Mr. David Friedman

U.S. Environmental Protection Agency, Region lii

Land & Chemical Division 3LC20

1650 Arch Street

Philadelphia, PA 19103-2029

Ref: (1) Letter dated February 21, 2003 from B&Wto EPA Region Ill,

“Petition to Delist Hazardous Wastes (Petition)”

(2) E-mail dated October 1, 2009 from EPA Region Ill (Friedman) to B&W

(Storton) “EPA Region Ill Delisting Issues”

Dear Mr. Friedman:Babcock & Wilcox Nuclear Operations Group, Inc. (B&W NOG) is providing its response to

address EPA Region Ill’s Petition questions in the referenced e-mail (Reference 2). These

issues were discussed in our October 22, 2009 teleconference (B&W participants Jeffrey

Howard and I with EPA participants Cynthia J. Nadoiski and yourself).

After you have had an opportunity to review B&W’s response, we would like for EPA to

consider the possibility of an on-site meeting to further review any remaining concerns.

Should you have any questions, please give me a call at (434) 522-6677 or (434) 382-8447(celI).

Sincerely,

d’ohn M. Storton

Senior Advisory Engineer

Babcock & WilcoxNuclear Operation Group

cc (e-mail) DC Ward RL Coats N Whitten LR Morrell

W H Anderson RH Sedgley File 3-3.3473

babcock & wilcox nuclear operations group, inc., a Babcock & Wilcox company
of October 1991, this special nuclear material contamination was eliminated from thefilter cake.”

In the description of waste streams in the delisting petition, the low level radioactive

treatment system receives small quantities of radioactive materials including uranium andradioactive materials contained in storm water from building roofs. Does precipitation

and microfiltration sufficiently remove the radioactive component in this waste so that

subsequent sludge formation is not a mixed waste?

B&W Response:

The Final Effluent Ponds (FEP5) have received suspended solids from both the low-level

radioactive (LLR) and nonradioactive Pickle Acid wastewater treatment systems. Thereferenced 1990 statement relates to an inadvertent radiological contamination ofthePickle Acid wastewater system. B&W successfully segregated the sources of

radiological contamination from the Pickle Acid waste water system and routed them to

the LLR system in 1991.

The treated wastewater containing the suspended solids from both systems is combined

prior to its introduction into the FEPs. Therefore the comingled suspended solids that are

discharged into the FEPs are radiologically contaminated.

2. How is the current delisted non-radioactive filter cake disposed of? The delisting forthis waste includes a condition requiring it be disposed in a Subtitle D landfill.

B&W Response:

B&W disposes of the Pickle Acid filter cake at Waste Management’s Maplewood

Subtitle D Landfill in Amelia, VA.

3. All Federal delistings granted are conditional exclusions which include several

conditions including a condition prescribing permissible disposal. For a typical delistedwaste, this condition has been disposal in a Subtitle D landfill. What disposal options are

available for management ofthis material under NRC regulations? Does NRC regulationofthe sludge continue indefinitely, or does it end ifthe radiation levels drop below some

limit? We’ve been assuming that disposal in a Subtitle D landfill is not an option.

Babcock & Wilcox 1 10/16/09
Facility is the only commercial option available to B&W for the disposal of low

level

radioactive waste and it is also the only commercial facility in the nation that can dispose

of Class A Radioactive Mixed Waste.

Although the levels of radioactive contamination are low, the half-life ofthe uranium

isotopes is on the order of hundreds of thousands of years. At the final NRC

decommissioning ofthe Final Effluent Ponds, the waste could be disposed of as a lowlevel radioactive waste. However, because it was classified as a mixed waste, its disposalat the Clive Facility will be as a mixed waste because of the facility’s license. There may

be other disposal options available for the waste in the future that could allow for its

disposal without regarding to its previous hazardous waste listing.

4. Fluoride in groundwater — Based on recent analysis of Final Effluent Pond (FEP)

groundwater monitoring samples, has the concentration of fluoride in the groundwaterchanged since the sampling events ofthe 2001/2002 timeframe?

B&W Response:

B&W does not routinely monitor for fluoride in the groundwater monitoring wells.

However, B&W sampled the downgradient FEP groundwater monitoring wells FEP-l

and FEP-2 twice in 2009 in support of another program. The fluoride analyses for these

samples were completed outside the 28 day hold time. The fluoride level in FEP-lwas 4.3

mg/L and in FEP-2 was an average of 10.3 mg/L. In comparison, the fluoride

concentrations in groundwater samples collected from FEP- 1 and FEP-2 during the 2001-

2002 sampling events ranged from 2.7 to 4.0 mg/L for FEP-1 and 8.37 to 18.1 mg/L forFEP-2.

5. Fluoride in sludge — Fluoride concentration (both total and leachate) were determined

on filter cake for the January 14, 2000 delisting ofthe (then) currently produced sludge.

Fluoride concentrations were determined on sludge samples (not dewatered filter cake)

collected from the FEPs for the pending delisting petition.

Do you have analytical results that show total and leachable fluoride concentrations for

dewatered FEP sludge? Perhaps you collected some fluoride data on filtered samples

when you did the recent FEP sludge removal project.

Babcock & Wilcox 10/16/09
sa

p

ed a

d a

a

y

ed the wet sludge for the FEPs for fluoride as part ofthe Phase

2 Chemical Characterization (BWXT 2006). FEP sludge samples collected during thiseffort were analyzed for both total and extractable concentrations of fluoride as well asother parameters. The total fluoride concentrations ranged from 23 to 722 milligrams per

kilogram of wet sludge, with an average of 222 milligrams per kilogram.

The fluoride concentrations in the pH 10 TCLP extracts ranged from 7.8 to 184

milligrams per Liter (mg/L) with averages for FEP 2 of 142 mg/L and for FEP 1 of 36

mg/L. TCLP extractions were run at pH 10 during the Phase 2 FEP sludge

characterization because this condition resulted in higher extractable fluoride

concentrations in comparison to the standard (slightly acidic pH) TCLP extraction

solution and a deionized water (pH 7) extraction solution, as demonstrated in the Phase 1

characterization tests (BWXT 2005). Using the deionized water as the extraction

solution the fluoride concentrations for the FEP sludge samples ranged from 8.25 to 14

mg/L.

6. Active life of the FEPs — Do you have a revised estimate of how many years you

expect to utilize the FEPs until they are decommissioned and closed?B&W Response:

B&W expects to continue to utilize the FEPs as an integral part of its WastewaterTreatment operation well into the future. It is anticipated that the FEPs would be

decommissioned at the end of plant life, which should be decades into the future.

References:

BWX Technologies, Inc., (BWXT) 2006, Phase 2 Chemical Characterizationfor

Delisting ofthe Final Effluent Pond Sludges, Mt. Athos Site, Lynchburg, VA, July.

BWX Technologies, Inc., (BWXT) 2005, Results ofthe Phase 1 Chemical

Characterizationfor Delisting ofthe Final Effluent Pond Sludges, Mt. Athos Site,

Lynchburg, VA, May.

Babcock & Wilcox 3 10/16/09