KN5\BWXT\FEP\P2 SAP\FEP SAP Cov_10-12-05.doc\10/12/2005\3:37 PM 

## Final Effluent Pond Phase 2 Sludge Sampling and Analysis Plan

BWX Technologies, Inc.
Mt. Athos Site Lynchburg, Virginia

Prepared for:

Prepared by:



### Shaw Environmental, Inc.

312 Directors Drive Knoxville, Tennessee 37923

October 2005BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM 1 

### EXHIBIT 7

FINAL EFFLUENT POND

PHASE 2 SLUDGE SAMPLI NG AND ANALYSIS PLAN

Introduction

This plan revision reflects th e results and conclusions from the Phase 1 sludge sampling and analysis. The Phase 1 results we re presented in the May 2005 draf t report titled “Results of

Phase 1 Chemical Characterization of the Final Effluent Pond Sludges, BWX Technologies, Inc. (BWXT), Mt. Athos Site, Lynchburg, Virginia.”

The plan has been revised to specify the short list of Phase 2 analytical parameters, in accordance

with verbal comments received from the U.S. E nvironmental Protection Agency on September 8, 2005. The Phase 2 analytical parameters, which ar e also listed in Table 1, will be as follows:

• Metals – Cadmium, copper, mercury, nickel, and thallium.

• Volatile organics (VOC) – 1,2-dichloroetha ne, tetrachloroethene, and trichloroethene

• Appendix IX Polychlorinated biphenyls (PCB)

• Appendix IX Dioxins/furans

• Fluoride.

One exception is that dioxins/furans will only be analyzed from three composite samples from each pond. The pond areas with the highest concentrations of dioxi n/furan risk drivers in the Phase 1 samples have been selected for sampli ng and analysis of dioxins/furans in Phase 2 (Section IV.B and Exhibit 7-F).

In Phase 2 only one type of TCLP extraction will be performed for each analyte – using the extraction liquid that produced the highest soluble concentration in Phase 1. For parameters that were not detected in any type of Phase 1 TCLP extraction, i.e. mercury and PCBs, the standard TCLP extraction fluid will be used in Phase 2. Thus, the standard TCLP extraction fluid will be used for all constituents except thallium and fluoride. TCLP an alyses for thallium and fluoride will use a pH 10 solution of sodium bicarbonate and sodium carbonate (Table 1).

Additionally, 17 supplemental sludg e coring locations, as shown in Exhibit 7-F, have been selected to measure sludge thickness where th ere are open spaces in the array of randomly selected analytical sampling points. No analytical samples will be collected from these supplemental locations. The supplemental cores will provide additional measurements of sludge

thickness with which to calculate the volume of sludge. The sludge volume will be determined from the sludge thickness recovered in the sa mpling tubes. Recovered core thickness, when applied to the analytical results, will be a mo re accurate measure of total constituent mass than would in-situ sludge thickness (see th e discussion in the Phase 1 report).BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM 2 Additional changes in Phase 2 are as follows:

• The water column in the sludge core tubes will be removed while the tubes are being recovered from the pond. This will re duce the weight on the sludge cores and increase sludge core retention.

• Sludge cores for VOC sampling will not be cooled overnight with dry ice. In Phase 1, cores left overnight in dry ice were fr ozen solid, which hinder ed collection of VOC samples. The sludge samples for VOC analys is in Phase 2 will be placed in 2 ounce jars immediately after sample cores are removed from the pond. The Encore samplers used in Phase 1 will not be used in Phase 2, as they are more appropriate for the collection of consolidated soil samples rather than unconsolidated sludges.

• Laboratory analyses will be performed by the Severn Trent Laboratory (STL) St. Louis and STL Knoxville (dioxins/furans only) . The analytical methods are the same used in Phase 1, but anticipated detection/ reporting limits are different. Analyses for metals (except mercury) will be performed by SW-846 method 6020, which has been approved by the EPA for this work.

• A temperature blank will be included in each cooler of analytical samples shipped to off-site laboratories. (In Phase 1, an on- site laboratory performed the analyses.)

• TCLP analyses for fluoride will include sepa rate analyses of the filtrate liquid (the liquid separated from the solids prior to extracting the solids) and the solids extract liquid. The results of these separate analyses will be us ed to calculate and report the

TCLP-extractable fluoride concentration in the sludge samples. Presenting fluoride results for the separate liquid phases w ill provide additional information about whether the soluble fluoride originates main ly from the solid or liquid phase of the sludge.

I. Overview

To provide a comprehensive sludge sampling strate gy for the Final Effluent Ponds (FEP), a twophase sampling plan is being implemented. Phase 1 has been completed.

In Phase 1, sludge was collected from four re presentative locations in each pond and analyzed for the comprehensive list of chemical com pounds and other analytical parameters. The analytical parameter list incl uded the 40 Code of Federal Re gulations (CFR) 264 Appendix IX (Groundwater Monitoring List) analytes for th e metal, VOCs, semivolatile organic compound, PCBs, and dioxin/furan groups. Excluded from the analyte list because of process knowledge were the herbicide and pesticide groupings of compounds. Three additional compounds from the 40 CFR Appendix VIII (Hazardous Constituent List ) were included based on process knowledge: dibutyl phthalate, acetone, and formaldehyde. Othe r analytical parameters included total oil and grease, fluoride, cyanide, total sulfide, water content, corrosivity, and ignitability.BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM 3 The Phase 1 testing included analyses for both (a) total concentrations and (b) toxicity characteristic leaching procedure (TCLP)-extract able concentrations. Past sampling of the sludges has shown them to have high water conten ts. (Phase 1 sludge samples had solid contents ranging from 17 to 57 percent). Therefore, ch emical concentrations were reported on a wetweight basis. Sludge water content was also an alyzed and reported. For total concentration analyses, the sludge samples were prepared and analyzed as a solid matrix.

In addition to the standard TCLP extraction, one Phase 1 sample from each pond was subjected to extract testing at two additional pH values. The multiple pH extract testing followed the

recommendations in the EPA RCRA Delisting Program

, Guidance Manual for the Petitioner

, March 2000. Besides the standard extract de scribed in TCLP Method 1311, the sludge was extracted at two other pH values and analy zed. The two alternate extract fluids were:

• Reagent (distilled deionized, DI) water (pH 6)

• An alkaline solution of sodium bicarbonate and sodium carbonate with a pH of 10.

The Phase 1 samples for the multiple pH extracti ons were collected from the sampling location in each pond that was anticipated to have the greatest sludge thickness. Exhibit 7-A presents an isopach map of pond sediment (i.e., sludge) thickn ess determined in a 1993 study of the FEPs.

Exhibit 7-F shows both the 1993 and 2005 measuremen ts of in-situ sludge thickness. A new estimate of the pond sludge volume will be prepared from the sludge core thicknesses measured

in Phase 2.

In Phase 1, the TCLP extractions and the mu ltiple pH extractions were analyzed for all constituents except total sulfide, total oil and grease, and the Resource Conservation and Recovery Act (RCRA) characteristics of ignitability and corrosivity.

Phase 2 will collect samples from more numerous locations that are randomly selected according to the method recommended for surface impoundments in EPA RCRA Delisting Program

, Guidance Manual for the Petitioner , March 2000. The Phase 2 samples will be analyzed for a subset of analytes determined from the Phase 1 results, as described in the Introduction above and in Section IV.B. In Phase 2, sludge samples will continue to be prepared and analyzed as a solid matrix, and chemical concentrations will be reported on a wet-weight basis.

II. Phase 2 Sampling Locations

The plan for sampling the FEP sludge is to coll ect a sufficient number of samples using an unbiased approach to characterize the material in the ponds. The sampling plan accounts for potential vertical and horizontal variability in the sludge. Horiz ontal variability is accounted for in the sampling strategy for each pond, as described later in this section.

Vertical variability of the sludge will be addressed by taking a re presentative sample from the full thickness of sludge at each sampling location. Each location will be sampled by taking one or more cores through the entire thickness of the sludge (where the sludge is thin, multiple cores could be necessary to obtain sufficient sample material for all the analyses). VOCs will be analyzed on a subsample taken from th e middle portion of a sludge core.BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM 4 A. Overview

Sample locations for Phase 2 are selected us ing the random sampling selection process for surface impoundments as described in EPA RCRA Delisting Program

, Guidance Manual for the

Petitioner , March 2000.

First, the total area of each pond is determined. Second, each pond is divided into equal sampling sections of less than or equal to 10,000 square feet (sq ft) (FEP1 will be divided into 7 sections and FEP2 into 6 sections). Third, each 10,000-sq-ft section is divided into a grid of one hundred squares or rectangles roughly 10 feet on each side (hereafter referre d to as “squares”). Finally, a random number table is used to select f our squares for sampling w ithin each section.

Each of the four “squares” with in a section will be sampled for sludge, and the sludge cores from the four squares in each section will be composited into a single sample for analysis (except for VOC analysis). Sludge cores from the 28 sample locations in FEP1 will be combined into 7 composite samples and sludge cores from the 24 sampling locations in FEP2 will be combined into 6 composite samples. Sludge cores collected from each sample location will be chilled using ice or dry ice un til all the cores are collected from one section and combined into composite samples. Overnight chilling of sludge cores will be avoided to prevent freezing the

cores.

For VOC analysis in Phase 2, only one core from each 10,000-sq-ft section will be collected for VOC analysis. The VOC sample will be collected from the middle of the sludge core by cutting the polycarbonate tube with a pipe cutter. E xhibit 7-F shows the specific locations within each pond where cores for VOCs will be collected in Phase 2.

If a composite of single cores from the four sa mpling “squares” in a section provides insufficient material for analyses, then multiple cores will be obtained from each sampling “square.” The resulting composite must include the same number of cores from each sampling “square.”

A.1 Determination of Surface Area

FEP1 has an irregular shape, and its surface area is 68,500 sq ft. FEP2 is rectangular, and its approximate surface area is 54,800 sq ft. Plan views and surface area calculations for the FEPs are presented in Exhibit 7-B.

A.2 Determination of Sampling Sections

FEP1 is divided into seven (7) 10,000-sq-ft sect ions. Due to the irregular shape of FEP1, the

surface area of the sections va ries from approximately 9,559 to 9,853 sq ft. The sampling section layout for FEP1 is presented in Exhibit 7-C.

FEP2 is divided into six (6) equal sections, each having a surface area of 9,133 sq ft. The sampling section layout for FEP2 is presented in Exhibit 7-D.BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM 5 B. Determination of Phase 2 Sample Locations

Each of the sampling sections is divided into 100 “squares” roughly 10 feet on a side. The “squares” are consecutively numbered from 1 to 100, beginning in the northwest corner of the section and proceeding east, then south.

The random number table presented in EPA RCRA Delisting Program

, Guidance Manual for the

Petitioner , March 2000, is used to randomly select four squares for sampling within each section. The table is presented in Exhibit 7-E. Sampli ng points will be located in the centers of the squares. In some cases where the first set of four random numbers in the table would provide a poor representation of a particular section, a s econd set or a third set of random numbers that provides a better representation was chosen (FEP 1 Sections 5 and 7, and FEP2 Section 2).

Each of the sampling points selected usi ng the random number table was assigned a unique coordinate address, measured in feet to the east and to the south from the northwest corner of the pond to the center of the square sele cted by the random number table (e.g., [E7, S3] is the point 7 feet east and 3 feet south of the northwest corner of FEP2 , the center of square 01 of Section 1 of FEP2, selected by the random number table for sampling).

B.1 FEP1

FEP1 has 28 Phase 2 sampling locations (7 sections with 4 sample locations per section). The layout of 10,000-sq-ft sections and “squares” for FEP1 is presented in Exhibit 7-C. Table 2 presents the coordinates for the Phase 2 sampli ng locations at FEP1. Exhibit 7-F shows the coordinate system, the locations of the indi vidual sampling points, the boundaries of the sampling sections within which samples will be composited, and the approximate thicknesses of sludge at FEP1.

B.2 FEP2

FEP2 has 24 Phase 2 sampling locations (6 sections with 4 sample locations per section). The sampling location layout for FEP2 is presented in Exhibit 7-D. Table 3 presents the coordinates for the Phase 2 sampling locations at FEP2. Exhibit 7-F shows the coordinate system, the locations of the individual sampling points, the boundaries of the sampling sections within which samples will be composited, and the approximate thicknesses of sludge at FEP2.

III. Sample Collection – Phase 2

A. Field Health and Safety

The most recent revision to the site-specific health and safety plan prepared for the RCRA corrective action program at the Mt. Athos site will be used to guide implementation of the sample collection activity ( Site-Specific Health and Safety Pl an for BWX Technologies, Inc, Mt. Athos Facility, Lynchburg, Virginia, May, 2005 ).BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM 6 B. Sampling Rig and Navigation Method

A sampling raft will be fabricated from boats. Ropes will be strung across the pond to pull the raft to the designated sample locations. To guide positioning of the raft, rows of pin flags or stakes will be set up along the sides of the pond to locate sampling coordinates.

C. Sampling Equipment and Preparation

Samples will be collected using new, clear polyc arbonate tubes with a wall thickness of 1/8 inch. Cores that are taken only for the purpose of measuring sludge thickness may be collected with used and decontaminated polycarbonate tubes. A typical tube diameter is 2-5/8 inches, but other diameters may be used. Plugs or other seali ng devices will be used to prevent the sludge material from leaking out of the tube while be ing retrieved from the pond depth and transported to the sample process area. Aluminum foil caps s ecured with tape, cable ties or hose clamps may be used to seal the bottom end of the sample tube after each sample is collected.

A new polycarbonate sampling tube will be used to collect each sample from the ponds. All sampling equipment used for sample homogeniza tion and packing (e.g., stainless steel bowls, stainless steel mixing spoons, stai nless steel holding tins, Pyrex la dles) will be decontaminated prior to use for each sample. Personnel will wear new latex gloves when handling samples or sampling equipment. Sampling equipment will be decontaminated as follows:

• DI water rinse

• Liquinox ® soap solution wash

• DI water rinse, twice

• Dilute nitric acid solution rinse

• Final DI water rinse

• Air dried and wrapped in aluminum foil.

D. Sample Handling Area

A work area will be established to decontaminate the sampling equipment and to prepare and process the samples for transport to the laborator y. The area will include separate locations for sample collection, preparation and sample pro cessing, decontamination, and sample and waste storage. All tubs, bowls, drums, and coolers used in processing the sludge sample material will be placed in secondary containment to prevent ac cidental spillage of material onto the ground.

E. Disposal of Investigation-Derived Waste

Investigation-derived wastes should be disposed of as follows:

Pond Water After collecting sludge core s, pond water remaining in the sampling tubes should be drained through the weep hole located above the top of the sludge. The drained pond

water should be stored in an appropriate container. PondBWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM 7 water from the container should then be disposed of back into the pond from which the tube was collected.

Sludge Excess sampled sludge left over after the sample containers are filled should be disposed of back into the pond from which the sample was collected.

Decontamination Water Water generated during decontamination processes should be stored in a labeled 55-g allon drum for treatment and disposal at the low-level radioactive (LLR) Waste Treatment Facility.

PPE After use, personal protective equipment (PPE) such as sample gloves or booties should be placed into a trash bag and labeled according to contents. Trash bags containing PPE waste will be screened for radiation and disposed of by BWXT personnel.

Trash Miscellaneous items (e.g., cardboard boxes, excess tape, string, paper) should be dispos ed of into a trash bag for regular waste disposal performed by BWXT personnel.

F. Sampling Method

Sludge samples will be collected as follows:

1. At each sample location, the depth of water to the top of the sludge layer and the insitu thickness of the sludge will be measured to determine what length of polycarbonate tube is needed. Sludge thickne ss will be measured using a marked rod. Depth to the top of sludge will be measured using a marked rod with a disc or plate that will provide resistance at the sludge layer. After recording the depths, the length of polycarbonate sample tube necessary to collect the full column of sludge will be selected. (However, if the sludge is less th an one-half foot thick, the sludge will not be sampled.) The polycarbonate tubing will be pushed through the sludge layers and driven into the clay layer on the bottom of the pond using a mallet. The clay helps serve as a plug to keep the sample in the tube and as a visual confirmation that the base of the sludge layer is reached.

2. To obtain sufficient sludge for all the analyses, multiple cores may be necessary at each sampling location. In Phase 2, where cores from four sampling squares will be composited (for all parameters except VOC), if multiple cores are needed, then the

same number of cores will be collected fr om each of the sampling squares, and an equal number of tubes from each square will be composited (this is to ensure that the final composite is equally re presentative of the sludge from the four sample locations in the section). See Table 8 for sample volumes and quality control (QC) sample requirements in Phase 2.BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM 8 3. The water inside the tube (above the sludge) may be removed by suction from a peristaltic pump with new polyethylene tubing; this will reduce the weight on the sludge, and thereby improve retention of the sludge core. A plunge r with holes in it, a cap, or a stopper will be inserted on the top end of the sample tube to serve as a seal to retain the sample as the tube is wit hdrawn from the bottom of the pond. The tube containing the sample will be lifted at an angle to reduce the downward pressure on

the column.

4. The sample tube will be held over the side of the boat, and the outside of the sample

tube will be rinsed with DI water. The bottom end will be secured with an aluminum foil cap that will be secured with tape, cable ties or hose clamps to ensure that the sample will not fall out of the tube during handling. The sludge cores will be maintained in a vertical position during ha ndling to preserve sample integrity.

5. Each sample tube will be given a unique identifier that is traceable to the pond number, the location coordinates, and, if multiple cores are necessary, the order in

which tubes are collected at that coordinate location.

6. After sample collection, the total sludge core thickness will be measured (excluding the bottom clay liner), including measurements of any stratification in the sample. The sludge will be described for color and any other visual characteristics, looking through the polycarbonate tube wall. The to tal sludge depth and description will be recorded on a Sample Collection Log. Th e sample collection team will coordinate with BWXT to get photographic documentation of the sludge cores, if possible. If a significant column of water remains on top of the sludge, a hole may be drilled in the sample tube at the top of the sludge layer to allow the water colu mn above the sample to weep out of the tube. Alternatively, a peristaltic pump with new polyethylene tubing may be used to suction off the remaining free water.

7. The sample tubes for analytical samples wi ll be wrapped with new aluminum foil at the top end. Sample tubes collected solely for sludge thickness measurements will be emptied back into the pond where they originated.

8. The analytical sample tubes will be moved to the sample handling area. Sample cores will be chilled until all the cores from one section are collected and ready to be combined into a composite sample.

G. Sample Preparation

The sample chilling system for sludge cores will consist of two (2) 55-gallon open-head drums, several pieces of 6-inch or 10-inch diameter polyvi nyl chloride (PVC) pipe cut in lengths slightly longer than the sample tubes and capped at one e nd, and either ice or dry ice. The PVC pipe sections will be placed into a 55-gallon drum, and the sample tubes will be lowered into the PVC pipes. Ice or dry ice will be poured into the sp aces between the sample tubes until the PVC pipesBWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM 9 are full and the sample tubes are completely cove red. A second drum will be inverted and placed

over the bottom drum.

Core tubes from which samples will be collected for VOC analysis will be split open at the midpoint of sludge thickness with a plastic pipe cutt er. The sludge sample for VOC analysis will be placed in the appropriate sample container (Table 4) with zero head space. The remainder of the sludge in this core tube will be used to form composite samples for other analyses.

The cores from each Phase 2 10,000-sq-ft sampling section will be combined and homogenized, and the homogenized material will be used for f illing the remainder (other than VOC) of the sample containers. Composites must be made from an equal number of cores from each sampling

location.

The cores to be composited will be placed in a new stainless steel pan or other suitable, cleaned metal container. The combined sludges will be homogenized within the container by stirring with a decontaminated utensil. Aliquots of the homogenized sludge will be placed in the appropriate sample bottles.

Table 4 lists the sample containers, preservation requirements, and holding times for the various Phase 2 analytical parameters.

The sample containers will be placed in coolers with ice or stored in a secured refrigerator to maintain a temperature of 4 degrees Celsius (°C) . A temperature blank will be included in each cooler. A custody seal will be placed across each sample container lid or cooler that contains multiple samples.

Samples for VOC analysis will be shipped to the laboratory the same day they are removed from the cores. Other samples preferably will be ship ped to the laboratory the same day also; but if they are held overnight, then the coolers will be kept in a secure, locked location. Sample shipments will conform to DOT regulations for shipment of radioactive materials.

Custody of the samples will be maintained following the chain-of-custody procedures in the BWXT Data Collection Quality Assurance Plan (DCQAP).

H. Field Documentation

The sludge sampling activities will be documen ted on the following kinds of field forms:

• Field Activity Daily Log

• Sample Collection Log

• Chain-of-Custody Form.

Examples of these forms, and how they are used, are included in the DCQAP.

The daily narrative of the fieldwork for the sludge sampling will be documented on Field Activity Daily Logs. Each sludge tube or othe r sample collected will be documented on aBWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM 10 Sample Collection Log. The Sample Collecti on Log will provide the following information about the sample: pond identifier (ID), sample lo cation ID, number of tubes collected at the sampling point, recovered sludge thickness and descri ption, collection of additional material for QC samples, and any comments or observations. A ll samples sent to the laboratory for analysis will be accompanied by a chain-of-custody form, wh ich will also include the request for analysis.

IV. Sample Analysis

A. Analytical Laboratories

All analyses will be performed by laboratories accredited by the National Environmental Laboratory Accreditation Program for those analys es. In Phase 2, it is anticipated that all laboratory analyses will be performed by Severn Trent Laboratory-St. Lo uis, in Earth City, Missouri, except dioxins/furans will be anal yzed by Severn Trent Laboratory-Knoxville, in Knoxville, Tennessee.

B. Phase 2 Analytical Parameters

The Phase 2 analytical parameters, which are listed in Table 1, are as follows:

• Metals – Cadmium, copper, mercury, nickel, and thallium.

• VOCs – 1,2-dichloroethane, tetrach loroethene, and trichloroethene

• Appendix IX PCBs

• Appendix IX Dioxins/furans

• Fluoride.

Dioxins/furans will only be analyzed from three composite samples from each pond. The sampling sections with the highest concentrations of dioxin/furan risk drivers in the Phase 1 samples have been selected for analysis of dioxins /furans in Phase 2. As shown in Exhibit 7-F, samples for dioxin/furan analysis will be collected in pond FEP1 from sampling sections 2, 6, and 7, and in FEP2 from sampling sections 1, 4, and 5.

In contrast to Phase 1, where three types of TC LP extractions were run for each analyte group, in Phase 2 only one type of TCLP extraction wi ll be performed for each analyte – using the extraction liquid that produced the highest soluble concentration in Phase 1. For parameters that were not detected in any type of Phase 1 TCLP extraction, i.e. mercury and PCBs, the standard

TCLP extraction fluid will be used in Phase 2. Table 1 lists which extraction fluid will be used for each parameter.

The laboratory analytical methods will those li sted in Table 4. Anticipated reporting and detection limits are listed in Tables 5, 6 and 7.BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM 11 V. Quality Control Samples

QC samples will be collected and analyzed to veri fy the integrity of the sampling and analytical program. The types of QC samples that will be collected and their general collection frequencies

are described below.

A. Trip Blanks

Trip blanks are applicable only to water samples being analyzed for VOCs, which in this case are only the field blank and equipment rinsate blanks. The blanks are prepared in the laboratory using laboratory-grade DI water. The blanks are transported to the site and back to the laboratory without being opened until the site samples are analyzed. One trip blank will accompany each cooler that contains water sample s to be analyzed for VOCs. The trip blank will be analyzed for VOCs along with the sa mples that it accompanied from the field.

B. Equipment Rinsates

Equipment rinsate samples will be collected during sampling to verify the effectiveness of sampling equipment cleaning and to monitor for pot ential to inadvertently transport constituents of interest between samples. Equipment rinsates will be collected from the final DI water rinses of the sludge homogenization containers. Two rins ate samples will be collected in the Phase 2 sampling event (. The rinsate samples will be analyzed for total concentrations of all the chemical parameters.

C. Field Blanks

Field blanks will be prepared in the field from the source of the DI water used for cleaning. Analysis of field blanks will ensure that al l water sources used during cleaning of sampling equipment are free of the parameters of interest. One field blank will be collected per source of water used for equipment cleaning or one per sa mpling event, whichever is greater. The field blank(s) will be analyzed for total concen trations of all the chemical parameters.

D. Field Duplicates

One field duplicate sample of the sludge will be co llected in Phase 2. The aliquot of the field duplicate for VOC analysis will be collected from an adjacent position on the same sludge core. Field duplicate aliquots for the other analytical parameters will be collected from the homogenized sludge. The field du plicate will be analyzed for th e same parameters as the other sludge samples.

E. Matrix Spike and Matrix Spike Duplicate Samples

Separate field samples will be collected for the laboratory matrix spike/matrix spike duplicate (MS/MSD) analyses. MS/MSD samples are desc ribed in the DCQAP. One pair of MS/MSD samples will be collected for the Phase 2 sampling event.BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM 12 VI. Sample Quantities

Table 8 lists the estimated numbers of sludge samples and QC samples and the sample containers for the Phase 2 sampling.

VII. Data Validation

The analytical data will be validated by Shaw En vironmental, Inc., in accordance with the EPA Region III Innovative Approaches to Data Validation (June 1995). The validation will evaluate the laboratory analytical reports and the associ ated field documentation to determine whether the sampling and analytical method requirements are achie ved. The analytical data generated will be analyzed for precision, accuracy, representative ness, completeness, and comparability. Organic compounds will be validated at level M-2 and inorganic compounds at level IM-1.

The completeness goal for Phase 2 will be a minimum of 90 percent.BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM 13 LIST OF TABLES

1 Analytical Parameters for Phase 2 Sa mpling and Analysis of the FEP Sludges

2 Coordinates of Phase 2 Sludge Sampling Locations – FEP1

3 Coordinates of Phase 2 Sludge Sampling Locations – FEP2

4 Analytical Methods, Sample Containers, and Preservation Requirements for Phase 2 Analyses of FEP Sludges

5 Reporting Limits for Metals, Fluoride, and Vo latile Organics, Phase 2 Analyses of FEP Sludges

6 Reporting Limits for Polychlorinated Bi phenyls, Phase 1 Analyses of FEP Sludges

7 Reporting Limits for Dioxins and Fura ns, Phase 1 Analyses of FEP Sludges

8 Numbers of Sludge and Quality Control Samp les for Phase 2 Analyses of FEP Sludges

LIST OF EXHIBITS

EXHIBIT 7-A Isopach Map of Sediment Mate rial in Ponds 1 and 2 (Figure 2 from the Report of Findings, Sediment Sampli ng from the Final Effluent Ponds , by IT Corp., October 1993)

EXHIBIT 7-B Plan Views and Surf ace Area Calculations for the FEPs

EXHIBIT 7-C Sampling Section Layout for FEP1

EXHIBIT 7-D Sampling Section Layout for FEP2

EXHIBIT 7-E Random Number Table

EXHIBIT 7-F Phase 2 Sludge Sampling LocationsTable 1

Analytical Parameters for Phase 2 FEP Sludge Samples BWXT Mt. Athos Site, Lynchburg, Virginia

A NALYTICAL PARAMETERS FEP 1 FEP 2 TOTAL
Total Analyses (note 1)
VOCs - 1,2-DCA, PCE, and TCE 7 6 13 Metals - Cadmium, Copper, Mercury, Nickel, & Thallium 7 6 13 Appendix IX PCBs 7 6 13 Appendix IX Dioxins/Furans 336

Fluoride 7 6 13 Standard-Extract TCLP Analyses
VOCs - 1,2-DCA, PCE, and TCE 7 6 13 Metals - Cadmium, Copper, Mercury & Nickel 7 6 13 Appendix IX PCBs 7 6 13

A ppendix IX Dioxins/Furans 336 pH 10-Extract TCLP Analyses (note 2)

Thallium 7 6 13 Fluoride (note 4) 7 6 13 Other Analyses Percent water content or percent solids (note 3 ) 7 6 13

App. IX - 40 CFR 264 Appendix IX, Ground-Water Monitoring List

1,2-DCA - 1,2-dichloroethane.

FEP - Final Effluent Pond.
PCB - Polychlorinated biphenyl.

PCE - tetrachloroethene.

TCE - trichloroethene.
TCLP - Toxicity characteristic leaching procedure.
VOC - Volatile organic compound.

Notes:

1 . For total concentration analyses, the sludge samples will be prepared and analyzed as a solid matrix. NO. OF SAMPLES

3. Analytical results will be reported on a wet weight basis. Sludge water content will also be analyzed and reported. 2. pH 10 TCLP analyses use a sodium bicarbonate and sodium carbonate solution of pH 10 as the extraction fluid.

4 . For the TCLP analysis of fluoride, the filtrate liquid and the solid extract liquid should be analyzed separately. Fluoride concentrations will be reported for (1) the volume-weighted average, (2) the filtrate liquid (the liquid separated from the solids prior to extracting the solids), and (3) the solids extract liquid. These extra analyses will provide information about whether the soluble fluoride originates mainly from the solid or liquid phase of the sludge.

KN5\BWXT\FEP\P2 SAP\Ph2 FEP SAP Tab1 4 to 8.xls(Table 1)\10/12/2005(3:41 PM)KN5\BWXT\FEP\P2 SAP\Tab2&3_11-4-04.doc\10/12/2005\3:37 PM Table 2

Coordinates of Phase 2 Sludge Sampling Locations – FEP1 BWXT Mt. Athos Site, Lynchburg, Virginia

LOCATION ID
Section # / Grid # Coordinates LOCATION ID
Section # / Grid # Coordinates

1 / 20 E112, S12 5 / 05 E227, S 6

1 / 22 E18, S21 5 / 26 E235, S 32

1 / 74 E41, S62 5 / 74 E220, S 97

1 / 94 E41, S79 5 / 87 E243, S 110

2 / 16 E65, S96 6 / 05 E186, S 132

2 / 44 E41, S121 6 / 08 E231, S 132

2 / 45 E53, S121 6 / 37 E126, S 156

2 / 93 E30, S162 6 / 95 E126, S 223

3 / 03 E30, S171 7 / 60 E 319, S 51

3 / 04 E41, S171 7 / 63 E 276, S 58

3 / 32 E18, S196 7 / 94 E 276, S 105

3 / 62 E18, S221 7 / 96 E 302, S 105

4 / 01 E122, S 6

4 / 27 E167, S 32

4 / 61 E122, S 84

4 / 89 E182, S 110KN5\BWXT\FEP\P2 SAP\Tab2&3_11-4-04.doc\10/12/2005\3:37 PM Table 3

Coordinates of Phase 2 Sludge Sampling Locations – FEP2 BWXT Mt. Athos Site, Lynchburg, Virginia

LOCATION ID

Section # /
Grid # Coordinates LOCATION ID
Section # / Grid # Coordinates LOCATION ID
Section # / Grid # Coordinates

1 / 01 E 7, S 3 3 / 07 E 218, S 3 5 / 02 E 284, S 3

1 / 16 E 73, S 10 3 / 10 E 258, S 3 5 / 08 E 364, S 3

1 / 29 E 112, S 17 3 / 14 E 178, S 10 5 / 44 E 311, S 31

1 / 98 E 99, S 66 3 / 35 E 192, S 24 5 / 86 E 337, S 59

2 / 05 E 59, S 72 4 / 12 E 152, S 79 6 / 23 E 298, S 86

2 / 11 E 7, S 79 4 / 27 E 218, S 86 6 / 61 E 271, S 114

2 / 61 E 7, S 114 4 / 35 E 192, S 93 6 / 67 E 351, S 114

2 / 89 E 112, S 128 4 / 95 E 192, S 135 6 / 89 E 377, S 128Table 4Analytical Methods, Sample Containers, and Preservation Requirementsfor Phase 2 Analyses of FEP SludgesBWXT Mt. Athos Site, Lynchburg, VirginiaPreparation CleanupAnalytical Sample Holding SampleAnalytical Parameters Method MethodMethod(note 1)Container TimePreservationTotal Analyses(note 5)VOCs - 1,2-DCA, PCE, and TCE SW846-5035 SW846-8260B 2 oz glass 14 days 4oCMetals - Cadmium, Copper, Mercury, Nickel, &ThalliumSW846-3051A and 7471A SW846-6020 & 7471A 4 oz glass180 days,Mercury 28 days4oCAppendix IX PCBsSW846-3540C or 3545A or3550BSW846-3665A orSW846-3665A/3630CSW846-8082 4 oz glass14/40 days(note 6)4oCAppendix IX Dioxins/FuransSW846-8290 4 oz glass28/40 days(note 6)4oCFluoride EPA 300.0 sect 11.7 SW846-9056 4 oz glass 28 days 4oCStandard-Extract TCLP AnalysesSW846-1311VOCs - 1,2-DCA, PCE, and TCE SW846-5030B SW846-8260B 2 oz glass14/14 days(note 2)4oCMetals - Cadmium, Copper, Mercury & Nickel SW846-3015A and 7470A SW846-6020 & 7470A 500 mL glass180/180 days and28/28 (mercury only)(note 2)4oCAppendix IX PCBs SW846-3510C or 3520CSW846-3665A or SW846-3665A/3630CSW846-8082 1 L glass14/7/40 days (note3)4oCAppendix IX Dioxins/FuransSW846-8290 1 L glass28/28/40 days(note 3)4oCpH 10-Extract TCLP Analyses(note 4)SW846-1311 but with pH 10extract fluid (note 4)Thallium SW846-3015A SW846-6020 500 mL glass28/28 days(note 2)4oCFluorideSW846-9056 500 mL glass28/28 days(note 2)4oCOther AnalysesPercent water content (note 1) NA NA CLP Modified NA NA NANotes°C - Degrees Celsius.1.Analytical results will be reported on a wet weight basis.1,2-DCA - 1,2-dichloroethane.FEP - Final Effluent Pond.L - Liter.mL - Milliliter.4.TCLP analyses usingapH 10 sodium bicarbonate/sodium carbonate solution instead of the standard TCLP extraction fluid.NA - Not applicable.5.For total concentration analyses, the sludge samples will beprepared and analyzed as a solid matrix.oz - Ounce.6. 1# / 2# days means 1# days until extraction, 2# days from extraction until determinative analysis.3.1# / 2# / 3# days means 1# days until TCLP extraction, 2# days from TCLP extraction until preparative extraction, 3# days frompreparative extraction untilanalysis.2. 1# / 2# days means 1# days until TCLP extraction, 2# days from TCLP extraction until determinative analysis.KN5\BWXT\FEP\P2 SAP\Ph2 FEP SAP Tab1 4 to 8.xls(Table 4)\10/12/2005(3:41 PM)Table 5Reporting Limits for Metals, Fluoride, and Volatile OrganicsPhase 2 Analyses of FEP SludgesBWXT Mt. Athos Site, Lynchburg, VirginiaLaboratory:Severn-Trent Laboratory - St. LouisNote: Detection and reporting limits are not adjusted for % moisture or sample dilution factors.Detection LimitReporting LimitDetection LimitReporting LimitMetals CAS#Method (note 1) μg/L μg/L μg/kg μg/kgCadmium 7440-43-9 6020 0.067 5 24.5 500Copper 7440-50-8 6020 0.72 10 220.5 1000Mercury 7439-97-6 7470A, 7471A 2 0.046 7.2 33.3Nickel 7440-02-0 6020 1.15 10129.5 1000Thallium 7440-28-0 6020 0.22 10 77.5 1000Miscellaneous Detection LimitReporting LimitDetection LimitReporting LimitCompounds CAS#Method mg/L mg/L mg/kg mg/kgFluoride 16984-48-8 9056 0.040 0.1 0.051 0.1Detection LimitReporting LimitDetection LimitReporting LimitCompound CAS#Method μg/L μg/L μg/kg μg/kg1,2-Dichloroethane 107-06-2 8260B 0.09 5 0.42 5Tetrachloroethene 127-18-4 8260B 0.1 5 0.55 5Trichloroethene 79-01-6 8260B 0.13 5 0.44 5Notes1.For Metals, the first method is for TCLP extract, the second method is for Solid (total analysis). See Table 4.CAS - Chemical Abstract Service.FEP - Final Effluent Pond.μg/kg - Micrograms per kilogram.μg/L - Micrograms per liter.TCLP - Toxicity characteristic leaching procedure.Water or TCLP Extract SolidWater or TCLP Extract SolidWater or TCLP Extract SolidKN5\BWXT\FEP\P2 SAP\Ph2 FEP SAP Tab1 4 to 8.xls(Table 5)\10/12/2005(3:41 PM)Table 6 Reporting Limits for Polychlorinated Biphenyls (PCBs) Phase 2 Analyses of FEP Sludges BWXT Mt. Athos Site, Lynchburg, Virginia

Method: SW846-8082 Laboratory: Severn-Trent Laboratory - St. Louis

Note: Detection and reporting limits are not adjusted for % moisture or sample dilution factors.

Detection Limit Reporting Limit Detection Limit Reporting Limit Compound CAS # μg/L μg/L μg/kg μg/kg

AROCLOR-1016 12674-11-2 2.2 10 4.68 33

AROCLOR-1221 11104-28-2 2.2 10 4.68 33

AROCLOR-1232 11141-16-5 4.9 10 4.68 33

AROCLOR-1242 53469-21-9 2.0 10 4.68 33

AROCLOR-1248 12672-29-6 1.4 10 4.68 33

AROCLOR-1254 11097-69-1 1.4 10 4.77 33

AROCLOR-1260 11096-82-5 1.4 10 4.77 33

Notes

CAS - Chemical Abstract Service.

FEP - Final Effluent Pond. μg/kg - Micrograms per kilogram. μg/L - Micrograms per liter. TCLP - Toxicity characteristic leaching procedure. Water or TCLP Extract Solid

KN5\BWXT\FEP\P2 SAP\Ph2 FEP SAP Tab1 4 to 8.xls(Table 6)\10/12/2005(3:42 PM)Table 7 Reporting Limits for Dioxins and Furans Phase 2 Analyses of FEP Sludges BWXT Mt. Athos Site, Lynchburg, Virginia

Method: SW846-8290 Laboratory: Severn Trent Laboratory - Knoxville

Note: Detection and reporting limits are not adjusted for % moisture or sample dilution factors.

Water or

TCLP Extract Solid Reportin g Limit Reportin g Limit Compound CAS # pg/L ng/kg 2,3,7,8-TCDD 1746-01-6 10.0 10.0 1,2,3,7,8-PeCDD 40321-76-4 25.0 25.0 1,2,3,4,7,8-HxCDD 39227-28-6 25.0 25.0 1,2,3,6,7,8-HxCDD 57653-85-7 25.0 25.0 1,2,3,7,8,9-HxCDD 19408-74-3 25.0 25.0 1,2,3,4,6,7,8-HpCDD 35822-39-4 25.0 25.0 1,2,3,4,6,7,8,9-OCDD 3268-87-9 50.0 50.0 2,3,7,8-TCDF 51207-31-9 10.0 10.0 1,2,3,7,8-PeCDF 57117-41-6 25.0 25.0 2,3,4,7,8-PeCDF 57117-31-4 25.0 25.0 1,2,3,4,7,8-HxCDF 70648-26-9 25.0 25.0 1,2,3,6,7,8-HxCDF 57117-44-9 25.0 25.0 2,3,4,6,7,8-HxCDF 60851-34-5 25.0 25.0 1,2,3,7,8,9-HxCDF 72918-21-9 25.0 25.0 1,2,3,4,6,7,8-HpCDF 67562-39-4 25.0 25.0 1,2,3,4,7,8,9-HpCDF 55673-89-7 25.0 25.0 1,2,3,4,6,7,8,9-OCDF 39001-02-0 50.0 50.0

Notes

CAS - Chemical Abstract Service.

FEP - Final Effluent Pond. ng/kg - Nanograms per kilogram. pg/L - Picograms per liter. TCLP - Toxicity characteristic leaching procedure.

KN5\BWXT\FEP\P2 SAP\Ph2 FEP SAP Tab1 4 to 8.xls(Table 7)\10/12/2005(3:42 PM)Table 8Numbers of Sludge and Quality Control Samplesfor Phase 2 Analyses of FEP SludgesBWXT Mt. Athos Site, Lynchburg, VirginiaSample No. of No. of No. of No. of No. ofTotal(7)Container Sludge Field No. of No. of Equipment Trip Field No. ofAnalysis Matrix TypeSamples(1)Duplicates(2)MS(3)MSD(3)Rinsates(4)Blanks(5)Blanks(6)SamplesTotal AnalysesSludge 2 oz glass 13 1 1 1 see below see below see below 16Blank water 3 x 40 mL vials2 3 16Sludge 4 oz glass 13 1 1 1 see below see below 16Blank water 500 mL poly2 13Sludge 4 oz glass 13 1 1 1 see below see below 16Blank water 2 x 1 L glass2 13Sludge 4 oz glass 6 1 1 1 see below see below 9Blank water 2 x 1 L glass2 13Sludge 4 oz glass 13 1 1 1 see below see below 16Blank water 100 mL poly2 13Standard-Extract TCLP AnalysesVOCs - 1,2-DCA, PCE, and TCE Sludge 2 oz glass 13 1 1 1 16Metals - Cadmium, Copper, Mercury &NickelSludge 500 mL glass 13 1 1 1 16Appendix IX PCBs Sludge 1 L glass 13 1 1 1 16Appendix IX Dioxins/Furans Sludge 1 L glass 6 1 1 1 9pH 10-Extract TCLP AnalysesThallium Sludge 500 mL glass 13 1 1 1 16Fluoride Sludge 500 mL glass 13 1 1 1 16Other AnalysesPercent water content SludgeNA(8)13 114Notes(1) Each sludge sample is a composite from four cores taken within a sampling sector, except for VOCs, which are taken from a single core.(2) One field duplicate for every 20 sludge samples, or one per sampling event, whichever is more frequent.(3) One pair of MS/MSD samples will be collected for every 20 sludge samples, or one per sampling event, whichever is more frequent. These samples will require double volume.(4) One equipment rinsate per 20 sludge samples or 2 per sampling event, whichever is more frequent.(5) One trip blank for each cooler containing Equipment Rinsate or Field Blank samples for VOC analysis. No trip blanks for sludge samples.(6) One field blank per source of water used for field equipment cleaning, or one per sampling event, whichever is greater. Assumes one source of water per sampling event.(7) In addition to these sample numbers, all coolers will also contain a temperature blank.(8) A separate container is not required for the moisture content sample.1,2-DCA - 1,2-dichloroethane. oz - Ounce.FEP - Final Effluent Pond. PCB - Polychlorinated biphenyl.L - Liter. PCE - tetrachloroethene.mL - Milliliter. TCE - trichloroethene.MS - Matrix spike.TCLP - Toxicity characteristic leaching procedure.MSD - Matrix spike duplicate.VOC - Volatile organic compound.NA - Not applicable.Appendix IX Dioxins/FuransFluorideQuality Control SamplesVOCs - 1,2-DCA, PCE, and TCEMetals - Cadmium, Copper, Mercury,Nickel, & ThalliumAppendix IX PCBsKN5\BWXT\FEP\P2 SAP\Ph2 FEP SAP Tab1 4 to 8.xls(Table 8)\10/12/2005(3:42 PM)BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM EXHIBIT 7-A

ISOPACH MAP OF SEDIMENT MATERIAL IN PONDS 1 AND 2 (FIGURE 2 FROM

THE REPORT OF FINDINGS, SEDIMENT SAMPLING FROM THE FINAL

EFFLUENT PONDS , BY IT CORP., OCTOBER 1993)BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM EXHIBIT 7-B

PLAN VIEWS AND SURFACE AREA CALCULATIONS FOR THE FEPSBWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM EXHIBIT 7-C

SAMPLING SECTION LAYOUT FOR FEP1BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM EXHIBIT 7-D

SAMPLING SECTION LAYOUT FOR FEP2BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM EXHIBIT 7-E

RANDOM NUMBER TABLEEXHIBIT 7-E

RANDOM NUMBER TABLE

(Page 1 of 2)

FEP 1

Section 1

Section 2

Section 3

Section 4

Section 5

Section 6

Section 7

KN5\BWXT\FEP\P2 SAP\Exhibit 7-E.xls(Sheet1)\10/12/2005(3:40 PM) Page 1 of 2EXHIBIT 7-E

RANDOM NUMBER TABLE

(Page 2 of 2)

FEP 2

Section 1

Section 2

Section 3

Section 4

Section 5

Section 6

KN5\BWXT\FEP\P2 SAP\Exhibit 7-E.xls(Sheet1)\10/12/2005(3:40 PM) Page 2 of 2BWXT - FEP Delisting Petition 10/12/05

KN4\BWXT\FEP\SAP\Exh 7\11-04\Ph 2 FEP SAP Txt.doc\10/12/2005\3:35 PM EXHIBIT 7-F

PHASE 2 SLUDGE SAMPLING LOCATIONS