



  

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania  19103-2029



August 19, 2004







John M. Storton, Advisory Engineer

Environmental Safety Health & Safeguards Department

BWX Technologies, Inc.

Nuclear Products Division

P.O. Box 785

Lynchburg, VA  24505-0785





Dear Mr. Storton,



	We have reviewed the additional information dated June 15, 2004, which
you submitted in support of your delisting petition.  We have the
following additional comments on your Final Effluent Pond Sludge
Sampling and Analysis (S/A) Plan.



1.  Data Validation - Based on our comment letter dated February 12,
2004, BWXT revised the S/A Plan to indicate that the analytical data
will be validated in accordance with EPA Region III, Innovative
Approaches to Data Validation (June 1995).  This document contains
several validation levels which were designed to be appropriate for
various data uses.  Therefore, the plan should specify the validation
level for organics and inorganics appropriate for this project.  We
request that data of this type be validated at a minimum level of M-2
for organics and IM-1 for inorganics.



2.  Dioxin/Furan analysis - Table 4,  Analytical Methods, Sample
Containers, and Preservation Requirements, lists SW-846 Method 8280A as
the analytical method to be used for the analysis of dioxins and furans.
 We request that the more sensitive SW-846 Method 8290 or EPA Office of
Water Method 1613 be used, since the data from this analysis will be
used in a risk assessment.



3.  TCLP analysis - On page 1of the S/A Plan, in the next to last
paragraph, the plan states, “Note that organics that are not detected
in the total analyses do not need to be analyzed in the TCLP and
multiple pH extracts.”  



We request that the organic constituents listed under 40 CFR §261.24 be
analyzed in the TCLP leachate, even if they are not detected above the
reporting limit in the total analysis.  In the EPA Delisting Program
Guidance Manual for the Petitioner, March 23, 2000, Exhibit 2 (Analyses
for Constituents of Concern and Hazardous Waste Characteristics), the
next to last bullet in this table includes total constituent and TCLP 
analyses for the organic constituents listed under 40 CFR §261.24.  



It is the last bullet in this exhibit which addresses the total
constituent and TCLP for any other organic constituents of concern that
could potentially be present in the waste [emphasis added] where the
guidance states that, “You do not need to conduct TCLP analyses if the
constituent is not detected in the total constituent analyses...” 



	I would like to further request that you provide the Virginia
Department of Environmental Quality (VADEQ) and me with a schedule for
implementation of this project plan.  I would appreciate receiving
notification at least fourteen (14) day prior to the actual sampling
event, so that we can attempt to arrange to have someone on site to
observe the implementation of the sampling plan.



	If you have any questions or concerns, please feel free to contact me
at 214/814-3395, or at the above address.







Sincerely,







David M. Friedman

Delisting Coordinator

Waste and Chemicals Management Division

EPA Region III

































cc:	Mike Jacobi (EPA)

	Cynthia Nadolski (EPA)

	Hassan Vakili (VADEQ)

