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 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 1

EXHIBIT 7 

FINAL EFFLUENT POND 

PHASE 2 SLUDGE SAMPLING AND ANALYSIS PLAN 

Introduction

This plan revision reflects the results and conclusions from the Phase 1 sludge sampling and 

analysis. The Phase 1 results were presented in the May 2005 draft 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. Environmental Protection Agency on September 8, 

2005. The Phase 2 analytical parameters, which are also listed in Table 1, will be as follows: 

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

• Volatile organics (VOC) – 1,2-dichloroethane, 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 dioxin/furan risk drivers in the 

Phase 1 samples have been selected for sampling 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 analyses for thallium and fluoride 

will use a pH 10 solution of sodium bicarbonate and sodium carbonate (Table 1). 

Additionally, 17 supplemental sludge coring locations, as shown in Exhibit 7-F, have been 

selected to measure sludge thickness where there 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 sampling tubes. Recovered core thickness, when 

applied to the analytical results, will be a more accurate measure of total constituent mass than 

would in-situ sludge thickness (see the 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 reduce 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 frozen solid, which hindered collection of VOC 

samples. The sludge samples for VOC analysis 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 separate 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 used to calculate and report the 

TCLP-extractable fluoride concentration in the sludge samples. Presenting fluoride 

results for the separate liquid phases will provide additional information about 

whether the soluble fluoride originates mainly from the solid or liquid phase of the 

sludge. 

I. Overview

To provide a comprehensive sludge sampling strategy 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 representative locations in each pond and analyzed 

for the comprehensive list of chemical compounds and other analytical parameters. The 

analytical parameter list included the 40 Code of Federal Regulations (CFR) 264 Appendix IX 

(Groundwater Monitoring List) analytes for the 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. Other 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)-extractable concentrations. Past sampling of the 

sludges has shown them to have high water contents. (Phase 1 sludge samples had solid contents 

ranging from 17 to 57 percent). Therefore, chemical concentrations were reported on a wetweight basis. Sludge water content was also analyzed 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 described in TCLP Method 1311, the sludge was 

extracted at two other pH values and analyzed. 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 extractions 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) thickness determined in a 1993 study of the FEPs. 

Exhibit 7-F shows both the 1993 and 2005 measurements 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 multiple 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 collect 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. Horizontal 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 representative 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 the 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 using 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 referred to as “squares”). 

Finally, a random number table is used to select four squares for sampling within each section. 

Each of the four “squares” within 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 until 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. Exhibit 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 sampling “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 sections. Due to the irregular shape of FEP1, the 

surface area of the sections varies 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. Sampling 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 second set or a third set of random numbers that 

provides a better representation was chosen (FEP1 Sections 5 and 7, and FEP2 Section 2). 

Each of the sampling points selected using 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 selected 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 sampling locations at FEP1. 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 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 Plan 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 polycarbonate 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 sealing devices will be used to prevent the sludge 

material from leaking out of the tube while being retrieved from the pond depth and transported 

to the sample process area. Aluminum foil caps secured 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 homogenization and packing (e.g., stainless steel bowls, 

stainless steel mixing spoons, stainless steel holding tins, Pyrex ladles) 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 laboratory. The area will include separate locations for 

sample collection, preparation and sample processing, 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 accidental 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 cores, 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. Pond 
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 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-gallon 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 disposed 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 thickness 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 than 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 from 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 representative 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 plunger 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 withdrawn 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 handling 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 total sludge depth and description will be 

recorded on a Sample Collection Log. The 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 column 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 will 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 polyvinyl chloride (PVC) pipe cut in lengths slightly 

longer than the sample tubes and capped at one end, 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 spaces between the sample tubes until the PVC pipes 
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 9

are full and the sample tubes are completely covered. 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 cutter. 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 filling 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 shipped 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 documented 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 other sample collected will be documented on a 
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 10

Sample Collection Log. The Sample Collection Log will provide the following information 

about the sample: pond identifier (ID), sample location ID, number of tubes collected at the 

sampling point, recovered sludge thickness and description, collection of additional material for 

QC samples, and any comments or observations. All samples sent to the laboratory for analysis 

will be accompanied by a chain-of-custody form, which 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 analyses. In Phase 2, it is anticipated that all 

laboratory analyses will be performed by Severn Trent Laboratory-St. Louis, in Earth City, 

Missouri, except dioxins/furans will be analyzed 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, tetrachloroethene, 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 TCLP extractions were run for each analyte group, 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. Table 1 lists which extraction fluid will be used 

for each parameter. 

The laboratory analytical methods will those listed 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 verify 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 samples to be analyzed for VOCs. The trip blank 

will be analyzed for VOCs along with the samples 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 potential 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 rinsate 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 all 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 sampling event, whichever is greater. The field 

blank(s) will be analyzed for total concentrations of all the chemical parameters. 

D. Field Duplicates 

One field duplicate sample of the sludge will be collected 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 duplicate will be analyzed for the 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 described 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 Environmental, 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 associated field documentation to determine whether the 

sampling and analytical method requirements are achieved. The analytical data generated will be 

analyzed for precision, accuracy, representativeness, 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 Sampling 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 Volatile Organics, Phase 2 Analyses of FEP 

Sludges 

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

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

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

LIST OF EXHIBITS 

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) 

EXHIBIT 7-B Plan Views and Surface 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 Locations 
Table 1

Analytical Parameters for Phase 2 FEP Sludge Samples

BWXT Mt. Athos Site, Lynchburg, Virginia

ANALYTICAL 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

Appendix 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 110 
KN5\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 128 
Table 4

Analytical Methods, Sample Containers, and Preservation Requirements 

for Phase 2 Analyses of FEP Sludges

BWXT Mt. Athos Site, Lynchburg, Virginia

Preparation Cleanup Analytical Sample Hol

Analytical Parameters Method Method Method (note 1) Container Ti

Total Analyses (note 5)VOCs - 1,2-DCA, PCE, and TCE SW846-5035 SW846-8260B 2 oz glass 14 Metals - Cadmium, Copper, Mercury, Nickel, & Thallium SW846-3051A and 7471A SW846-6020 & 7471A 4 oz glass 180 

Mercury 

Appendix IX PCBs SW846-3540C or 3545A or 3550B SW846-3665A or SW846-3665A/3630C SW846-8082 4 oz glass 14/4

(no

Appendix IX Dioxins/Furans SW846-8290 4 oz glass 28/4

(no

Fluoride EPA 300.0 sect 11.7 SW846-9056 4 oz glass 28 Standard-Extract TCLP Analyses SW846-1311VOCs - 1,2-DCA, PCE, and TCE SW846-5030B SW846-8260B 2 oz glass 14/1

(no

Metals - Cadmium, Copper, Mercury & Nickel SW846-3015A and 7470A SW846-6020 & 7470A 500 mL glass

180/180 

28/28 (me

(no

Appendix IX PCBs SW846-3510C or 3520C SW846-3665A or SW846- 3665A/3630C SW846-8082 1 L glass 14/7/40 daAppendix IX Dioxins/Furans SW846-8290 1 L glass 28/28/

(no

pH 10-Extract TCLP Analyses (note 4) SW846-1311 but with pH 10 extract fluid (note 4)

Thallium SW846-3015A SW846-6020 500 mL glass 28/2

(no

Fluoride SW846-9056 500 mL glass 28/2

(no

Other AnalysesPercent water content (note 1) NA NA CLP Modified NA NNotes

°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 using a pH 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 be prepared 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 fro

analysis.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 5

Reporting Limits for Metals, Fluoride, and Volatile Organics

Phase 2 Analyses of FEP Sludges

BWXT Mt. Athos Site, Lynchburg, Virginia

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 

Metals CAS # Method (note 1) μg/L μg/L μg/kg 

Cadmium 7440-43-9 6020 0.067 5 24.5 Copper 7440-50-8 6020 0.72 10 220.5 Mercury 7439-97-6 7470A, 7471A 2 0.046 7.2 Nickel 7440-02-0 6020 1.15 10 129.5 

Thallium 7440-28-0 6020 0.22 10 77.5 Miscellaneous Detection Limit Reporting Limit Detection Limit 

Compounds CAS # Method mg/L mg/L mg/kg 

Fluoride 16984-48-8 9056 0.040 0.1 0.051 

Detection Limit Reporting Limit Detection Limit 

Compound CAS # Method μg/L μg/L μg/kg 

1,2-Dichloroethane 107-06-2 8260B 0.09 5 0.42 Tetrachloroethene 127-18-4 8260B 0.1 5 0.55 Trichloroethene 79-01-6 8260B 0.13 5 0.44 Notes

1. 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 SWater or TCLP Extract SWater or TCLP Extract S

KN5\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

Reporting Limit Reporting 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 8

Numbers of Sludge and Quality Control Samples

for Phase 2 Analyses of FEP Sludges

BWXT Mt. Athos Site, Lynchburg, Virginia

Sample No. of No. of No. of No. of 

Container Sludge Field No. of No. of Equipment Trip 

Analysis Matrix Type Samples (1) Duplicates (2) MS (3) MSD (3) Rinsates (4) Blanks (5) 

Total Analyses

Sludge 2 oz glass 13 1 1 1 see below see below 

Blank water 3 x 40 mL vials 2 3 

Sludge 4 oz glass 13 1 1 1 see below 

Blank water 500 mL poly 2 

Sludge 4 oz glass 13 1 1 1 see below 

Blank water 2 x 1 L glass 2 

Sludge 4 oz glass 6 1 1 1 see below 

Blank water 2 x 1 L glass 2 

Sludge 4 oz glass 13 1 1 1 see below 

Blank water 100 mL poly 2 

Standard-Extract TCLP AnalysesVOCs - 1,2-DCA, PCE, and TCE Sludge 2 oz glass 13 1 1 1 Metals - Cadmium, Copper, Mercury & Nickel Sludge 500 mL glass 13 1 1 1 Appendix IX PCBs Sludge 1 L glass 13 1 1 1 Appendix IX Dioxins/Furans Sludge 1 L glass 6 1 1 1 pH 10-Extract TCLP AnalysesThallium Sludge 500 mL glass 13 1 1 1 Fluoride Sludge 500 mL glass 13 1 1 1 Other AnalysesPercent water content Sludge NA (8) 13 1 

Notes

(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 doub(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 e(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/FuransFluoride

Quality Control Samples

VOCs - 1,2-DCA, PCE, and TCE

Metals - Cadmium, Copper, Mercury, Nickel, & ThalliumAppendix IX PCBs

KN5\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 FEPS 

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-C 

SAMPLING SECTION LAYOUT FOR FEP1 



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-D 

SAMPLING SECTION LAYOUT FOR FEP2 


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-E 

RANDOM NUMBER TABLE 

 
EXHIBIT 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 2
EXHIBIT 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 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

EXHIBIT 7-F 

PHASE 2 SLUDGE SAMPLING LOCATIONS