SUMMARYOFSLUDGEREMOVALPROJECTBWXTechnologiesInc.September2,2008FinalEffluentPondsOperatingHistoryTheFinalEffluentPonds(FEPs)attheBWXTechnologies,Inc.(BWXT)Mt.AthossiteinLynchburg,Virginiaaretwopondslocatedinthenortheastcornerofthesite.ThepondsarepartofBWXT’swastewatertreatmentsystem.TheyprovideequalizationofthetreatedwastewatereffluentforcontrolofpHandsuspendedsolidspriortodischargetoJamesRiver.Thesystem,includingtheFEPs,ispermittedbytheVirginiaDepartmentofEnvironmentalQuality.TheFEPscontainlowlevelradioactivesolids.Forthisreason,theyareincorporatedintoBWXLsNuclearRegulatoryCommission(NRC)licensethatpermitsBWXTtoprocessandpossessradioactivematerials.AphotographoftheFEPsispresentedinFigure1.FEP1(601)istriangularshapedandFEP2(701)isrectangularshapeandclosertotheJamesRiver.FEP1wasplacedinservicein1973withanominalcapacityof2,000,000gallons.FEP2wasplacedinservicein1979withanominalcapacityof1,900,000gallons.BothFEPswereconstructedusingexistingon-siteclaysoilasaliner.ThesurfaceareasofFEP1andFEP2areapproximately1.6and1.4acres.ThesludgeintheFEPsoriginatesfromsuspendedsolidscarriedoverfromtheneutralizationofradioactiveandindustrialwastewaters.TheindustrialwastewatersincludeeffluentfromaprocessthatwasconsideredbyVDEQtogeneratealistedF006hazardouswaste.BWXTsuccessfullydelistedtheF006filtercakesolidsin2000.Thus,Figure1BWXT’sFinalEffluentPonds2of69/2/2008the currently generated

filter cake solids

that

are discharged

into
the ponds

are

no longer an F006 waste. BWXT

was not able

to retroactively

delist

the suspended

solids deposited

in the FEPs prior

to the delisting

date.

The delisting petition

that was granted only addressed

the F006 solids

on

a go forward
basis. During

their operating

life, both FEPs have received wastewater

with suspended

solids from BWXT’s radioactive processing

areas.

The solids deposited

in both ponds contain low levels

of radioactivity.

Under

its NRC license, BWXT

has analyzed

the levels

of radioactivity

in the FEP sludge several times.

The sludge

in the FEPs

is regulated

by the NRC

and

is also considered

to be

a listed F006 hazardous

waste. Upon removal

from

the ponds,

the sludge must

be managed

and regulated

as

a mixed waste.

The FEP sludge must

be dewatered

to meet

the free water waste acceptance

criteria

at

a licensed mixed (radioactive/hazardous)

waste disposal facility. FEPs Sludge Removal Project BWXT contracted

with EnergySolutions

to remove

as much sludge

as possible

from

the FEPs under

a turnkey project

for the removal, shipping

and disposal

of the waste. EnergySolutions

is

a conglomerate

of nuclear engineering,

nuclear waste processing

and nuclear waste disposal organizations. EnergySolutions

developed

a sludge removal approach

for the FEPs

that

is presented

in the following schematic.FinalEffluentPondsSolids Schematic

of FEP Sludge Removal Operation 3 of

6

9/2/2008Adredge(smallselfpropelledvesselwitharotor-tillerlikerake)wasoperatedineachpond.SludgewasremovedsystematicallyfromtheFEPsfollowinganestablishedgrid.AphotographofthedredgeispresentedinFigure2.Acranewasusedtoplaceandremovethedredgefromtheponds.Thedredgewasguidedbyacablethatranthelengthofeachpond.Thecablewasattachedtomovableconcreteanchor.Theanchorswererelocatedaftereachpasssothattheentiresurfaceareaofthepondwascovered.Afterfollowingitscableroutesbackandforthacrossthepond,thedredgeoperatedaroundtheperimeterofthepondtoensurethatanyresiduesludgeinthepondwasremoved.Thedredgefluidizedthesludgeandpumpedittoanagitationtankwherechemicalswereaddedtoimprovethefilterabilityofthesolids.A213cubicfootfilterpresswasusedtoremovethesolidsfromthesludgeslurry.Thefiltrate(water)wasreturnedtothepond.‘Whenthefilterpressreacheditsoperatingpressureitwas“blowndown”(excessivewaterremoved)andtheresultingfiltercakewasdroppedontoamovingconveyorbelt.Thefiltercakewasdepositedintoaliftliner(240cubicfootsuper-sack)thatservedasanIP-2shippingcontainer.Asmallquantityofwateradsorbentwasaddedtoeachliftlinertoensurethatthepackagedmixedwastemetthefreewatercriteriaatthedisposalsite.Thefiltercakegeneratedinthedewateringprocesswasonaverageapproximately25percentofthevolumeofthesludgepumpedtothefilterpress.ThephotographsofthesetupandfinalarrangementofthesludgedewateringsystemarepresentedinFigures3and4.Figure2DredgelocatedinFinalEffluentPond1(notefrontend“rototiller”device)4of69/2/2008The filled super-sacks

were weighed

and shipped

in covered Gondola railcars

to the licensed mixed waste disposal facility.

The sludge removal project generated

a total

of 450 super-sacks

that contained

4,050 cubic yards (109,000

cubic feet)

of filter cake,

for

a- Figure

3 Agitation

Tank

and Filter Press being Setup Figure

4 Final System
Setup

and Operating arrangement 5 of

6

9/2/2008total

of 7.3 million pounds

of mixed waste.

The mixed waste

was shipped

to the disposal site

in 37 high sided Gondola railcars. BWXT

is confident

that

all of the mixed waste

that could

be practically removed

from the FEPs

was removed.

The dredge operator

was able

to differentiate

from sludge

and the clay bottom

of the FEPs based

on the operational parameters

of the dredge,

and EnergySolutions

is confident

that sludge

in both FEPs

was removed

to the maximum extent practicable.

The volume

of filter cake generated

in the dewatering

process

is approximately
equivalent

to 4,050 cubic yards (109,000

cubic feet)

of sludge removed from

the FEPs.

In 2005,

the total volume

of sludge residing

in the ponds

was estimated at 13,200 cubic yards (356,400

cubic feet) based

on detailed measurements

of
in situ sludge thickness (BWXT,
2005). Therefore,

only

a small quantity

of the sludge remains in the FEPs. Recently BWXT dropped

the water level

in FEP

1 in order

to perform

some maintenance work

on the inlet pipe

to the pond.

FEP

1 was relatively

free

of sludge along

its perimeter

and towards

the center

of the pond. However, adjacent

to the inlet pipe, there was

a quantity

of sludge, estimated

to be on the order

of 2,000 cubic

feet based

on the apparent

area and thickness

of the residual sludge. Assuming

that

an equivalent
volume of sludge remains

in FEP

2 (4,000 cubic

feet
for both FEPs),

it is estimated

that more than 98%

of the sludge

has been removed

from

the ponds. 6of6

9/2/2008