enters the Memtek

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Additionally, waste sludge from the Sanitary Treatment Process can be added to the sludge blend

tanks. The sludge blend tanks act as a reservoir for the LLR sludge filter presses. Filter press

filtrate is discharged by gravity to the LLR effluent day tank. The combined Memtek and filter

press filtrates are pumped to two final effluent equalization tanks for final pH adjustment and

fluoride measurement.

The effluent equalization tanks discharge to the former regulated 401 Outfall sump, then flow bygravity to FEP 2. Flow from FEP 2 is discharged through VPDES regulated internal Outfall 701

before entering the final mixing chamber. The mixing chamber mixes treated wastewater from

FEP 2, FEP 1, and the Sanitary Waste Treatment System before flowing by gravity to the James

River.

If problems occur with the Memtek microfilters, neutralized wastewater will be pumped to the

LLR Clarifier for solids separation. Supernatant from the Clarifier is discharged directly into the

401 Outfall sump. Settled solids are pumped directly to the LLR filter presses.

Certain sections of building roofs are contaminated with radioactivity. Stormwater from theseareas are segregated and sent to a roof equalization tank, then discharged by gravity either to the

LLR Clarifier for solids removal or to the 401 Outfall sump.

Dewatered sludge (50 to 60 percent solids) from the LLR filter presses is processed in two

propane gas fired sludge dryers. Dried sludge is discharged into a pug mill for particle size

reduction and conveying to a 55gallon drum packaging station. Full drums of dried LLR filter

cake (called TP solids) are assayed via gamma scanning for uranium-235 concentration, then

shipped for ultimate disposal in an approved LLR landfill.

2.6 PA Waste Treatment System

Wastewater discharged from manufacturing operations is collected in equalization tanks. Each

equalization tank is air sparged before processing to provide mixing ofthe contents for uniformchemical concentration (specifically acidity and fluoride) for the remaining treatment process.

From the equalization tanks, the wastewater is pumped to a fluoride reaction tank (formerly the

PA Neutralization Tank) where lime slurry is added (in an approximate amount to consume the

free fluoride present in the waste stream). Refer to Figure 2-3 for a process flow schematic ofthe

PA System.

Chemically treated wastewater is pumped from the fluoride reaction tank to the PA Memtek

Microfiltration System. Liquid caustic is added in a series ofreaction tanks ofthe Memtek

system to neutralize the wastewater to a pH of approximately 10.5. This neutralization allows the

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sludge blend tank. Also, the Grit Blast Treatment System sludge is blended with the PA sludge in the sludge blend tank. If chemical treatment (such as polymer or a coagulant aid) is required, the sludge blend tank allows for complete mixing of the chemical with the combined sludge. The sludge blend tank acts as a reservoir for the PA sludge filter press. Filter press filtrate is

discharged by gravity to the PA effluent day tank. The combined Memtek and filter press filtrates are pumped to a final reaction tank for final pH adjustment and fluoride measurement.

The final reaction tank discharges to the former regulated 401 Outfall sump, then flow by gravity

to FEP 2. Flow from FEP 2 is discharged through VPDES regulated internal Outfall 701 before

entering the final mixing chamber. The mixing chamber mixes treated wastewater from FEP 2,

FEP 1, and the Sanitary Waste Treatment System before flowing by gravity to the James River.

If problems occur with the Memtek microfilters, neutralized wastewater will be pumped to the Grit Blast Treatment System Clarifier for solids separation. Supematant from the Clarifier is

discharged to the PA effluent day tank. Settled solids are pumped directly to the PA filter press.

Dewatered sludge (50 to 60 percent solids) from the PA filter press is placed into a roll-off

shipping container, then shipped for ultimate disposal in an approved industrial landfill in

accordance with the approved “F006” Delisting Petition (approved by EPA in January and by VDEQ in May 2000).

2.7 Grit Blast Waste Treatment System

Wastewater discharged from manufacturing operations is collected in an unmixed equalization tank (which is a small section of the old Imhoff Treatment Tank). The equalization tank allows for settling of heavy particulates and for blending of chemical concentrations. When necessary, the equalization tank is drained and the settled particulates removed to a concrete drying bed. Dry solids are removed from the drying bed, packaged, then shipped for ultimate disposal in an approved industrial landfill.

From the equalization tank, the wastewater is pumped to an inclined plate Clarifier (Lanco

Clarifier) with separate flash mix and flocculation chambers. If chemical treatment (such as polymer or a coagulant aid) is required, the chemicals are mixed with the wastewater in the flash

mix chamber. The Clarifier provides for solids separation. Supematant from the Clarifier is

discharged to the PA effluent day tank. Settled solids are pumped directly to the PA filter press. Dewatered solids are placed into a roll-offshipping container, then shipped for ultimate disposal in an approved industrial landfill.

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James River. In addition to influent from the James River, the Make-up Service Water receives

effluent from a groundwater pump and treat system, installed as part of an existing corrective

action. The groundwater pump and treat system is operated for the removal of trichloroethylene

contamination from the groundwater and utilizes an air stripping unit.

The Service Water treatment system utilizes chemical addition, solids contact

flocculation/clarification units, and sand filtration. Wastewater from each of these treatment

s:stems is discharged by gravity to an equalization tank; called the Imhoff Tank (which is two

hge sections of the old Imhoff Treatment Tank).

Ir the 1 980s, NNFD encountered a low pH sub-surface spring during the construction of a new

building. A sump was installed in the basement of the building to collect the spring water. The

collected water is sent to the lmhoff Tank. In addition, the Imhoff Tank receives treated

wastewater from photographic processing operations. The Imhoff Tank is continuously air

sparged to provide mixing of the contents to minimize settling and to provide blending of the

waste streams.

From the Imhoff Tank, the wastewater is pumped to a Lift Station, then to an inclined plate

Clarifier (Lamella Clarifier) with separate flash mix and flocculation chambers.

Coagulation/flocculation chemicals are added to the flash mix chamber for removal of

particulates (especially River mud/silt). The Clarifier provides for solids separation. Supematant

from the Clarifier flows by gravity to two sand filters for effluent polishing and solids removal.

The sand filters continuously backwash, with the backwash waste flowing by gravity to the Lift

Sttion for reprocessing.

Effluent from the sand filters flow by gravity to the former regulated 301 Outfall sump, then

flow by gravity to FEP 1. Flow from FEP 1 enters the final mixing chamber. The mixing

chamber mixes treated wastewater from FEP 1, FEP 2, and the Sanitary Waste Treatment System before flowing by gravity to the James River.

Settled sludge from the Clarifier is pumped to the Imhoff filter press. Dewatered solids are

placed into a roll-offshipping container, then shipped for ultimate disposal in an approved

industrial landfill.

2.9 Sanitary Waste Treatment System

As previously noted, treated effluent from the Sanitary Waste Treatment System was discharged

to the FEPs, prior to 1992. Also, as previously discussed, it was discovered that the facility’s

non-contact cooling water system (Service Water system) was found to contain small quantities

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Screenings are dewatered using a screw compactor, then collected in 55-gallon drums. Dry

hydrated lime is added to the drums for odor control and pH stabilization. Drums of screenings,

consisting of organic materials, are shipped to a incineration facility that processes low level

radioactive materials for disposal.

Flow from the wet well is pumped to an equalization tank to provide a uniform flow into the

remainder of the treatment system. The equalization basin is also continuously air sparged to

p-ovide mixing to minimize settling and the effects of waste concentration fluctuations. From the

e. ualization tank, the wastewater is pumped to a splitter chamber, where it is mixed with the

rcturn activated sludge from the Sanitary Clarifier. This wastewater stream flows by gravity to an

aeration basin. The aeration basin is of the extended aeration complete mix activated sludge

design. Coagulation and/or flocculation chemicals can be added to the aeration basin effluent to

enhance sludge settling. Refer to Figure 2-4 for a process flow schematic ofthe Sanitary System.

Flow enters the Sanitary Clarifier by gravity from the aeration basin, where quiescent conditions

are provided for the separation of solids from the wastewater. Settled solids (called activated

sludge) are continuously pumped from the Clarifier to the Splitter Box. Approximately 4 times

per day, settled solids are wasted from the Clarifier to a sludge holding tank. Supernatant from

the Clarifier flows by gravity to the Ultraviolet (UV) Disinfection System for pathogen reductionin accordance with the VPDES permit.

Flow from the Sanitary Waste Treatment System is discharged through VPDES regulatedinternal Outfall 101 before entering the final mixing chamber. The mixing chamber mixes treated

wastewater from the Sanitary Waste Treatment System, FEP 1, and FEP 2 before flowing by

gravity to the James River.

The contents of the Sanitary sludge holding tank are pumped to the LLR sludge processingsystem for blending, dewatering, drying, and disposal as LLR waste.

2.10 Once Through Non-Contact Cooling Water

NNTD’s service water system is separated into two components:

• Recirculated Non-Contact Cooling Water — which includes discharges from

equipment cooling systems

• Once Through Non-Contact Cooling Water — which includes discharges from some

equipment cooling systems, storm water from Building roofs, and storm water from

paved access roads/alleyways inside the Facility.

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14
FIGURE 3-1

SChEMATIC OF WATER FLOW

JAMES RIVER

(0 396 MGD)

REATED GROUND WA7 ER FRO

ScPLANTWATETvIENT SOD Os -

CONSUMPTION

DI WAT

004

RECYCLE

RESERVOIR &

EMERG

OVERFLOW

STORAGE TANK

ANP 

OOLING COOLING ALLEYWAY USAGE RECOVERY PROCESS ENUFACTUNG SING R

IMG 037 MGD)

iIO—

OPERATIONS ROOF DRAINS

OVERFLOW

OO DRAINS ACTIVE

_______ ____________

SETTLING

_________

0 391

______________ _____________________

EDLOOP

THROUGHROOF&SANITARY

Framalorne URANIUM URANIUM PICKLING& GRIT 

FScREEN DRAINS LIZA

________

EQUAL

SPRING

_______________

MGD WATER

_______________

REC.

______________

NEUTRALIZATj RALLZAT1ON

(005 MGD)

ALIZATIONc:RATION

OFTRN BYPASS

LOOP

COOLIN

_____________

MAJOR STORM TOWER

EVENTS ONLY AORATI

RIFICATION (4.8 MGD P

_________

BY PA S S

________________ _______________

SPLITTER

OAK)

EVENTS ONLY ISINTIONJETHROUGH

EQUALIZATION CLARIFICATION

MAJOR STORM

(0.050 MGD PEAK) - COOLING WATER EQUALIZA EQUALIZATION

(0.237 MGD) NO. 2 FOND NO. I

OUTFALL 101

0,031 MGD

BRYANT’S POND

(0017 MGD AVG

0329 MOD PEAK)

OUTFALL 701 OUTFALL 601

0.161 MGD 0.286 MGD

ETFALL

005

j OUTFALL 004 FINAL OU rPALL 001

0003 MOD AVG 0020 MOD AVG. 0479 MGD

0081 MOD PEAK 0.287 MOD PEAK

Notes:

1

‘

DIFFUSER

UNNAMED JAMES RIVER JAMES RIVER

DITCH LEADING

15

TO JAMES RIVER

1. All Flow Data is estill7

December, 2000.

2. All average and peak flo

cooling water overflow 

instantaneous peak rate,

3. MGD = Millions Gallons 
(A) EQUALIZ

(TWO -40,0

(B) FLUORID

TANK( 1

(C) AIR DISPL

(THREE T

(D) CLARIFIE

(B) SLUDGE 

(F) FILTER PR

(G) SLUDGE 

(H) PUG MILL

(I) DRUM PA

(J) LLR MEM

(K) FLOOR T

(L( POLYMER

(M) FUME SC

(N) CRITICAL

(0) RETENTI

(F) SUMP

(Q( FINAL EF

TANKS (T

(R) OUTFALL 

(S) OUTFALL 

(T) SANITARY 

(U) PARSHAL

(V) MIXING C

— . — 

ASTEWATER FROM LYNCHBURG

TECI-INOLOGY CENTER

LLR WASTEWATER LLR WASTEWATER

RECOVERY SIDE PLANT SIDE

Figure 3-2

LLR TREATMENT SYSTEM

LIQUID WASTE

— - — . —. — . —. . LLR SOLID WASTE

FOR DISPOSAL

r

R4

_

SLUDGE OPTIONAL

I FLOW ROUTE -I SLUDGE

WASTE TRBATMENT/

BLDG (lOT FLOOR)

L J

DPI 4 TREATED WASTEWATER

PICKLE ACID TREATED WASTEWATER

WASTE TREATMENT/

BLDG. (2ND FLOOR)

H‘vi H

-J FINAL EFFLUENT

TOJAMESRIVER

FINAL

EQUALIZATION

POND 412

I 900,000 GAL. 16

OUTFALL 001
NNFD PICKLE

OUTFALL 001

TO JAMES RIVER

LE

(A) EQUALIZAT

(TWO 25,000 

(B) FLUORIDE R

TANK (2,000 

(C) PICKLE ACI

(0) SLUDGE BL

(500 GAL.)

(E) FILTER PRES

(F) FINAL pH RE

TANK

(0) OUTFALL 60

(H) OUTFALL 70

(I) MIXING CHA

(OUTFALL 0

(J) PICKLE BYPA

BLAST SYSTE

(K) AIR DISPLA

INFLUENT P

(L) SUMP

ACID Figure 3-3

PICKLE ACID TREATMENT SYSTEM

-I

I WASTETREATMENT

BLDG (1ST FLOOR)

FORMER FEW SOLID

•—•* WASTEFOR

DISPOSAL (NOW DELISTED)

H

17

VALVES

NC NORM

NO NORM
Figure 3-4

SANITARY WASTEWATER SYSTEM 

(A) MEC

(B) COM

(C) LIFT 

(D) FLOW 

(F) FLOW 

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18

OUTFALL 001
include fabrication of elements or cores for research and test activities and research related to

manufacturing of fuel elements and recovery of uranium from scrap. The fuel manufacturing

process includes confidential processes and techniques. Other supporting activities include

uranium recovery operations, research related to the recovery of uranium, and a waste operations

pro ram that includes waste compaction, materials recycling, and wastewater treatment.BV XT’s production processes are described as either radioactive or non-radioactive.

Pro zess descriptions will be presented for manufacturing operations. However, many of themaaifacturing operations involve processes that are classified and cannot be discussed. In cases

where the process description carmot be provided, some generalized process information will be

provided. The chemicals used in manufacturing will be reviewed at the end of this Section. After

identification of the chemical constituents used on site and a comprehensive review ofthe 40

CFR 261, Appendix VIII chemicals, a list of chemical constituents for the FEP sludge analysis

will be developed.

3.2 Production Processes Generating Non-Radioactive Wastewater

3.2.1 Metal Processing and Pickling

Zirconium alloy components produced at BWXT undergo machining operations and subsequent

heat treatment. Grit blasting is conducted to remove the zirconium oxide film or scale that

develops during heat treatment. In the past, solvents including acetone, xylene, and

tricliloroethylene (TCE) have been used for pre- and post-cleaning to remove various substancessuch as cutting oil residue and layout dye markings adhering to the metal components resulting

dur rig the machining process. The metal components are also degreased, which had previously

bee done using either TCE or an ultrasonic detergent cleaning. All TCE cleaning operations

were separate systems that did not discharge into any of the Waste Treatment Facilities.

Since 1995, BWXT has eliminated the use of TCE, acetone, and xylene for general metal

cleaning and degreasing. Zirconium alloy components are currently cleaned and degreased with

aqueous based cleaning solutions, soaps, and/or isopropyl alcohol.

The removal of oxidized material leaves a rough surface. To regain the original surface condition

after each of the heat treatment and grit blasting steps, the metal components are pickled in anaqueous acid solution containing hydrofluoric acid and nitric acid. The pickling is followed by

hot and cold water rinses. The spent pickling solutions and water rinses are discharged to the

Waste Treatment Facilities.

3.2.2 Metal Anodizing

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quantities ofsludge (filter cake). The spent anodizing solutions and water rinses are discharged

to the Waste Treatment Facilities.

3.2.3 Copper Dissolution

B WXT dissolves copper using a nitric acid solution. The spent nitric acid solution and the

primary water rinse solution were previously combined and treated in a copper recovery process

that used soda ash neutralization. The copper carbonate was then calcined and sold as a copper

oxide by-product. In 1993, BWXT ceased the copper recovery operation. Since 1993, the spent

copper nitrate solutions have been collected and shipped as a hazardous waste for recovery to a

vendor. The rinse solutions from copper dissolution are discharged to the Waste Treatment

Facilities.

3.2.4 Hafnium and Inconel Processing and Pickling

Hafnium components are pickled in the same bath after metal components or in an identical fresh

nitric and hydrofluoric acid solution. Inconel components are cleaned in an aqueous solution of

hydrofluoric and nitric acids, and subsequently rinsed in cold and hot water. These process

wastewater streams are discharged to the Waste Treatment Facilities.

In 1994, an “acid clean line” was added as part of a new manufacturing process. It consists of a

series of water cleaning and rinse tanks, a hydrochloric acid activation bath, and an acid cleaningsolution to clean Inconel components. The acid cleaning solution consists of hydrofluoric, nitric,

hydrochloric, and phosphoric acids and ferric chloride. This spent solution is accumulated and

shipped as a hazardous waste to E.I. DuPont for treatment. The rinse solutions, cleaning

so aitions, and spent activation solutions are discharged to the Waste Treatment Facilities.

3.2.5 Aluminum Pickling and Anodizing

Aluminum components are pickled using a caustic solution, cleaned with an aqueous acid

solution consisting of nitric and hydrofluoric acids, and rinsed in cold and hot water. The final

aluminum product is anodized with a caustic solution followed by water rinses. The spent

solutions and water rinses are discharged to the Waste Treatment Facilities.

3.2.6 X-Ray Film Processing

Various components are x-rayed as part of the non-destructive testing program. X-ray film isdeveloped at the facility. Silver is electrochemically removed from the waste stream that is

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3.2.7 Grit Blasting and Water Jet Cutting Operations

BWXT utilizes an aluminum oxide grit blasting operation to remove zirconium oxide film and

scale that develops on metal components during heat treatment. The grit blasting operation is a

wet process that uses water mixed with aluminum oxide grit particles to abrade and clean metalcomponents. Discharge from each machine flows into a small settling chamber. Grit that settles

out is reused or sent off-site for disposal as a non-hazardous waste, while the wastewater is

decanted and discharged to the Waste Treatment Facilities. A polymer is added in the grit blast

equalization tank to enhance particle development to improve settling.

The water jet cutting operation uses a high-pressure jet of water and garnet sand to perform

precise cuts in Inconel metal. Wastewater from the cutter flows through a cyclone separator to

remove garnet and metal before discharge to the Waste Treatment Facilities. The garnet sand is

sent off-site for disposal as a non-hazardous waste. A garnet sand recovery and recycle process is

scheduled to begin before the summer of 2002.

3.2.8 Water Treatment

A discussion of the water production facilities for BWXT was previously presented in Section

2.0. Chemicals used in the DI water system include sodium chloride for water softener

regeneration, anti-scaling agent for protection of the reverse osmosis membranes, and sulfuric

acid and sodium hydroxide for ion exchange bed regeneration. Chemicals used in the make-up

water treatment system for the Non-Contact Cooling Water include Alum, for particulate

coagulation, and Bromine Chloride, for algae control.

3.2.9 Sanitary (Domestic) Waste TreatmentSection 2.0 presented a discussion of the radioactive contamination issues with the sanitary

wastewater generated on site. As noted, sanitary wastewater is generated from on-site restrooms

and from some roof drains from the BWXT Facility, LTC, and the adj acent Framatome ANP

fuel fabrication facility. The sanitary wastewater collection system is a gravity collection until

flow enters the Sanitary Treatment Facility wet well and pumping station. Chemicals used in theSanitary Waste Treatment System include a polymer and a flocculant to enhance particle

formation and to assist in sludge settling.

Chlorine was used for pathogen control until the addition of the TJV disinfection system in 1992.

Also, chlorine was fed to used in the final mixing chamber for pathogen control until

chlorination was discontinued with the renewed VPDES Permit in December 2001.

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It is standard industrial practice for all radioactive production areas generate radioactive

wastewater from the handwashing and showers required prior to exiting all radiological controlled areas. Additionally, radioactive wastewater is generated from an on-site laundry facility that washes all of the protective clothing used in radiological controlled areas.

3.3.1 Uranium Recovery Operations

BWXT recovers uranium using an acid dissolution process. Clad fuel components are dissolved

in a solution of nitric acid, hydrofluoric acid, and aluminum nitrate. The uranium is then

extracted from the acid solution using a solvent extraction process, consisting of an organic solution containing a phosphate and “refined kerosene”. In the solvent extraction process, uranium is driven into the solvent while impurities are removed from the dissolved uranium, to

form a concentrated uranyl nitrate solution. The organic solution is stripped from the aqueous acid solution prior to discharge of the depleted aqueous acid solution to the LLR waste treatment

facility. Waste organic solution is drummed and sent off-site for treatment and disposal as an LLR waste. Multiple uranium isotope counting and measurement systems provide nuclear safety of the waste solutions discharged to the LLR waste treatment facility.

Water from the concentrated uranyl nitrate solution thermally evaporated to form dry uranyl nitrate crystals. The wastewater generated from the crystallization process is discharged to the LLR waste treatment facility. Additionally, wastewater flow from the Recovery ventilation

system wet fume scrubber is discharged to the LLR waste treatment facility.

3.3.2 Downblending Operations

Beginning in 2000, BWXT began Downblending Operations to produce a dry low enriched uranium fuel for commercial nuclear power application. In the downblending facility, high enriched uranium and low enriched uranium are dissolved separately in concentrated nitric acid.

The two uranyl nitrate solution streams are then blended to produce a 4% enriched uranium

solution. The blended solution is then heated to drive offthe water and produce dry uranyl nitrate crystals. The acidic wastewater from the Downblending Operations is discharged to the LLR

waste treatment facility. The wastewater generated from the crystallization process is discharged

to the LLR waste treatment facility. The exhaust ventilation from the Downblending Operations is scrubbed by a wet fume scrubber. The wastewater from the scrubber is discharged to the LLR

waste treatment facility.

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3.3.4 Chemistry Laboratory Facility

The Chemistry Laboratory Facility (Chem Lab) provides support services of on-site Uranium

Processing Operations, including a wet chemistry area, gas analysis area, uranium analysis area,

mass spectrometer areas, and x-ray fluorescence area. The purpose of the Chem Lab is to

de:tructive1y evaluate both fuel and non-fuel bearing materials for various chemical attributes.

Urinium fuel material and zirconium alloy samples are routinely evaluated for impurity analysis, ur-iium isotopic analysis, uranium concentration testing, surface area testing, density testing,

and other process monitoring tests.

Various chemical analyses and evaluations are performed in the Wet Chemistry and gas analysis

areas. Chemical analyses include ion chromatography, kinetic phosphorescence, and

spectrophotometry. A variety of chemicals are used in the Chem Lab and will be presented in the

summary of chemicals used for manufacturing operations later in this Section. However, based

on the typically small quantity use, the environmental and health risks due to accumulations in

the FEP sludge are considered insignificant.

The wastewater from the Chem Lab is discharged to the LLR waste treatment facility.

Additionally, wastewater flow from a small Chem Lab ventilation system wet fume scrubber is

discharge to the LLR waste treatment facility. Solid wastes are analyzed as necessary, drummed,

and sent off-site for disposal as LLR waste.

3.3.5 Research Test Reactor and Targets (RTRT)

Th. RTRT facility manufacturers both high and low enriched clad uranium fuel used for a

variety of customers, including colleges, university, national laboratories, and nuclear research

test facilities throughout the world. Uranium oxide fuels for the high-flux isotope reactor are

manufactured for the U. S. Department of Energy’s (DOE’s) laboratory program, the National

Institute of Standards and Technology, and the high-flux beam reactor. Additionally, fuel

elements for the DOE’s Advanced Test Reactor and fuel elements for colleges and universities

are produced.

Enriched uranium fuel is manufactured in various forms. Other reactor components, such as

graphite reflectors and control rods, are manufactured. Various metal machining and milling

processes are used to produce these products.

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components are inspected and cleaned.

3.3.6 Atomic Energy of Canada United (AECL) Target Fabrication

The Target manufacturing process delivers sealed tube assemblies of prescribed quantities ofuranium oxide to the AECL for the production ofmedical isotopes. The manufacturing process

utilizes nitric acid and solvent wipe cleaning. All spent acid solutions and water rinses are

discharged to the Waste Treatment Facilities. Solvent rags are drummed and handled as

hazardous (or non-hazardous) waste in accordance with BWXT environmental procedures.

3.3.7 Fuel Assembly Area

The purpose ofthe Fuel Assembly Area is to assemble nuclear components. The wastewater

from this manufacturing area is discharged to the LLR waste treatment facility.

3.3.8 Metallographic Laboratory

The Metallographic Laboratory Facility (Met Lab) provides testing services for various

manufacturing process areas. Testing services include destructive evaluation of fuel and non-fuel

bearing components for microstructural and dimensional attributes and destructive evaluation ofweld qualities. Many of the samples are mounted in an epoxy base (or similar base materials) for

assay purposes. The chemicals associated with the mounting preparation are not placed in an

aqueous solution and are not discharged to the Waste Treatment Facilities. The samples are

ground, polished, and br etched for inspection using microscopics, comparators, and/or

metallographs. The wastewater from this manufacturing area is discharged to the LLR waste

treatment facility.

3.3.9 Laundry

BWXT operates a laundry facility to wash and dry clothing used in both radiological and nonradiological processing areas. Examples of items laundered include coveralls, lab coats, rubber

shoe covers, respirators, head covers, and towels. Chemicals used for laundering include

detergent, souring compound, print builder, and softener.

3.4 Lynchburg Technology Center (LTC)

As previously stated in Section 1.0, LTC is home to MTI Research & Development Division and

to the BWX Services (BWXS) Division. Operations at the LTC are widely diversified and

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this research. In addition, the Section focuses on the development of fuel cell energy systems and

non-radioactive materials development. Equipment process water and minor research solutions

are discharged to the LLR Waste Treatment Facilities.

BWXS operates a hot cell facility coupled with a metallurgical and radioanalytical laboratory.

These facilities analyze samples of irradiated metal, perform metallurgical failure analysis, and

perform spent fuel examination. A small volume ofradioactive wastewater is generated from

these operations. Typically, all liquid waste generated from these operations is solidified for

direct disposal as radioactive waste at a licensed facility.

A transfer canal and storage pooi is used to receive, unload, load, and prepare shielded casks for

shipment. Radioactive materials are storage and transferred to and from the hot cells through the

canal and storage pooi. The pool is recirculated through ion exchange columns to remove

radioactive isotopes prior to release water to the LLR Waste Treatment Facility. Ion exchangeresins are replaced when expended then disposed of as dry radioactive waste. Particulates that

settle to the pooi bottom are periodically removed using and underwater vacuum, dried, and

disposed of a dry radioactive waste at a licensed facility.In addition, BWXS operates a Nuclear Environmental Laboratory (NEL) that is a Virginia

certified, an EPA certified, and a Utah certified radioanalytical laboratory. The NEL is a

commercial environmental laboratory that provides isotopic analysis via high-resolution gammaspectroscopy, alpha isotopic analysis, and 1OCFR61 analysis to support manifesting of various

LLR wastes. In most cases, NEL returns radiological samples to their point of origin. Based on

the sample return procedure and sample size used for radiochemical analyses, insignificant

wastewater volumes are generated and the chemical concentrations of this wastewater are

considered insignificant. The majority of wastewater is generated from laboratory equipment

washing, hand washing, showers, laundering ofradiological area protective clothing, and

analytical equipment cooling.

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