ML071660105

Yankee Nuclear Power Station Site Closure Project Amended Phase III - Remedial Action Plan/Phase IV - Remedy Implementation Plan

ML071660105
Person / Time
Site:	Yankee Rowe
Issue date:	06/17/2005
From:	Jesse Rollins Yankee Atomic Electric Co
To:	Howland D NRC/FSME, State of MA, Dept of Environmental Protection
References
BYR 2005-055 RTN 1-13411
Download: ML071660105 (209)

Text

YANKEE ATOMIC ELECTRIC COMPANY 49 Yankee Road, Rowe, Massachusetts01367 June 17,2005 BYR 2005-055 Mr. David Howland Massachusetts Department of Environmental Protection DEP Western Region 436 Dwight Street Suite 402 Springfield, MA 01103

Subject:

- Yankee Nuclear Power Station (YNPS) Amended Phase Il - Remedial Action Plan/Phase IV - Remedy Implementation Plan

Dear Mr. Howland:

The enclosed YNPS Amended Phase II - Remedial Action Plan/Phase IV - Remedy Implementation Plan was prepared to summarize the:

• Results of the initial and detailed evaluation of remedial action alternatives and results of the initial screening.

• Justification for the selection of the proposed remedial alternatives.

• Design criteria to be used for the remedial alternatives.

• Plans and procedures for implementation of the remedial alternatives.

• Sampling and analysis plan for to confirm remedial objectives have been met.

• Permits and approvals needed to implement the remedial alternatives.

" Schedule for implementation of the remedial alternatives.

" Health and Safety Plan.

The purpose of the amended Phase IIIIV Report is to update the remedial action and implementation plans for the Site based on the most current site data generated during continuing decommissioning activities. This amended Phase Ill/TV Report specifically addresses reported non-radiological releases identified in soil discovered since completion of the Phase IlI/Phase IV for the Site.

MA Department of Environmental Protection Western Region'Office BYR 2005-055,Page 2 of 2 This Amended-Phase tIl/Phase IV Reportis submitted in fulfillment of the requirements of the Massachusetts Contingency Plan (MCP), Code of Massachusetts Regulation (310 CMR 40.0000) for a Phase ml1-Remedial Action. Plan (Phase In) Iursuant to 310CMR-40.0850 and Phase IV-Remedy Implementation Plan (Phase IV) pursuant to 310 CMR 40.0870.

Should you have questions or require additional information, please contact us.

Sincerely, YANKEE ATOMIC ELECTRIC COMPANY Jack D. Rollins Licensing and Regulatory Affairs Manager

Attachment:

YNPS Amended Phase III- Remedial Action Plan/Phase IV - Remedy ImplementionPlan ce: R. Walker, Director, Radiation Control Program, MA DPH M. Whalen, Radiation Control Program, MA DPH L. Hansen MA DEP ( O)

T. Kurpaska, MA DEP (WRO)

N. Bettinger, MA DEP (Boston)

C. Rowen, MA DEP (Boston)

L. Dunlavy, Franklin Regional Council of Government P. Sloan, Greenfield Director of Planning & Development W. Perlman, F RegionalPlanning Board T. Hutcheson, Franklin Regional Planning Board M. Roseknsten, US EPA, Chemicals Management Branch Chief M. Ballew, US EPA, Region I (Boston)

P. Newkirk, US EPA, Headquarters K. Tisa, US EPA, Region I, TSCA Coordinator

. Hickman, Project Manager, NRC NMSS L Kotton, Regional nseor,NRC Region I M. Fischer USGen New Englad, Inc.

D. Kati, Citizen's AwarenessNetwork Public Repository at Greenfield Community College J. Block, Esq.

Amended Phase Ill-Remedial Action Plan/Phase IV-Remedy Implementation Plan Yankee Nuclear Power Station Site Closure Project Rowe, Massachusetts Oy KE'E)

'"OWAffX8MWMOSO4 17 June 2005 ERM 399 Boylston St.

Boston, MA 02116 (617) 646-7800 www.erm.com Delivering sustainablesolutions in a more competitive world ERM

IFINAL fZ[e]IIT I Yankee Atomic Electric Company Phase III-Remedial Action Plan/Phase IV-Remedy Implementation Plan Yankee Nuclear Power Station RTN 1-13411 49 Yankee Road Rowe, Massachusetts 17 June 2005 ERM Reference 0015181 Karen L Brody.,LSP Project Engineer Environmental Resources Management 399 Boylston Street, 6th Floor Boston, Massachusetts 02116 T: (617) 646-7800 F: (617) 267-6447

TABLE OF CONTENTS LIST OF TABLES iv LIST OF FIGURES v LIST OFAPPENDICES vi LIST OFACRONYMNS vii

1.0 INTRODUCTION

1

1.1 BACKGROUND

1 1.2 PURPOSE & SCOPE 2 1.3 REPORT ORGANIZATION 3 1.4 RELEVANT CONTACTS 4 2.0

SUMMARY

OF PHASE II COMPREHENSIVE SITE ASSESSMENT 5 2.1 SITE ASSESSMENT INFORMATION

SUMMARY

5 3.0 REMEDIAL ACTION OBJECTIVES 9 3.1 OVERVIEW 9 3.2 REMEDIAL ACTION OBJECTIVES 10 3.2.1 PCBs 10 3.2.2 Dioxin 10 3.2.3 Petroleum Hydrocarbons 10 3.2.4 Lead 11 3.3

SUMMARY

OF REMEDIAL AREAS 11 3.3.1 PCBS 11 3.3.2 Dioxin 12 3.3.3 Petroleum Hydrocarbons 12 3.3.4 Lead 12 4.0 IDENTIFICATIONAND INITIAL SCREENING OF REMEDIAL TECHNOLOGIES 13 ERM i YANKEE/0028054-6/7/05

4.1 OVERVIEW 13 4.2 IDENTIFICATION OF REMEDIAL TECHNOLOGIES 13 4.2.1 PCBs, Dioxin and Petroleum Hydrocarbons 13 4.2.2 Lead 15 4.3 TECHNOLOGY SCREENING 17 4.3.1 PCBs, Dioxin and Petroleum Hydrocarbons 17 4.3.2 Lead 23 5.0 DETAILED EVALUATION OF ALTERNATIVES 26 5.1 OVERVIEW 26 5.2

SUMMARY

OFALTERNATIVES 26 5.2.1 PCBs, Dioxin and Petroleum Hydrocarbons 26 5.2.2 Lead 27 5.3 SCREENING CRITERIA 28 5.4 EVALUATION OF ALTERNATIVES 29 5.4.1 PCBs, Dioxin, Petroleum Hydrocarbons 29 5.4.2 Lead 33 6.0 COMPARATIVE EVALUATION OFALTERNATIVES 37 6.1 OVERVIEW 37 6.2 PCBS, DIOXIN AND PETROLEUM HYDROCARBONS 39 6.3 LEAD 39 7.0 RECOMMENDED REMEDIAL ALTERNATIVES 40 7.1 SELECTION OF REMEDIAL ACTION ALTERNATIVES 40 7.2 FEASIBILITY OFACHIEVING BACKGROUND 40 8.0 CONTAMINANT SOURCE REMOVAL 42 8.1 PCB SOURCEREMOVAL 42 8.2 DIOXIN SOURCE REMOVAL 43

.8.3 PETROLEUM SOURCE REMOVAL 43 ERM ii YANKEE/002805"/17/05

8.4 LEAD SOURCE REMOVAL 44 9.0 CONCEPTUAL DESIGN 45 9.1 OVERVIEW 45 9.2 REQUIRED PERMITS/APPROVALS 45 9.3 DESIGN AND CONSTRUCTION 47 9.4 MANAGEMENT OF REMEDIAL WASTE 48 9.4.1 Soil Storage Areas 48 9.4.2 Characterizationfor Disposal 49 9.4.3 Transportationand Disposal 49 9.4.4 On-Site Thermal Desorption 50 9.5 CLEANING AND DECONTAMINATION OF EQUIPMENTAND SAMPLING EQUIPMENT 51 9.6 SITE RESTORATION 52 9.7 OPERATION PARAMETERS 52 9.7.1 Verification Samplingfor Area 1 through Area 4 52 9.7.2 Verification Samplingfor Area 5 and SCFA 53 9.7.3 Verification Samplingfor Area 6 - Former Shooting Range 54 9.8 IMPLEMENTATION PROGRAM 55 9.8.1 Site and Environmental Impacts 55 9.8.2 Inspections and Monitoring 56 9.8.3 Healthand Safety 56 9.8.4 PropertyAccess 56 9.8.5 Public Notification Activities 57 9.9 IMPLEMENTATION SCHEDULE 57

10.0 REFERENCES

58 ERM ii YANKEE/0028054-6/17/05

LIST OF TABLES Table 1 Summary of Areas & Volumes Targetedfor Remediation Table 2 Summary of Remedial Technology Screening Table 3 Cost Estimatefor Alternative #1 - Excavation and Off-Site Disposalof Soil Table 4 Cost Estimatefor Alternative #2 - Excavation, On-Site Thermal Treatment & On-Site Reuse, and Off-Site Disposal of Soil Table 5 Cost Estimatefor Alternative #1 - Excavation and Off-Site Disposalof Lead Table 6 Cost Estimatefor Alternative #2 - Excavation, On-Site Stabilization/Solidificationand On-Site Reuse of Soil Table 7 ComparativeAnalysis of Remedial Alternatives - PCBs, Dioxin, PAHs Table 8 ComparativeAnalysis of Remedial Alternatives - Lead Table 9 Verification Sampling Summary - SCFA ERM iv YANKEE/0028054-6/17/05

LIST OF FIGURES Figure 1 Locus Map Figure2 Site Layout Figure3 Soil Sample Locations (Non-IndustrialArea) and OHM Results Exceeding MCP Reportable Concentrations Figure4 Soil Sample Locations (Industrialand Non-Industrial Areas)-and OHM Results ExceedingMCP Reportable Concentrations Figure5 Target Remedial Areas Figure6 Remediation StagingAreas Figure 7 Verification Sampling Grid Figure8 Verification Sampling Locations - Lead Impacted Area Figure9 PCB Remedial Area Map - SCFA Area Figure10 Area A- Cross Section and Verification Sampling Grid Figure11 Area B- Cross Section and Verification Sampling Grid Figure 12 Area C- Cross Section and Verification Sampling Grid Figure13 Area A, Area B, Area C Verification Sampling Grid Floorof Excavation ERM V YANKEE/0028054-/17/05

LIST OFAPPENDICES Appendix A BWSC TransmittalForm (BWSC-108)

Appendix B Public NotificationDocumentation Appendix C List of SupportingCharacterizationDocumentation Appendix D Indirect Thermal DesorptionSystem Information Appendix E YNPS ProcedureDP-8120Collection of Site Characterizationand Site Release Samples Appendix F CianbroHealth & Safety Plan ERMv vi YANKEEOO2805"4-6/17/05

LIST OF ACRONYMNS ABC Asphalt, Brick, and Concrete ALARA As Low As Reasonably Achievable AMDA Alternate Method of Disposal Approval ANRAD Abbreviated Notice of Resource Area Delineation AOC Area of Concern AOR Abnormal Occurrence Report AREOR Annual Radiological Environmental Operating Report ASTs Aboveground Storage Tanks AUL Activity and Use Limitation BUD Beneficial Use Determination CAD Corrective Action Design CFR Code of Federal Regulations CMR Code of Massachusetts Regulations COC Contaminant of Concern CR Condition Report CSA Comprehensive Site Assessment DCE 1,1-dichloroethene DCGL Derived Concentration Guideline Level DEHP bis(2-ethylhexyl)phthalate DOD Department of Defense DOE Department of Energy DPH Department of Public Health Dpm Disintegration per minute DRO Diesel Range Organics ECFA East Construction Fill Area EDCR Engineering Design Change Request EENF Expanded Environmental Notification Form EPA Environmental Protection Agency EPH Extractable Petroleum Hydrocarbon ERAMS Environmental Radiation Ambient Monitoring System ERM Environmental Resources Management FANP Framatome-ANP Laboratory FID Flame Ionization Detector FSS Final Status Survey GRO Gasoline Range Organics GTCC Greater Than Class C HPGe High Purity Germanium HSA Historical Site Assessment ISFSI Independent Spent Fuel Storage Installation IX Ion Exchange LER Licensee Event Report, LPST Low Pressure Surge Tank LSP Licensed Site Professional ERM vii YANKEE/0028054-6/17/05

LTP License Termination Plan MADEP Massachusetts Department of Environmental Protection MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual mCi/mi millicurrie per milliliter MCL Maximum Contaminant Level MCP Massachusetts Contingency Plan MDC Minimum Detected Concentration mg/kg Milligrams per kilogram (approximately equivalent to parts per million or ppm) mR/hr Millirad per hour mrad/hr Millirad per hour mrem/yr Millirems per year N&SDR North & South Decon Room NAAQS National Ambient Air Quality Standards NIST MAP National Institute of Standards and Technology Measurement Assurance Program NRC Nuclear Regulatory Commission NST Neutron Shield Tank OHM Oil and Hazardous Materials PAB Primary Auxiliary Building PAHs Polycyclic Aromatic Hydrocarbons PCA Potentially Contaminated Area PCBs Polychlorinated Biphenyls pCi/L picocuries per liter pCi/g picocuries per gram pg/g picograms per gram PIR, Plant Incident Report ppm Parts per million PVC Polyvinyl Chloride QAPP Quality Assurance Project. Plan QA/QC Quality Assurance/Quality Control RAM Release Abatement Measure RAO Release Abatement Outcome RBDAA Risk-Based Disposal Approval Application RCS Reportable Concentrations RCA Radiologically Controlled Area REMP Radiological Environmental Monitoring Program RETS Radiological.Environmental Technical Specifications RIR Radiological Incident Reports ROR Radiological Occurrence Report RSCS Radiation Safety Control Services SC-FA Southeast Construction Fill Area SCPP Site Closure Project Plan SFP Spent FuelPool SI/DG Safety Injection/ Diesel Generator YANKEE/0028054-6/17/05 viii Viii ERM YANKEE/0028054-6/17/05

SSCs Systems, Structures. & Components SVOC Semi-Volatile Organic Compound TCA 1,1,1-trichloroethane TEQ Total Equivalent Quantity TPH Total Petroleum Hydrocarbon ug/kg micrograms per kilogram USTs Underground Storage Tanks VC Vapor Container.

VOC Volatile Organic Compounds VPH Volatile Petroleum Hydrocarbon YAEC Yankee Atomic Electric -Company YNPS Yankee Nuclear Power Station ERM ix YANKEE/0028054-6/17/05

1.1 BACKGROUND

On behalf of Yankee Atomic Electric Company (YAEC), Environmental Resources Management (ERM) has prepared this Amended Phase III Remedial Action Plan (Phase Ill) and Phase IV Remedy Implementation Plan (Phase IV) for the Yankee Nuclear Power Station (YNPS) located at 49 Yankee Road in Rowe, Massachusetts (the "site") (Figure 1). This submittal has been prepared in accordance with the requirements of the Massachusetts Contingency Plan (MCP) 310 Code of Massachusetts Regulations (CMR) 40.0000 in response to the discovery of releases of oil and/or hazardous materials (OHM) to the environment. The Bureau of Waste Site Cleanup (BWSC) Comprehensive Response Action Transmittal Form (BWSC-108) is included in Appendix A and public notification documentation is included in Appendix B.

YNPS is in the process of being decommissioned in accordance with the U.S. Nuclear Regulatory Commission regulations. Demolition activities were initiated at the site in August 2003 and the majority of structures at the site have been demolished to grade. YAEC is in the process of demolishing the last of the site buildings, including the Primary Auxiliary Building, the New Fuel Vault, the Spent Fuel Pool, and the Reactor Support Structure.

Since the initiation of plant decommissioning activities in 1992, YAEC has conducted numerous environmental sampling programs to support the decommissionig effort. These investigations have included sampling of building surfaces and materials, asphalt, concrete, soil, soil gas, groundwater, stormwater systems, surface water, sediments and fish.

Samples have been analyzed for both radiological and non-radiological parameters. The environmental samngpling programs have resulted in the notification to the Massachusetts Department of Environmental Protection (MADEP) of OHM releases.

As a result of the notifications to MADEP, the following major MCP submittals have been made:

IRA Completion Report, February 2001 ERM 1 YANKEE/0028054-6/17/05

0 Release Abatement Measure (RAM) Plan, March 2001

• RAM Plan Amendment, June 2001

• RAM Plan Amendment, December 2004

• RAM Plan Amendment, February 2005

• Phase I Initial Site Investigation Report, April 2001 0 Phase II Comprehensive Site Assessment Report, April 2003

• Phase 11 Comprehensive Site Assessment Report, January 2005 (update of April 2003 Phase II)

• Phase III Remedial Action Plan Report, April 2003

• Phase IV Remedy Implementation Plan, April 2004 Detailed supporting characterization documentation is provided in the documents listed above and in Appendix C (available at Greenfield Community College Library and at www.yankee.com).

1.2 PURPOSE & SCOPE The purpose of the amended Phase III/IV Report is to update the remedial action and implementation plans for the site based on the most current site data generated during continuing decommissioning activities.

This amended Phase II/LV Report specifically addresses reported non-radiological releases identified in soil discovered since completion of the Phase III/Phase IV for the Site.

This amended Phase III utilizes site soil data collected since completion and submittal. of the Site Phase III/IV Reports to the MADEP and expanded evaluation of remedial action alternatives to support selection of the "preferred" remedial action alternative for the new Site release conditions. Phase IV includes information, plans, and reports related to the design, construction, and implementation of the additional remedial' action alternatives.

The amended Phase III /IV also addresses the management of PCB-impacted soils on site through a description of identified concentrations, and proposed remedial actions. Yankee, until this point, has managed PCBs in soils through a Release Abatement Measure (RAM)Plan issued by the Department in March of 2001. Semi-annual reports have been ERM 2 YANKEE/00280554-6/17/05

issued that have documented the management of PCBs in soils. The RAM will be completed and future remedial activities will be conducted in accordance with this Amended Phase III/IV Plan for the remainder of site decommissioning.

This amended Phase III/ IV does not address remedial actions that may be necessary for releases of plant-related radionuclides to the environment, as these actions are deemed adequately regulated by the Nuclear Regulatory. Commission (NRC) and the Massachusetts Department of Public Health (MA DPH). In addition, this amended Phase III/ Phase IV does. not address ongoing remedial actions for sediment initiated in the fall/winter of 2004, or negligible non-radiological impacts to groundwater undergoing further assessment and monitoring concurrent with groundwater monitoring for radionuclides.

1.3. REPORT ORGANIZATION The remainder of this report is organized to satisfy .the requirements of the MCP (310 CMR 40.0850 and 40.0874) and contains the following sections:

• Section 2.0 - Summary of the PhaseII Comprehensive Site Assessment, includes'a summary of the updated Phase 1I Report filed in January 2005 and results of recent Site investigation efforts.

• Section 3.0 -Remedial Action Objectives, includes the identification of regulatory requirements governing cleanup and justification for selection of target remedial action objectives for areas of OHM impacted media (i.e., soil) requiring remediation to achieve remedial action objectives.

• Section 4.0 - Identification and InitialScreening of Remedial Technologies, remedial technologies reasonably likely to achieve remedial action objectives were updated to form the basis~for development of updated remedial alternatives for detailed evaluation.

• Section 5.0 ,Detailed Evaluation of Alternatives, evaluation of the degree to which updated remedial alternatives meet MCP evaluation criteria including; effectiveness, short-term and long-terr reliability, technical difficulty, cost, risk, benefit, timeliness and aesthetic value.

• Section 6.0 -Comparative Evaluationof Alternatives,comparison between updated remedial alternatives based on detailed evaluation ERM 3 YANKEE/0028054-6/17/05

criteria.

• Section 7.0 - Recommended Remedial Alternatives, includes the rationale for, and selection of, the preferred remedial action alternative(s) and a schedule for implementation under a Phase IV Remedy Implementation Plan.

• Section 8.0 - ContaminantSource Removal, includes the identification of target cleanup levels and areas of OHM impacted soil requiring abatement to achieve remedial goals.

• Section 9.0 - Conceptual Design - includes the description of remedial activities; schematic construction plans and specifications; closure sampling; operation, maintenance and/or monitoring plans, as appropriate; health and safety plan; list of necessary permits; and, property access issues pertaining to soil remediation.

" Section 10.0 - References 1.4 RELEVANT CONTACTS The following table provides contact information for site owners and those persons who will operate and/or maintain the selected remedial action alternative(s) during and following construction.

Name Role Contact Information Yankee Nuclear Power Station Kenneth Dow Environmental Manager 49 Yankee Road Yankee Property'Owner Rowe, MA 01367 413-424-2245

~TransCanada Maryalice Fischer Environmental Manager TransCanada Pro'perty Owner 4 Park Street, Suite 402 Concord, NH 03301 603- 225-5528 LSP-of Record ERM John McTigue, P.G., LSP 399 Boylston St., 6th Floor Boston, MA 02116 617-646-7800 ERM 4 YANKEE/002905"/17/05

2.0

SUMMARY

OF PHASE H COMPREHENSIVE SITE ASSESSMENT 2.1 SITE ASSESSMENT INFORMATION

SUMMARY

This summary of site assessment information is compiled from Phase II Reports (April 2003, January 2005), Proposed Remedial Cleanup Plan (April 2005), and Notification and Certification of Self-Implementing Cleanup and Disposal of PCB Remediation Waste (April 2005) submitted to MADEP and United States Environmental Protection Agency (USEPA).

Much of the information presented in this section was gathered as part of plant decommissioning, after submittal of the original Phase-III and Phase IV Reports.

Comprehensive site assessment activities included a series of field investigations to assess the source, nature, and extent of impact from the release of PCB-containing paint chips to the environment and other potential non-radiological sources of OHM release to the environment.

Field activities included sampling building surfaces and materials, asphalt, concrete, soil, soil gas, groundwater, stormwater systems, surface water, sedimentsand fish. The results were utilized to define the nature and extent of OHM in affected media.

The site assessment results will be summarized by area. The developed portion of the site, displayed in Figure 2, will be discussed as three distinct areas based on past site activities and land use:

The Industrial Area is the approximately 13-acre fenced portion of the site surrounding the Radiologically Controlled Area (RCA) containing industrial plant structures and operations (approximately 17 acres including the RCA).

• The RCA is the approximately 4-acre parcel within the Industrial Area containing radiological materials associated with plant operation.

1 Non-Industrial Area is 'that portion of the site outside of the fenced The Industrial Area containing offices, roadways, fill areas, and undeveloped woodland and encompasses approximately 1,783 acres.

Major structures and features loýated within these areas are listed below:

ERM 5 YANKEE/0028054-6/17/05

Summary of YNPS Areas and Structures Area Description Structures Located Within Area Demineralized Water Tank Area Firewater Storage Tank/Pump House Former Diesel Generator Building Former Waste Incinerators Fuel Storage Building Former Fuel Oil Tank Independent Spent Fuel Storage Installation (ISFSI) Potentially Contaminated Area (PCA)

Warehouses (new and old)

Primary Auxiliary Building (PAB)

Radiological Waste Warehouse Temporary Waste Evap.

Waste Disposal Building Vapor Container (VC)

Industrial Area outside Screenwell House (Circulating Water Intake of the.RCA Structure)

Former Railroad Tracks Garage Security/Gatehouse North Warehouse Office Buildings Old Shooting Range Potable water supply wells* (current and former)

Propane Storage Security Diesel Building Service Building Turbine Building/Control Room Transformer Yard Non- Areas outside fenced Asphalt, brick and concrete (ABC) Rubble Industrial operational area Disposal Area Area Active and Inactive Leach Fields Administrative Building and office trailers Circulating Water Discharge Structure East and West Storm Drain Outfails East Construction Fill Area (ECFA)

Fire Fighter Training Area New Shooting Range Parkingareas.

Sand/Salt Shed Septic System Pump House Southeast Construction Fill Area (SCFA)

Storage Yard Trash Compactor Visitor's Center ERM 6 YANKEE/0028054-6/17/05

In the Industrial Area, a total of 806 soil samples were collected. A total of 673 soil samples were collected from the Non-Industrial Areas of the YNPS. Confirmed OHM present above RCS-1 are listed below:

SUMMARY

OF OHM Compound Area IndustrialArea EPH (C11 - C22 Aromatics) Pavement area south of ISFSI Dioxin Former incinerator area Hillside area west of Access Road PCBs Multiple locations*

PAHs (benzo(a)anthracene, benzo(a)pyrene Roadway northwest of VC and benzo(b)fluoranthene)

PAHs (benzo(a)anthracene, and Former fuel oil AST benzo(a)pyrene)

Non-IndustrialArea TPH Visitor Center Parking Lot PAHs - (benzo(a)anthracene, benzo(a)pyrene, Railroad track area near northeast benzo(b)fluoranthene benzo(k)fluoranthene, corner of fence line, south of chrysene, dibenz(a,h)anthracene, ideno(1,2,3- Reservoir cd)pyrene)

PAHs (benzo(a)anthracene, benzo(a)pyrene, Septic system leach field and benzo(b)fluoranthene)

PAIis (benzo(a)anthracene and SCFA benzo(a)pyrene Lead Shooting Ranges PCBs Multiple locations* including the SCFA

• Addresssed in April2003 Phase Iii, April 2004 Phase IV and January 2005 Phase II AST Aboveground Storage Tank EPH, Extractable Petroleum Hydrocarbon ISFSI Independent Spent Fuel Storage Installation PAI4s Polycyclic Aromatic Hydrocarbons PCBS Polychlorinated Biphenyls SCFA Southeast Construction Fill Area VC 'Vapor Container TPH Total Petroleum Hydrocarbons ERM 7 YANKEE/0028054-6/17/05

Figures 3 and 4 present the locations where OHM were detected in soil above applicable Reportable Concentrations.

Based on the results of recent investigations, soils requiring remediation are present within and adjacent to the operational footprint of the plant in most of the areas listed above. Of those areas identified above, investigation is continuing in the following areas, and if results confirm impacts at levels consistent with previous results, it is anticipated that the low levels of impact detected in these areas would not pose a significant risk, and therefore no remediation is currently planned.

• Hillside area west of Access Road (Dioxin only)

• Pavement area south of ISFSI

• Roadway northwest of VC

• Visitor Center Parking Lot

• Septic system leachfield

" Railroad track area If additional investigation reveals that remedial actions for soil are necessary in the above, or other unidentified areas, it will be completed in accordance with the amended Phase IV implementation plans provided in

,this report. To account for uncertainties in the volume of soil requiring abatement, a substantial contingency was added to the expected volume of soil to account for additional soil remediation that may be necessary in these areas.

Known and potential sources of OHM release have been abated and will be eliminated during the final phase of plant decommissioning.

Therefore, this amended Phase III/Phase IV focuses on the identification of remedial technologies and alternatives most likely to achieve a Permanent Solution for non-radiological impacts to soil, including, PCB-containing paint chips, dioxin, petroleum hydrocarbons/ PAHs, and lead.

A comprehensive risk characterization will be prepared following completion of remedial actions at the site to document that residual radioactivity and/or OHM remaining at the site following closure meet applicable risk management criteria for protection of human health, safety, public welfare, and the environment.

EIZM 8 ERM 8YANKEE/0028054-6/17/

3.0 REMEDIAL ACTION OBJECTIVES 3.1 OVERVIEW The purpose of this section is to establish objectives for remediation of contaminant impacts to soil that will enable achievement of a Permanent Solution, if feasible. Remedial action objectives are expressed as media-specific target goals for contaminants in soil that if achieved, would restore the site to a condition of No Significant Risk, meet MCP performance standards for the filing of a Response Action Outcome (RAO) Statement, and represent a Permanent Solution for the site. Key MCP Response Action Performance Standards (RAPS) that must be met in order to achieve a Permanent Solution include:

Elimination or control of each source of OHM which is resulting, or is likely to result, in an increase in concentrations of OHM in an environmental medium, either as a consequence of a direct discharge or through inter-media transfer (per 310 CMR 40.1003).

" Reduction in the concentration of OHM in affected media to levels that do not pose a condition of Significant Risk of harm to human health, safety, public welfare, and the environment (per 310 CMR 40.1003).

• Reduction in the concentration of OHM in affected media to levels that would exist in the absence of the site. Such measures shall, to the extent feasible, achieve or approach background levels of OHM in the environment as defined under 310 CMR 40.0006 (per 310 CMR 40.1020); ý Reduction in the overall mass and volume of OHM at the site to the extent feasible, regardless of whether it is feasible to achieve one or more Temporary or Permanent Solutions, or whether it is feasible to achieve background for the entire site (per 310 CMR 40.01.91).

In addition to meeting the MCP performance standards, the development of the remedial action objectives also considered the need for compliance with the Toxic SUbstance Control Act (TSCA). The .SCA regulations govern the remediation and management of PCB remediation waste (PCB-impacted soil). Other local,. state, and federal regulatory requirements applicable to the development of remedial action objectiyes and achievement of RAPS are discussed where appropriate.

ERM 9 ERM 9YANKEE/0028054-6/17

3.2 REMEDIAL ACTION OBJECTIVES 3.2.1 PCBs Under the MCP, YAEC has proposed achievement of a target cleanup goal for PCBs in soil of one (1) milligram per kilogram (mg/kg), which is approximately equivalent to one part per million (ppm). YAEC proposes to achieve this goal as an arithmetic average concentration remaining in soil within five potential exposure areas.

Under TSCA (CFR 761.61(a)), YAEC proposes to meet the cleanup standard for bulk PCB remediation waste for areas that are of "low occupancy" of less than or equal to 25 ppm. The low occupancy standard was selected as the most appropriate standard under TSCA since: 1) it will allow for achievement one ppm as an arithmetic average consistent with the MCP; 2) it is consistent with the nature of the release as a solid in paint and impacted soil as a bulk remediation waste; and 3) it is consistent with the projected future use of the site. Areas of residual PCB impact in soil greater than 1 ppm, will be covered with clean fill, to provide a physical barrier to incidental exposure. Future use of the site will be controlled by deed restrictions or an Activity and Use Limitation (AUL), prohibiting activities or uses that could result in adverse exposure to residual PCBs in the subsurface.

3.2.2 Dioxin YAEC will use a target cleanup goal for dioxin Total Equivalent Quantity (TEQ) in soil of 4 pg/g (picograms per gram), the current S-1/GW-1 MCP Method I standard for the area of the historic waste incinerator within the Industrial Area of the site.

3.2.3 PetroleumHydrocarbons YAEC will use the S-1/GW-1 Method I standards as the target cleanup goal for the PAHs. These are listed below for the contaminants of concern:

• benzo(a)anthracene 0.7 ppm

• benzo(a)pyrene 0.7 ppm

• benzo(b)fluoranthene 7 ppm

• benzo(k)fluoranthene 7 ppm M.. 10YAKE,..'4-/170 ERM 10 YANKEE/0028054-6/17/05

• chrysene 7 ppm

• dibenz(a,h)anthracene 0.7 ppm

" ideno(1,2,3-cd)pyrene 0.7 ppm YAEC will also use the S-1/GW-1 Method I standard as the target cleanup goal for the EPH (Cl1 - C22 Aromatics), 200 ppm.

3.2.4 Lead YAEC will use the S-1/GW-1 Method 1 standard of 300 ppm as the target cleanup goal for lead.

3.3

SUMMARY

OF REMEDIAL AREAS 3.3.1 PCBs There are several areas of the site where PCBs in soil are present above the remedial action objective. The site has been separated into exposure labeled Areas 1-5 with targeted remedial areas within each of the five exposure areas listed in Table I and shown in Figure 5. The volume of PCB-impacted soil targeted for remedial action by area and sub-area are estimated and shown in Table 1.

To determine the extent of cleanup that would be appropriate in each exposure area, YAEC considered the following criteria:

Removal of soils at locations necessary to meet regulatory cleanup goals for PCBs (an average of 1 ppm (MCP) and maximum of 25 ppm (TSCA)).

Removal at locations where site observations and interim soil management practices warrant remedial action to abate observed PCB-containing paint chips in soil (e.g., crane pads, former waste management areas, trenches adjacent to buildings containing visible paint chips, etc.).

Removal at locations for the presence of contaminants other than PCBs (e.g., dioxin, petroleum, or radioactivity), but where PCBs coincide and will be removed.

ERM ERM 11 11 YANKEE/0028054-6/17/05 YANKEE/0028054.-6/17/05

The total volume of soil to be remediated for PCBs is estimated to range between 8,000 to 18,000 cubic yards (CY). The large contingency reflects the high degree of uncertainty in lateral and vertical extent of removal necessary, as well as the added volume that could result from continuing investigations described in Section 2.1.

3.3.2 Dioxin Dioxins have been detected in shallow soil samples collected below pavement in the central portion of the site, Area 3, as shown in Figure 5.

This is an area that is also impacted by PCBs. The area to be remediated was estimated and is listed in Table I as Area 3.1.

3.3.3 Petroleum Hydrocarbons Petroleum hydrocarbons were observed in soil within the berm of the former No. 2 AST. The former AST was dismantled during December 2000 and the associated fuel lines were drained and purged and are no longer in use. Future activities planned as part of plant decommissioning include removal of the inactive fuel lines located between the former AST, a fuel transfer building, and the Auxiliary Boiler Room area that was part of the Turbine Building complex., The estimated area/volume of petroleum-impacted soil is unknown, but will be determined during excavation for removal of the tank pad and the'fuel lines. The area occupied by these structures is approximately 50 feet long, 25 feet wide and four feet deep, as shown in Table 1. Soil impacted by petroleum is assumed to be impacted by PCBs within Area 1.8 as shown in Figure 5.

3.3.4 Lead Lead has been detected in soil at the Old Shooting Range (see Figure 2). A Limited Removal Action (LRA) was conducted at the Old Shooting Range in 1997. At that time, closure samplig indicating that remaining lead levels were below MCP Reportable Concentrations. However, lead was detected above Reportable Concentrations in an area adjacent to the Old Shooting Range during the site closure sampling. YAEC is currently evaluating the data to determine the need for additional delineation sampling and/or remedial activities. The area of impact is estimated to extend 15 feet by 15 feet to a depth of one foot and two underlying 3 by 3 foot areas to a depth of 3 feet The volume of soil requirng removal is estimated at 10 CY. This area is listed in Table 1 and shown in Figure 5.

ERM 12 12 YANKEE/0028054.6/17/05 YANKEE/002805"/17/05

4.0 IDENTIFICATION AND INITIAL SCREENING OF REMEDIAL TECHNOLOGIES 4.1 OVERVIEW This section identifies remedial technologies to be evaluated based on their potential to achieve remedial goals for site soil. Technologies are screened using the specific criteria outlined in the following section. In accordance with 310 CMR 40.0856, a summary of the screening process for the remedial technologies is provided in Table 2.

Although radioactivity is excluded from the consideration of remedial alternatives it is important to recognize that OHM in soil are co-located with. plant related radioactivity in soil. Radiological characterization is ongoing in support of site closure and as part of site remedial actions for OHM. In the event that soils are to be transported off-site for treatment and/or disposal, a determination will be made if the materials must be transported to a facility specifically permitted for radiological waste. Off-site disposal is the only technology that would achieve an immediate reduction in the levels of residual radioactivity remaining at the site. For the purposes of the detailed evaluation, it was assumed that the radiological impacts to soil do not drive remedial action, since if this is the case, the only available alternative to achieve a reduction in the levels of residual radioactivity in soil is off-site disposal.

4.2 IDENTIFICATION OF REMEDIAL TECHNOLOGIES 4.2.1 PCBs, Dioxin and Petroleum Hydrocarbons The.2003 Phase III Report provided a comprehensive identification and description of remedial technologies applicable to PCBs in soil.

Additional OHM that are included in this amended Phase III Report are:

dioxin, petroleum hydrocarbons, and lead. Typical remedial technologies to address dioxin, PCBs, and petroleum hydrocarbons in shallow soils are similar,. Therefore, the remedial technologies previously identified remain applicable with the additional OHM (dioxin and petroleum ER 13 YANKEE/0028054-6/17/05

hydrocarbons) and additional volumes of soil. Remedial technologies for lead are discussed in Section 4.2.2.

As presented in the 2003 Phase II Report, remedial treatment

• technologies to address the presence of PCBs in the environment may be grouped into five general categories:

• Containment of impacted soil as a means of reducing the potential risk by reducing/eliminating the potential for exposure;

• In-Situ (in place) treatment of impacted soil to physically and/or chemically stabilize or neutralize the contaminants; separate and/or concentrate the contaminants; or destroy the contaminants;

• Removal of soil in combination with other technologies;

• Ex-Situ treatment of impacted soil; or

• Off-site disposal of impacted soil.

These categories are also applicable to dioxin and petroleum hydrocarbons. Each of these general remediation categories is discussed in detail in the 2003 Phase III Report (Section 4.2).

A summary of remedial technologies potentially applicable to the abatement of soil by PCB-containing paint chips, dioxin and petroleum hydrocarbons at the site is provided below. A description of the technologies and an evaluation of their potential to meet the stated screening criteria (i.e. effectiveness and implementability) are included in Section 4.3.

Summary of PotentialRemedial Technologies Off-Site Containment In-Situ Treatment Removal Ex-Situ Treatment Disposal Engineered Monitored Natural Excavation Thermal Desorption Disposal Barrier/Cap, Recovery incineration

• Solidification/

St*bilization Solvent Extraction

-soil Washht . ...

Bioremediation SiWshn Phytoremediation Solidification/ Stabilization Chemical Bioremediation Treatment Chemical Treatment ERM 14 .Y AN KEE/ 0028054-6 /17 /05

4.2.2 Lead Remedial treatment technologies to address the presence of lead in soil may be grouped into four general categories:

• Containment of impacted soil as a means of reducing the potential risk by reducing/eliminating the potential for exposure;

• In-Situ (in place) or Ex-Situ treatment to physically and/or chemically stabilize or neutralize the lead;

• Removal of soil in combination with other technologies; or

• Off-site disposal of impacted soil.

Containment Containment is the controlled isolation of impacted media by placement of isolating materials over the area of impact. Containment may be used to isolate materials in place or isolate materials once they are removed from the ground. Containment can isolate the lead from the environment and potential receptors using natural and/or man-made products that are typically layered. Containment'technologies may be implemented in various ways. Containment alternatives for soil include an aboveground engineered barrier or cap.

Ex-Situ On-Site/Off-Site Treatment Reasonably feasible treatment technologies that could be implemented on-or off-Site for abatementof lead in soil include:

Stabilization/ Solidification: an ex-situ process that immobilizes lead impacted soil into building materials or structural fill. The stabilized/solidified mixture would immobilize the lead. This treatment technology is potentially effective in achieving a Permanent or Temporary Solution, is implementable, and is therefore carried forward.

Soil Washing: an ex-situ process that reduces the volume of contaminated material by physical and chemical separationmethods to remove metals. The smaller volume of residual waste would require additional treatment and/or disposal. This treatmient technology is potentially effective in achieving a Permanent or Temporary Solution, is implemeniable, and is therefore, carried forward.

Phytoremediation: an in situ treatment process that utilizes plants to ERM 15 YANKEE/0028054-6/17/05

extract, degrade or volatilize OHM such as lead. It requires off-site disposal of the biomass created.

Removal by Excavation Removal by excavation is a common technology used to remediate soil.

Excavation would require on- or off-site treatment and disposal of remediation wastes generated.

Removal by excavation would enable achievement of a Permanent Solution and is therefore an effective technology. Excavation is implementable, since site physical conditions are adequate to enable excavation and the equipment and persons are-available. Therefore, excavation is carried forward as a technology suitable for development of remedial alternatives and detailed analysis.

Off-Site Disposal of Soil Soil could be transported to a permitted disposal facility. Off-Site-disposal would be effective in achieving a Permanent Solution and is commonly implemented. Therefore, off-Site disposal is retained as an effective and implementable technology.

Summary of PotentialRemedial Technologies A summary of remedial technologies potentially applicable to the abatement of soil impacted by lead at the site is provided below. A description of the technologies and an evaluation of their potential to meet the stated screening criteria (i.e. effectiveness and implementability) are included in Section 4.3.

ERM 16 YANKEE/0028054-6/17/05

Summary of PotentialRemedial Technologies Off-Site Containment In-Situ Treatment Removal Ex-Situ Treatment Disposal Engineered Solidification/ Excavation Soil Washing Disposal Barrier/Cap Stabilization Solidification/

Phytoremediation Stabilization 4.3 TECHNOLOGY SCREENING The screening process is intended to identify those remedial technologies that maintain the potential to reduce OHM concentrations in soil to target remedial action objectives. The screening includes an evaluation of each potential remedial technology to meet the following criteria:

Effectiveness - the ability of the technology to support achievement of a Permanent or Temporary Solution; i.e., meeting remedial action objectives.

• Implementability - the availability of personnel to implement the technology.

4.3.1 PCBs,Dioxin and Petroleum Hydrocarbons Containment Containment-of soil may be an effective technology to achieve a Temporary or Permanent Solution. Resources are available to implement the technology. Use of containment technologies would require that institutional controls be put in place because the concentration of OHM in the environment would not be changed. However, containment technologies are not consistent with YAEC's goals of reducing the levels of OHM remaining in the environment to the extent feasible. Therefore, containment technologies were eliminated from further consideration.

Monitored Natural Recovery Monitored Natural Recovery is non-invasive and requires no construction activities. Long-term monitoring and use limitations are typically part of this type of remedy. There is some uncertainty with the success of this ERM 17 YANKEE/0028054-6/17/05

remedial approach and it can be a relatively slow process due to the persistence of PCBs in the environment. The dioxin and petroleum in some locations are expected to be co-located with the PCBs. This remedy is typically used when other alternatives are impracticable. There is little data to suggest that this remedial approach is capable of achieving the remedial objective in a reasonable time frame since PCBs and dioxin are quite persistent in the environment and do not degrade readily under natural degradation processes. Therefore, monitored natural recovery was not considered to be an effective technology for the site and was eliminated from further consideration.

In-Situ Solidification/Stabilization Solidification and stabilization involve the addition of a binder (e.g.

cement, cement kiln dust, fly ash) to soil to convert OHM into a less soluble, less mobile and less toxic form. The technology is intended to prevent or slow the release of harmful contaminants from soil or sediment. In-situ solidification/stabilization technologies were eliminated from further consideration due to the location of impacted soils near the ground surface (less than four feet in depth), lack of data on effectiveness to bind PCBs adequately and the desire for the property owner to have unrestricted future use of the property. This treatment technology would not be effective in achieving a Permanent Solution atthe site.

In-Situ Bioremediation In-situ bioremediation is used to speed up the natural restoration of soil.

The concentration of the contaminant must be sufficiently high to serve as substrate. Bioremediation is generally not as effective with low contaminant concentrations. Biological treatment was eliminated from further consideration, due tooits unproven ability to degrade the OHM at this Site, particularly PCBs, to low levels and ultimately to achieve a Permanent Solution.

ERM

.ERM 18 18 YANKEE/0028054-6/17/05 YANKtE/0028055 "/17/05

Phytoremediation This treatment process utilizes plants to extract, degrade, or volatilize contaminants water-soluble compounds such as petroleum; however, it has not been proven successful in the remediation of PCBs in soil.

Therefore, it was eliminated from further consideration.

Tn-Situ Chemical Treatment Chemical treatment is a process in which chemical reagents are added to soil for the purposes of contaminant destruction. Contaminants may be destroyed completely or may be made more stable, less toxic, less mobile, or inert. Some chemical treatment methods include chelation, dechlorination/dehalogenation, and oxidation/ reduction. Chemical treatment of soil in-situ is quite difficult to implement due to the need to isolate the areas being treated during implementation. It is not a proven technology capable of reducing PCB concentrations to less than 1 mg/kg.

Chemical treatment technologies were eliminated from further consideration due to their unproven ability to sufficiently reduce PCB concentrations to achieve a Permanent Solution and the lack of proven implementability to the remedial action objective.

Ex-Situ Thermal Treatment A variety of high (e.g., incineration) and low temperature (desorption) thermal treatment technologies are available to treat organic contaminants. These technologies are highly effective in treating a wide variety of organic compounds, including PCBs, dioxin and petroleum.

Thermal desorption physically separates PCBs and other compounds from soil by heating to temperatures high enough to volatilize the organic compounds. Heating may be accomplished by heated screw conveyors, a series of externally heated distillation chambers, indirectly fired rotary kilns, or fluidized beds (USEPA, 1991). Thermal desorption is not as effective a treatment process as incineration, however, it has less energy requirements, less gaseous emissions, and less potential for the formation of toxic emissions. In addition, thermal desorption may not be as effective treating dioxin, particularly at low concentrations, as the other compounds of concern. -Mobile treamtment units are available to use on-site for both thermal desorption and incineration.

Incineration is a destruction technology that treats organic contaminants in soil by subjecting them to high temperatures in'thepresence of oxygen, ERM 19 YANKEE/0028054-6/17/05

which causes volatilization, combustion, and destruction of PCBs. This process typically generates up to six process residual waste streams:

treated media, oversize materials, condensed contaminants and water, emission gas dust, clean off-gas and spent carbon. This technology can achieve a destruction efficiency of 99.99 percent (USEPA, 1994).

Thermal treatment technologies are considered to be an effective and implementable technology for removal of PCBs, dioxin, petroleum hydrocarbons and were retained for further consideration.

Ex-Situ Solvent Extraction Solvent extraction processes are used to separate contaminated soil into three fractions: particulate solids, water, and concentrated organic compounds. Contaminants are dissolved or physically separated from the particulate solids using a solvent that is mixed thoroughly with the contaminated soil. Most extraction processes do not destroy or detoxify contaminants, but they reduce the volume of contaminated material that must be subsequently treated or disposed (USEPA, 1994). Due to the relatively low concentrations of PCBs, on-site solvent extraction is not reasonably implementable and was therefore, eliminated from further consideration.

Ex-Situ Soil Washing Soil washing is a water-based process for "scrubbing" soil to remove contaminants. The process removes contaminants by dissolving them or suspending them in solution or concentrating them into a smaller volume of soil through particle separation or gravity separation. The effectiveness of soil washing PCBs bound to paint chips is unknown. Also, due to the relatively low concentrations of PCBs, on-site soil washing is not reasonably implementable and is therefore, eliminated from further consideration.

Ex-Situ Stabilization/Solidification These technologies will not change the mass of PCBs in the material, therefore following treatment the materia will still require off-site disposal ata facility permitted to accept PCB remediation wastes or placement on-site and use of institutional controls to prevent damage and exposure to the materials.

ERM 20 YANKEE/0028054-6/17/05

Ex-situ solidification/stabilization technologies were eliminated from further consideration due to the lack of data on effectiveness to bind PCBs adequately and the desire that future use of the property is unrestricted.

This treatment technology would not be effectivein achieving a Permanent Solution at the site and is therefore eliminated from consideration.

Ex-Situ Bioremediation Bioremediation is used to speed up the natural restoration of soil. Ex-situ bioremediation can include slurry phase bioremediation, in which the soil is mixed in water to form a slurry. Solid-phase bioremediation uses treatment cells where the soil is tilled with water and nutrients. Solid-phase treatment is one of the most widely used and oldest remedial technologies for treatment of hazardous wastes (USEPA, 1993). Both slurry and solid-phase treatment will have liquid waste streams that require further treatment and/or disposal. The success of biological treatment of PCBs is not as well proven or documented. The concentration of the contaminant must be sufficiently high to serve as substrate. Bioremediation is generally not as effective with low contaminant concentrations. Biological treatment was eliminated from further consideration, due to its unproven ability to degrade OHM, particularly PCBs, to low levels and ultimately to achieve a Permanent Solution.

Ex-Situ Chemical Treatment The alternatives available for the ex-situ treatment of soil are the, same as those described earlier for in-situ applications. Ex-situ chemical treatment typically has higher treatment efficiencies than in-situ treatment due to the ability to completely mix the chemicals with the impacted media.

Nevertheless, chemical treatment technologies were eliminated from further consideration due to their unproven ability to sufficiently reduce PCB concentrations to levels necessary.to achieve a Permanent Solution.

Removal - Excavation Shallow. soils may be removed using conventional excavation equipment (e.g. bulldozers, backhoes). Excavation can be very. effective at reaching desired remedial objectives in a relatively short time period. This remedy does not require institutional controls or post-remediation monitoring to ensure long-term effectiveness but will require post - remediation characterization to ensure that remedial goals are achieved and the ERM 21 ERM 21YANKEE/0028054-6/17/0.5

replacement with fill or treated soil suitable to the surrounding substrate.

Once the soil is removed, it would require on- or off-site treatment or disposal. Excavation is considered to be an effective and implementable technology for removal of OHM-impacted soil and was retained for further consideration.

Off-Site Disposal Off-site disposal facilities are available to accept the OHM-impacted soil.

Off-site disposal would be effective in achieving a Permanent Solution and is commonly implemented. There are facilities available to accept the impacted soil for disposal. Therefore, off-site management, using disposal, (in conjunction with excavation) is retained as an effective and implementable technology that is commonly implemented and would be effective in achieving a Permanent Solution.

PCB waste must be disposed of in accordance with the requirements of 40 CFR 761. These requirements establish disposal options for various PCB materials and wastes. PCBs, dioxin, and petroleum hydrocarbons must also be managed in accordance MCP requirements for remediation waste and local receiving facility requirements, as applicable.

As previously stated, part of facility decommissioning involves radiological characterization of all materials. In -the event that soil is to be transported off-site for treatmentand/or disposal, a determination will be made if the materials must be transported to a facility specifically

,perfriitted for radiological waste. For the purposes of the detailed evaluation, it was assumed that the soil would not be classified as radiological waste.

Summary Based on the technology screening, the following remedial technologies were identified as being effective, implementable and having the potential to reduce PCBs, petroleum hydrocarbon and dioxin concentrations in soil to target remedial action objectives.

. J ERM ERM 22 21 YANKEE/0028054-6/17/05 YANKEE/0028054-6/17/05

Summary of Retained Remedial Technologies Removal Ex-Situ Treatment On-Site Off-Site Disposal Excavation Thermal Desorption Disposal PCB, dioxin, petroleum PCB, petroleum hydrocarbons PCB, dioxin hydrocarbons These remedial technologies were carried forward to support identification, selection, and detailed evaluation of remedial alternatives in the following sections.

4.3.2 Lead Containment Containment of soil may be an effective technology to achieve a Temporary or Permanent Solution. Resources are available to implement the technology. Use of containment technologies would require that institutional controls be put in place :because the concentration of lead in the environment would not be changed. Due to the desire that future use of those portions of property be unrestricted where feasible, containment technologies were eliminated from further consideration.

In-Situ Solidification/Stabilization Solidification and stabilization involve the addition of a binder (e.g.

cement, cement kiln dust, fly ash) to soil to convert lead into a less soluble, less mobile and less toxic form. The technology is intended to prevent or slow the.release of harmful contaminants from soil. In-situ solidification/stabilization technologies were eliminated from further consideration due to the location of impacted soils near the ground surface (less than one foot in depth), lack of data on effectiveness to bind PCBs adequately and the desire for future use of the property to remain unrestricted, where feasible. This treatment technology would not be effective in achieving a Permanent Solution at the site.

ERM

~RM 23 23 YANKEE/002S054-6/17/05 YANKEE/002805"/17/05

Phytoremediation This treatment process utilizes plants to extract, degrade, or volatilize water-soluble contaminants such as lead. The location of the lead- ,

impacted soil poses a potential security issue for in-situ technologies such as phytoremediation. The use of plants in areas of the site adjacent to the ISFSI will not be allowed due to security considerations. Therefore, it was eliminated from further consideration.

Ex-Situ Soil Washing Soil washing is a water-based process for "scrubbing" soil to remove contaminants. The process removes contaminants by dissolving them or suspending them in solution or concentrating them into a smaller volume of soil through particle separation or gravity separation. Due to the relatively low concentration of lead and limited volume of impacted soil, on-site soil washing is not reasonably implementable and is therefore, eliminated from further consideration.

Ex-Situ Stabilization/Solidification These technologies will not change the mass of lead in the soil, therefore, following treatment theomaterial will still require off-site disposal at a facility permitted to accept the remediation wastes or placement on-site.

The stabilized/solidified nixture would immobilize the lead. This treatment technology is potentially effective in achieving a Permanent or Temporary Solution, is implementable, and is therefore carried forward.

Removal - Excavation Shallow soils may be removed using conventional excavation equipment (e.g., bulldozers, backhoes). Excavation can be very effective at reaching desired remedial objectives in a relatively short time period. This remedy does not require institutional controls or post-remediation monitoring to ensure long-term effectiveness but will require post-remediation characterization to ensure that remedial goals are achieved and replacement with fill or treated soil suitable to the surrounding sUbstrate.

Once the soiltis removed, it would require on- or off-site Ateatment orf di posal. Excavation isconsidered to be ant effective and implementable technology for removal of iead-impacted soil and was retained for further consideration.

ERM 24 YANKEE/0028054-6/17/05

Off-Site Disposal Off-site disposal facilities are available to accept the lead-impacted soil.

Off-site disposal would be effective in achieving a Permanent Solution and is commonly implemented. There are facilities available to accept the impacted soil for treatment and/or disposal. Therefore, off-site disposal, (in conjunction with excavation) is retained as an effective and implementable technology that is commonly implemented and would be effective in achieving a Permanent Solution.

As stated earlier, part of facility decommissioning involves radiological characterization of all materials. In the event that soil is to be transported off-site for treatment and/or disposal, a determination will be made if the materials must be transported to a facility specifically permitted for radiological waste. For the purposes of the detailed evaluation, it was assumed that the soil would not be classified as radiological waste.

Summary Based. on the technology screening, the following remedial technologies were identified as being effective, implementable and having the potential to reduce lead concentrations in soil to target remedial action objectives.

Summary of Retained Lead Remedial Technologies Removal Ex-Situ Treatment On-Site Off-Site Disposal Excavation Solidification/Stabilization Disposal These remedial technologies were carried forward to support identification, selection, and detailed evaluation of remedial alternatives in the following sections.

25 YANKEE/0028054-6/17/05 ERM ERM 25 YANKEE/W28054-6/17/05

5.0 DETAILED EVALUATION OF ALTERNATIVES 5.1 OVERVIEW Pursuant to 310 CMR 40.0857, this section includes a detailed evaluation of remedial alternatives identified in the initial screening of remedial technologies presented in the previous section.

Pursuant to 310 CMR 40.0858, the detailed evaluation must consider each of the seven criteria defined in Section 5.3 for each alternative. Each remedial alternative for soil is evaluated relative to these criteria in Section 5.4. A comparative analysis of the alternatives relative to each of the screening criteria is presented, by media, in Section 6.0.

For costing and discussion purposes in this report, off-site disposal is assumed to be the selected off-site disposal approach.

5.2

SUMMARY

OFALTERNATIVES 5.2.1 PCBs, Dioxin and Petroleum Hydrocarbons Based on the initial screening of remedial technologies, the following remedial alternatives were identified as candidates for the remediation of soil and were carried forward for detailed evaluation:

Alternative #1 -Excavation and-Off-Site Disposal (Dioxin, PCBs)

° Alternative #2 - Excavation, On-Site Thermal Treatment and Reuse and Off-Site Disposal of Waste Each of the alternatives chosen for further consideration is outlined in detail below.

Altermative #i- Excavation & Off-Site Disposal o Obtain Permits/Approvals o Excavation of OHM-impacted soil (estimated 16,000 cubic yards) o Off-site transportation and disposal of soil containing OHM (estimate 16,000 cubic yards).

ERM 26 YAN KEE/0028054-6/17/05

o Restore site Alternative #2 - Excavation, On-Site Thermal Treatment and Reuse &

Off-Site Disposal o Obtain Permits/Approvals o Excavation of OHM-impacted soil (estimated 16,000 cubic yards) o On-site thermal treatment for soil containing PCBs (estimated 16,000 cubic yards) o Reuse treated soils on-site o Manage thermal treatment residues off-site o Off-site transportation and disposal of soil containing dioxin (estimated 200 cubic yards) o Restore site 5.2.2 Lead Based on the initial screening of remedial technologies, the following remedial alternatives were identified as candidates for the remediation of soil and were carried forward for detailed evaluation:

• Alternative #1 - Excavation and Off-Site Disposal

• Alternative #2 - Excavation, On-Site Stabilization/Solidification and Reuse Each of the alternatives chosen for further consideration is outlined in detail below.

Alternative #1- Excavation &Off-Site Disposal o Obtain Permits/Approvals o Excavation of lead-impacted soil (estimated 250 cubic yards) o Off-site transportation and disposal of soil o Restore site Alternative #2 - Excavation, On-Site Stabilization/Solidification and Reuse o Obtain Permits/Approvals o Excavation of lead-impacted soil (estimated 250 cubic yards) o On-site stabilization/solidification o Reuse treated soils on-site o Restore site ERM 27 YANKEE/0028054-6/17/05

5.3 SCREENING CRITERIA A detailed evaluation of the alternatives includes a brief description of the site-specific aspects of each alternative. This is followed by an evaluation of each alternative using the following criteria:

Effectiveness This criterion identifies whether the alternative will achieve a Permanent or a Temporary Solution. It also addresses how contaminant concentrations will be reduced and the likelihood that residual concentrations will approach or achieve "background."

Reliability This criterion addresses the likelihood that the alternative will be successful and the effectiveness of any measures required to manage waste streams, if applicable.

Implementability This criterion addresses the technical complexity of the alternative and its compatibility with site constraints. It also addresses whether the remedial alternative has successfully been used at other sites in similar situations.

Cost This criterion addresses the short-term and long-term costs associated with implementing the alternative. The costs presented are intended for use in the comparative analysis in Section 6.0.

Risks This criterion addresses the expected short-term and long-term risk associated with the alternative.

Benefits This criterion addresses the expected benefits associated with the alternative.

Timeliness This criterion compares the timeliness of each alternative in terms of achieving a level of No Significant Risk.

Note: The cost estimates presented in this section are not intended for budgeting or contracting purposes, but were prepared specifically to ERM 28 YANKEE/0028054-6/17/05

support the comparative analysis of the alternatives. Actual costs could vary.

5.4 EVALUATION OF ALTERNATIVES 5.4.1 PCBs, Dioxin, PetroleumHydrocarbons 5.4.1.1 Alternative #1-Excavation & Off-Site Disposal The primary engineering and management components of Alternative #1 include permitting, excavation and segregation, off-site disposal and site restoration. Each of these components is described briefly below:

• Permitting and Approvals - obtain approval from permitting authorities.

• Excavation and Segregation - excavation and segregation of OHM-impacted soil into stockpiles specific to waste characteristics and disposal facility receiving requirements (e.g., as a non-TSCA or TSCA remediation waste).

• Transportation & Disposal - transport materials to licensed treatment and/or disposal-facilities, based on waste characterization and receiving facility- requirements.

Site Restoration - restoration of disturbed areas.

Effectiveness Excavation and off-site disposal of the waste would be very effective at reducing OHM concentrations to levels that achieve a condition of No Significant Risk to human health and the environment and enable achievement of a Permanent Solution. This alternative 'Vould not necessarily destroy or detoxify OHM (i.e., it would-transfer-the material to another location), but would reduce the concentrations of OHM onsite to below the cleanup goals. Use of excavation and off-site disposal may reduce the residual levels of OHM in the environment to background.

Reliability Excavation and off-site disposal is a reliable remedial method that has been used regularly to remediate OHM. Therefore, this alternative carries a high degree of certainty in its ability to meet, target remedial objectives ER 9YNE!OO85!/7O ERM 29 YANKEE/W28054-6/17/05

necessary to achieve a Permanent Solution. No institutional controls would be necessary following remediation.

Implementability Removal by excavation is a common technology used to remediate soil.

The areas targeted for remediation are easily accessible for conventional excavation equipment. Therefore, excavation and off-site disposal is deemed to be implementable.

Cost The cost estimate for the off-site disposal alternative is summarized in Table 3. The estimated cost for this alternative is $12,550,000. Long-term operation and maintenance would not be necessary.

It should be noted that if the radiological characterization indicated that the soil needed to be managed as a radiological waste, then the disposal costs are estimated to increase substantially.

Risks Excavation and.off-site disposal would provide for long-term risk reduction. Effective management of remedial actions and remediation waste would be necessary to ensure protection of human health (use of personal protective equipment) and .the environment (engineering controls) during implementation. The off-site transport of the material poses a slight short-term risk that could be controlled.

Benefits Excavation. and off-sitedisposalof OHM-impacted materials would be beneficial to the long-term restoration of the site. In addition, restoration of the site to unrestricted use would provide both short- and long-term benefit.

Timeliness Excavation and off-site disposal would expedite achievement of a condition of No Significant Risk to human health and the environment in a.timely manner.

30 YANKEE/0028054-6/17/05 ERM ERM 30 YANKEE/0028054-6/17/05

5.4.1.2 Alternative #2- Excavation, On-Site Thermal Treatment & Reuse and Off-Site Disposal The primary engineering and management components of Alternative #2 are similar to Alternative #1. Remediation wastes containing PCBs and petroleum hydrocarbons would be treated on-site using thermal treatment prior to reuse of the material as fill. Soil containing lead and dioxin would be, disposed off-site.

Effectiveness This alternative would reduce OHM to levels that would not pose a condition of Significant Risk to human health or the environment and enable achievement of a Permanent Solution. This alternative would detoxify the site by consolidating the mass of contaminants into a fraction of the impacted volume, but would not necessarily reduce the residual levels of OHM in the environment to background.

Reliability Excavation and off-site disposal is a reliable remedial method that has been used for decades to remediate OHM in the environment. Thermal trepitment of OHM-impacted soils is a common treatment method.

Therefore, this alternative carries a high degree of certainty in its ability to meet target remedial objectives necessary to achieve a Permanent Solution. No institutional controls would be necessary following remediation.

Implementability Removal by excavation is a common technology used to remediate soil.

The areas targeted for remediation are easily accessible for conventional excavation equipment. Therefore, excavation and off-site disposal is deemed to be implementable for those soils containing lead and dioxin.

Those soils to be treated and reused on-site are also easily accessible for conventional excavation equipment. Bench-scale testing has been.

performed to confirm the feasibility and cost of on-site thermal treatment.

Testing would be performed on a portion of soil to ensure thatthe thermal treatment process would achieve the desired treatment level. Thermal treatmentunits-are transportable and would be brought to the site.

Therefore, this alternative is deemed to be implementable.

ERM ERM 31 31 YANKEE/0028054-6/17/05

.YAN KEE/ 028054-6/17 /05

Cost The estimated cost for the on-site treatment and reuse and off-site disposal for soil impacted with lead and dioxin is summarized in Table 4. The estimated cost for this alternative is $7,240,000. Long-term operation and maintenance would not be necessary.

If the radiological characterization indicated tlhat the soils intended for' off-site disposal needed to be managed as a radiological waste, then the costs for off-site disposal could increase the cost of this alternative substantially.

Risks This alternative would provide long-term risk reduction. Effective management of remedial actions and remediation waste would ensure protection of human health (use of personal protective equipment) and the environment (engineering controls) during implementation. The on-site use of thermal treatment equipment and the off-site transport of the material pose a slight short-term risk, but this can be reduced through application of appropriate health and safety protocols.

Benefits Excavation and off-site disposal of OHM-impacted materials would be beneficial to the long-term restoration of the site. In addition, restoration of the site to unrestricted use would provide both short-and long-term benefit. Thermal treatment and on-site reuse of OHM-impacted materials would provide benefits by reducing the amount of material targeted for disposal in off-site disposal facilities. Thermal treatment should also have the benefit of destroying.the OHM.

Timeliness Excavation and off-site disposal would expedite achievement of a condition of No"Significant Risk to human health and the environment by eliminating the potential for OHM exposure in a timely manner.

ERM*

ERM 32 32 YANKEE/0028054-6/17/05 YANlKEE/001804-6"/17/05

5.4.2 Lead 5.4.2.1 Alternative #1 - Excavation & Off-Site Disposal The primary engineering and management components of Alternative #1 include permitting, excavation and segregation, off-site disposal and site restoration. Each of these components is described briefly below:

" Permitting and Approvals - obtain approval from permitting authorities.

" Excavation and Segregation - excavation and segregation of lead-impacted soil.

0 Transportation & Disposal - transport materials to licensed treatment and/or disposal facilities, based on waste characterization and receiving facility requirements.

• Site Restoration - restoration of disturbed areas.

Effectiveness Excavation and off-site disposal of the waste would be very effective at reducing lead concentrations to levels that achieve a condition of No Significant Risk to human health and the environment and enable achievement of a Permanent Solution. This alternative would not necessarily destroy or detoxify lead (for the material is placed in a landfill) and would reduce the concentrations to below the cleanup goals, but may not reduce the residual levels of lead in the environment to background.

Reliability Excavation and off-site disposal is a reliable remedial method that has been used regularly toremediate lead. Therefore, this alternative carries a high degree of certainty in its ability to meet target remedial objectives necessary to achieve a Permanent Solution. No institutional controls would be necessary following remediation.

Implementability Removal by excavation is a common technology ýused to remediate soil.

The areas targeted for remediation are easily accessible for conventional excavation equipment. Therefore, excavation and off-site disposalis deemed to beimplementable.

ERM 33 YANKEE/0028054-6/17/05

Cost The cost estimate for the off-site disposal alternative is summarized in Table 5. The estimated cost for this alternative is $30,000. Long-term operation and maintenance would not be necessary.

It should be noted that if the radiological characterization indicated that the soil needed to be managed as a radiological waste, then the disposal costs would increase substantially.

Risks Excavation and off-site disposal would provide for long-term risk reduction. Effective management of remedial actions and remediation waste would be necessary to ensure protection of human health (use of personal protective equipment) and the environment (engineering controls) during implementation. The off-site transport of the material poses a slight short-term risk that could be controlled.

Benefits Excavation and off-site disposal of lead-impacted materials would be beneficial to the long-term restoration of the site. In addition, restoration of the site to unrestricted use would provide both short- and long-term benefit.

Timeliness Excavation and off-site disposal would expedite achievement of a condition of No Significant Risk to human health and the environment in a timely manner.

5.4.2.2 Alternative #2 - Excavation, On-Site Stabilization/Solidificationand On-Site Reuse The primary engineering and management components of Alternative #2 are identical to Alternative #1, with one exception; remediation wastes would be stabilized/solidified on-site, with the treated material re-used on-site as fill. Selection of the actual treatment technique would be made following treatability studies.

34 YANKEE/0028054-6/17/O5 ERM ERM 34 YANKEE/0028054-6117/05

Effectiveness This alternative would reduce lead to levels that would not pose a condition of Significant Risk to human health or the environment and enable achievement of a Permanent Solution.

Reliability Stabilization/solidification is a relatively reliable remedial method that has been used to remediate lead and other heavy metals in the environment. Treatability testing would be necessary to ensure a high degree of certainty in its ability to meet target remedial objectives necessary to achieve a Permanent Solution. No institutional controls would be necessary following remediation.

Implementability Removal by excavation is a common technology used to remediate soil.

Those soils to be treated and reused on-site are easily accessible for conventional excavation equipment. Bench-scale testing would be performed to confirm the feasibility and cost of on-site treatment. Testing would be performed on a portion of soil to ensure that the treatment process would achieve the desired treatment level. The equipment used is transportable and would be brought to the site. Therefore, this alternative is deemed to be implementable.

Cost The estimated cost for the on-site treatment and reuse is summarized in Table 6. The estimated cost for fhisalternative is $80,000. Long-term operation and maintenance would not be necessary.

Risks This alternative would provide long-term risk reduction. Effective management of remedial actions and remediation waste would ensure protection of human health (use of personal protective equipment) and the environment (engineering controls) during implementation.

Benefits Excavation and detoxification of lead-impacted materials would be beneficial to the long-term restoration of the site. However, the re-use of EIZM 35 YANKEE/0028054-6/17/05

the treated soil may not be desirable to the property owner due to the desire for unrestricted use of the site. On-site reuse of the treated lead-impacted materials would provide benefits by reducing the amount of material targeted for disposal in off-site disposal facilities. However, the treatment would not have the benefit of destroying the lead or reducing its mass.

Timeliness Excavation, treatment, and on-site management would expedite achievement of a condition of No Significant Risk to human health and the environment by eliminating the potential for OHM exposure in a timely manner.

36 YANKEE/0028054-6/17/05 ERM ERM 36 YANKEE/0018054-6117/05

6.0 COMPARATIVE EVALUATION OF ALTERNATIVES 6.1 OVERVIEW This section presents a comparative evaluation of the remedial alternatives discussed in Section 5.0. This evaluation compares the remedial alternatives for each screening criterion and determines which alternative(s) is (are) most likely to satisfy the requirements of that criterion. The purpose of the comparative analysis is to assist in selecting the remedial alternative that appears most likely to achieve the remedial action objectives for the site (i.e., the alternative that best satisfies the majority of screening criteria).

To assist in this analysis, a numerical scoring system was adopted to calculate a cumulative score for each alternative based on: 1) the relative importance of each of the seven criteria in meeting response action objectives for that media (i.e., a weighting factor for each criteria by media); and 2) the degree to which the alternative meets each of the seven detailed evaluation criteria listed under 310 CMR 40.0858 (i.e.,

effectiveness, reliability, implementability, cost, risk, benefits and timeliness). This scoring process is summarized below.

Each of the evaluation criteria were first assigned a relative weighting factor based on judging the relative importance of the criteria in meeting remedial action objectives:

" A weighting factor of "3" was assigned if the criteria was judged to be of highest importance in meeting the remedial action objectives.

• A weighting factor of "2" was assigned if the criteria was judged to be of moderate importance in meeting the remedial action objectives.

• A weighting factor of "1" was assigned if the criteria was judged to be of least importance in meeting the remedial action objectives.

Each of the remedial alternatives was then assigned a numerical evaluation score based on the degree to which the alternative was judged to meet the each of the seven evaluation criteria. Evaluation scores were assigned as follows:

ER 37 YANKEE/0028054-6/17/05

• Effectiveness o 1 - Not likely to result in a Permanent Solution o 2 - May result in a Permanent Solution o 3 - Likely to result in a Permanent Solution

• Reliability o 1 - Not widely used or proven successful o 2 - Not widely used but likely to be applicable o 3 - Widely used and proven successful

• Implementability o 1 - Most complex o 2- Moderately complex o 3 - Least complex a Relative Cost o 1 - Highest o 3 -Lowest

• Relative Risk o 1 - Highest o 3 - Lowest 0 Relative Benefits o 1 - Lowest o 3- Highest

• Timeliness o 1 - Longer treatmenttime than desired o 2 - Acceptable treatment time o 3 - Rapid treatment time Criterion-specific scores for each remedial alternative were calculated as the product of the weighting factor and the evaluation score. The total score for each remedial alternative was calculated by suummg the criterion-specific scores. Therefore, the higher the total score, the more desirable the alteriiative' The comparative evaluation scores for each alternative are summarized in Tables 7 and 8 and described in the following sections.

ERM ERM 38 38 YANKEE/0028054-6/17/05 YANKEE/002805"-/17/0S

6.2 PCBS, DIOXIN AND PETROLEUM HYDROCARBONS The two alternatives identified for remediation of PCBs, dioxin, and petroleum hydrocarbons in soil and the calculated comparative evaluation scores for each alternative are summarized below:

Alternative Comparative Evaluation Score

1. 1 - Excavation & Off-Site Disposal 35

1. 2 - Excavation, On-Site Thermal Treatment and On and Off- 37 Site Disposal Based on the comparative evaluation scores calculated for remediation of soil, Alternative #2 - Excavation & On-Site Thermal Treatment and On-and Off-Site Disposal scores highest in comparative evaluation, followed closely by Alternative #1 - Excavation & Off-Site Disposal. Both alternatives are being utilized onsite based on the association of OHM to other parameters (i.e. radiological).

6.3 LEAD The two alternatives identified for remediation of lead in soil and the calculated comparative evaluation scores for each alternative are summarized below:

Alternative Comparative Evaluation Score

1. 1 - Excavation;& Off-Site Disposal 40'

1. 2 - Excavation, On-Site Stabilization/Solidification and On- 34 Site Reuse Based onthe comparative evaluation scores calculated for remediation of soil, Alternative #1- Excavation & Off-site Disposal scores highest in comparative evaluation.

ERM 39* ERM 39YANKEE/00280546/17/05

7.0. RECOMMENDED REMEDIAL ALTERNATIVES 7.1 SELECTION OF REMEDIAL ACTION ALTERNATIVES Based on the results of the technology screening and a detailed evaluation of remedial alternatives YAEC has selected excavation of OHM-impacted soil and a combination of off-site disposal (of lead and dioxin-impacted soil) and on-site treatment by thermal desorption followed by on-site reuse as a fill material.

7.2 FEASIBILITY OF ACHIEVING BACKGROUND The MCP (310 CMR 40.0860(6) (a)) states that achieving background should be considered feasible unless "the incremental cost of conducting the remedial alternative is substantial and disproportionate to the incremental benefit of risk reduction, environmental restoration, and monetary and non-pecuniary values." Using a benchmark comparison approach, ERM evaluated the cost of additional remediation to approach or achieve background to the cost of achieving a condition of No Significant Risk at the site.

As shown in Tables 3 through 6, the cost to complete the chosen remedial alternative for soil to the target remedial objectives is estimated at $7.2M to achieve a condition of No Significant Risk. The volune of soil requiring removal and dispoSal is estimated at 18,000 cubic yards. Remediation of soil tobackground would require removal of soil atall sample locations where the concentrations of OHM are greater than the laboratory detection limit. The volume of remediation waste is estimated to increase from 18,000 cubic yards to approximately 28,000 cubic yards. This results in an increase in cost from $7.2M to $12.3M.

Available Department guidance regarding the use of benchmark comparisons in determining the feasibility of remediation to background indicates that if the additional costs to remediate beyond a condition of No Significant Risk to levels that approach background exceed 20 percent' of the cost to remediate to a condition of No Significant Risk then EK* 40 Y ANKEE / 028054-6 /1i7/ O5

remediation to approach background is considered infeasible. Therefore, based on the above benchmark comparison remediation of soil to approach or achieve background is considered infeasible.

ERM 41 YANKEE/0028054-6/17/05

8.0 CONTAMINANT SOURCE REMOVAL 8.1 PCB SOURCE REMOVAL PCB Source The source of PCBs at the site was identified as PCB-containing paint flaking from'the VC and other buildings. Aroclor 1254 was detected in paint chips from the VC at concentrations up to 9,100 ppm. PCBs have been detected in paint chips from other buildings at the site at concentrations up to 720 ppm.

Immediate Response Action The following source control measures were conducted as a part of the IRA to abate the release of PCBs to the environment.

• Paint chip characterization

" Building inspection and monitoring program

• Removal of PCB-containing paint from building surfaces under an USEPA approved Alternate Method of Disposal Approval (AMDA)

• VC painting to stabilize the underlying PCB laden paint.

• Road sand and catch basin remediation and monitoring program Exterior building surfaces were characterized for PCB-containing paint prior to demolition. Additional PCB source removal has been completed in advance of building demolition and has continue during plant decommissioning. Abatement Of PCB-containing paint at concentrations of 50 ppm or greater of PCBs is conducted under specific USEPA approved work plans developed in accordance with the AMDA, issued by the USEPA under Section6(e)(1) under the Toxic Substance Control Act (TSCA) and thePCB regulations (40 CFR61).

Release Abatement Measure The following mitigation measures continue under a DEP-approved RAM following the completion of the IRA:

ERM 42 YANKEE/002805"/17/05

• Road Sand and Catch Basin Remediation and Monitoring Program

• Building Inspection and Monitoring Program The RAM has been an effective tool to manage PCB impacted soils and has remained in effect during the decommissioning of buildings and structures coated with PCB-containing paint are completed. RAM Status Reports have, and will be filed with the MADEP at six-month intervals.

All standing buildings coated with PCB paint have now been demolished and future management of soils will be performed through the Phase IV process. A RAM completion report will be generated to document the final six-month interval.

8.2 DIOXIN SOURCE REMOVAL The source of dioxin at the site were two former incinerators. Two incinerators built in 1960 were taken out of service and later demolished (Framatome, 2003a). The primary incinerator was used to concentrate radiological wastes by stabilizing the ashes and non-combustible radioactive waste with cement in a compactor. The primary incinerator and compactor were located in the Waste Disposal Building in what is now the RCA. This practice was discontinued in 1970. A secondary incinerator burned non-radiological, combustible solid waste and by 1969 this solid-waste disposal practice had been discontinued. The incinerators were subsequently, demolished.

8.3 PETROLEUM SOURCE REMOVAL The removal of an inactive fuel line located between a former AST and a fuel transfer building is being planned. The former AST was dismantled during December 2000 and the associated fuel lines were drained and purged and are no longer in use. Visual inspections performed at the time of tank dismantling indicate no evidence of a fuel oil release associated with the former AST and distributionlines.

43 YANKEE/0028054-6/17/05 ERM ERM 43 YANKEE/0028054-6/17/05

8.4 LEAD SOURCE REMOVAL The source of lead was an old shooting range located onsite. The old shooting range was replaced with a new shooting range. The locations of the shooting ranges are shown on Figure 2. The shooting ranges were used by plant security for training purposes. Both ranges were closed and lead-impacted soil from the old and new shooting ranges was excavated and disposed of off-site in November 1997 as Limited Removal Actions (LRAs). A total of 20 cubic yards was removed from the shooting ranges.

Post-excavation sampling confirmed that the concentrations were below MCP RCs at that time. Subsequent evaluation identified residuals within a limited area.

ERM 44 YANKEE/0028054-6/17/05

9.0 CONCEPTUAL DESIGN 9.1 OVERVIEW The primary engineering and management components of the remedy implementation include:

Permitting- obtaining approvals from permitting authorities, including, but not limited to, the MADEP, USEPA, and the Rowe Conservation Commission.

• Remediation of Soil in Six Areas 0 Excavation - excavation of impacted soil from the locations shown in Figure 5.

• Verification Sampling - sampling the limits of the soil removal to confirm that remedial objectives have been achieved.

" Transportation& Disposal - transportation of the lead-impacted soil and dioxin-impacted soil to a licensed disposal facility based on waste characterization and receiving facility requirements.

" On-Site Treatment and Re-use - treatment of remediation waste using Indirect Thermal Desorption and reuse of soils on-site following testing.

Site Restoration - additional restoration of areas disturbed during remedial activities through regrading and planting.

9.2 REQUIRED PERMITS/APPROVALS The regulatory programs that are applicable to the Phase IV implementation are summarized below, along with the associated filings and permitting and approval authorities.

ERM 45 YANKEE/0028054-6/17/05

Permitting/Approval Regulatory Program Anticipated Filing Authority Massachusetts Contingency Phase 11/Phase IV Licensed Site Professional Plan (LSP)

Wetlands Protection Act Abbreviated Notice of Rowe Conservation (WPA)/Rivers Protection Act Resource Area Delineation and Commission and MADEP a Notice of Intent Toxic Substances Control Act Application for Risk-based Environmental Protection (TSCA) Disposal Approval Agency (USEPA)

TSCA Operation Permit for Thermal USEPA Desorption System TSCA Application for Self- USEPA Implementing Cleanup &

Disposal Solid Waste Management CAD Approval MADEP Facility Regulations Application for Beneficial Use Determination (BUD)

The applicability of each of the above regulatory programs is summarized below.

Massachusetts Department of Environmental Protection, Hazardous Waste Regulations - The management of wastes including those that contain PCBs are regulated in Massachusetts under 310 CMR 30.000.

These. regulations are intended to protect public health, safety, and welfare, and the environment, by comprehensively regulating the generation, storage, cpllection, transport, treatment, disposal, use, reuse, and recycling of hazardous waste in Massachusetts.

Wastes containing PCBs at greater than 50 ppm are subject to these regulations and are classified as Code MA02."

The WPA regulates activities in wetland resource areas and associated Buffer Zones, which are defined as areas within 100 feet of a wetland resource area, and in the Riverfront Area, which includes areas within 200 feet of a river. On 18 March 2004, YAEC filed an Abbreviated Notice of Resource Area Delineation (ANRAD) with the Rowe Conservation Commission and the MADEP to confirm the classification and delineation of the wetland resource areas in the vicinity of the site. The ANRAD was approved'verbally on 31 March 2004. The Order of Resource- Area Delineation was received on 20 ERM ERM 46 46 YANKEE/00280546/17/05 YAN KEE/0028054-6/17/05

April 2004. A Notice of Intent was filed on 7 May 2004 to support site activities, including removal of the SCFA. The Order of Conditions was issued on 14 September 2004.

TSCA regulates the remediation of releases of PCB-containing materials with a total PCB concentration greater than or equal to 50 ppm total PCBs. USEPA approval will be required for the proposed remedial activities at the site to comply with TSCA. A Notification &

Certification of Self-Implementing Cleanup & Disposal of PCB Remediation Waste for the industrial area of the plant was submitted to USEPA for the Southeast Construction Landfill on 4 April 2005 and approved on 28 April 2005. A Notification for the remainder of the site was provided to EPA on 6 May 2005 and is within the approval process at EPA. MADEP

• *TheSCFA has been classified as a construction and demolition (C&D) landfill by the MADEP and is undergoing closure in accordance with the Massachusetts Solid Waste Management Regulations, 310 CMR 19.000. MADEP issued a BUD Permit Approval - Provisional on 23 December 2004. This is no longer provisional as the Board of Health has reviewed the document. The BUD allows for the reuse of SCFA soil in restoration of the site. A separate BUD has been submitted for Department approval of the reuse of subsurface structures and above grade rubblized concrete in site restoration.

9.3 DESIGN AND CONSTRUCTION Soil excavation activities may take place in conjunction with facility demolition and decommissioning activities. Areastar~geted for soil excavation are generally unpaved. Excavation of the impacted shallow soil in most locations will be accomplished using a backhoe or front-end loader. Most areas are relatively flat and readily accessible using conventional earth moving equipment Portions of the targeted remediation area located West of the ISFSI access road are relatively steep and cfntain largei obblesand boulders.

Equipment, such asa long-reach excavator may b utilized to avoid the need

- :to drive excavation equipment onto theslop es of the hill&s Some soil removal may have to be conducted by hand or vacuum extraction due to the presence of obstacles (e.g. boulders) and accessibility issues. 56il removal will likely take place from upslope locatin todown-slope locations and upwind to downwind locations to minimize the potential ERM 47 YANKEE/0028054-6/17/05

for recontamination of previously excavated areas.

In general, soil will be removed to depths up to four feet below grade.

Excavated soil will be placed directly into roll-off containers or trucks for transport to staging areas for treatment and/or characterization.

Verification sampling, as described in Section 9.7, will be conducted prior to restoration activities. Erosion controls and temporary barriers or fencing will be placed around the excavated areas until verification sampling confirms that closure goals have been met and restoration is complete. Restoration of the area located West of the ISFSI access road is described in Section 9.6.

A detailed description of soil removal in the SCFA is included in the Notification & Certification of Self-Implementing Cleanup & Disposal of PCB Remediation Waste (Yankee, 2005) and Soil Management Plan (Yankee, 2005). These documents will be used by YAEC in conducting oversight of field activities that involve the excavation, segregation and on-site management of soil impacted by OHM and/or radioactivity associated with removal of the SCFA.

Figure 6 shows the planned locations for staging materials and equipment during remedial activities. These locations may be modified during implementation based on the availability of space during continuing plant decommissioning activities.

9.4 MANAGEMENT OFREMEDIAL WASTE 9.4.1 Soil StorageAreas Excavated soil will be segregated into stockpiles in the staging areas shown in Figure 6. Soil will be stored in a manner that will minimize the' infiltration of precipitation and erosion of the stockpile in accordance with 310 CMR 40.0036(3). Stockpiles and containers will be covered when not actively being managed. Silt fences or other erosion control measures will be used, as necessary, where Asl: handling occurs.

The stored remediation wastes willbe nspected periodically by YAEC:

environmental staff to ensure the integrity'of the containers and that the stockpiles covets are maintained.

Soil thermally treated on-site, will be stored in a separate location.

ERM 48 YANKEE/0028054-6/17/05

Sampling will confirm whether is meets the remedial objective. If the soil meets the remedial objective, it will be moved to another stockpile location to await on-site reuse.

In summary, the following stockpiles of soil are anticipated during Phase IV activities:

0 Excavated soil containing PCBs and/or petroleum hydrocarbons awaiting on-site thermal treatment 0 Excavated soils containing PCBs to be disposed of off-site

• Excavated soil containing lead to be disposed off-site

• Excavated soil containing dioxin to be disposed off-site

• Treated soil awaiting sampling and results

• Treated soil confirmed for re-use 9.4.2 Characterizationfor Disposal Stockpiled soil anticipated for off-site disposal will be sampled to confirm disposal options and to satisfy requirements of the disposal facility.

Stockpiled soil will be sampled for the following constituents. This list may change to meet the requirements of the selected disposal facility:

• PCBs extraction by EPA Method 3500B/3540C or 3500B/3550B

• PCBs by EPA Method 8082

" Lead by EPA Method 6010 (Total and/or TCLP)

" Radiological constituents Upon receipt of characterization data, stockpiled material will be released for shipment if it meets the acceptable levels for the disposal facility.

9.4.3 Transportationand Disposal Stockpiled material to be disposed off-site will be shipped to the designated disposal facility via truck. When segregated material has been released from the staging area, it Will be loaded into dump trailers or roll offs utilizing front-end loaders and other earth moving equipment.

Trucks will transport this material to the destination'facility.

Hazardous material shipped from the site will be properly manifested or shipped under a bill of lading if the material is non-hazardous. A log will

49. . .

ERM 49 ' YANKEE/OOM54-6/17/05

be maintained to track all shipments that leave the site. The following information will be tracked:

• Container ID, date, and time container left site

" Hauler

" Approximate volume

• Weight (when measured)

" Waste classification

• Manifest number

• Date of receipt of Manifest copy Excavated material will be disposed of at a disposal facility approved by YAEC, in accordance with RCRA, TSCA, and NRC requirements. Non-hazardous, non-radioactive waste will be disposed of or recycled at an appropriately permitted facility.

As part of facility decommissioning, radiological characterization is ongoing. In the event that soils are to be transported off-site for treatment and/or disposal, a determination will be made if the materials must be transported to a facility specifically permitted for radiological waste. For the purposes of the detailed evaluation, it was assumed that the soil would not be classified as radiological waste. If it is determined that this assumption must be modified, it may be appropriate to revisit the conclusions of this Remedial Action Plan.

9.4.4 On-Site Thermal Desorption On-Site Thermal Desorption will be performed using an Indirect Thermal Desorption System (IDS). The IDS is comprised of multiple components to treat contaminated soils and the associatedvaporand liquid steam resulting from the treatment process. The system consists of:

• an indirectly heated desorber to remove contaminants from soil;

• gas treatment components, includinga condenhser to remove contaminants from the carrier gas; and.

water treatient components to remove and concentrate contaminants from the water stream.,

The IDs indirectly heats soil in an enclosed rotary drum desorber where contaminants are volatilized from the soil. Remediated soils are passed ERM 50 YANKEE/O028054.6/17/O5

through a soil re-moisturizing and discharge system and are then stockpiled and tested to verify adequate treatment.. The IDS operates at desorption temperatures up to 1,400 degrees Fahrenheit (°F) to treat soils contaminated with a range of compounds, including PCBs and petroleum.

The unit planned for use at the Site is a transportable, indirect-fired rotary desorber. Off-gases are collected by condensation. Water from the system is processed through a mobile water treatment system, where contaminants are removed, concentrated, and collected. Treated water is used to cool and re-moisturize the treated soil, thereby providing a closed-loop for the process water. Excess water will be tested and discharged under an NPDES Exclusion permit. An induced draft fan maintains negative pressure throughout the system during operations.

IDS operations generate four primary waste streams that will be collected, and disposed off-site. Wastes produced from the IDS treatment process include:

• Filter cake from filter press

• High Efficiency Particulate Air (HEPA) Filter

• Expended vapor phase carbon a Condensed waste water The planned location of the IDS is shown in Figure .6.

Best Management Practices will be employed to contain prevent impacts to media on the. area of on-site treatment. These practices could include:

construction of a barrier system for the unit and feeder area, operation of dust suppression systems, and construction of erosion control features.

Detailed information regarding the planned thermal desorption process is include'd in Appendix D..

9.5 CLEANING AND DECONTAMINATION OF EQUIPMENTAND SAMPLING EQUIPMENT

Equipment in contact with potentially contaminated materials will be decontaminated in accordance with the YNPS Quality AssuranceProject Plan (QAPP).

ERM ERM 51 51 YANKEEIOO2SOS4-6/17/05 YANKEE/0028054-6/17/05

9.6 SITE RESTORATION Restoration work over most of the excavated areas will consist of backfilling with treated soil or a subsoil, installing topsoil, raking in an herbaceous conservation seed mix, and mulching with straw or using an erosion control blanket. Yankee has also developed and will implement a post-remediation planting plan for the site that-was provided as part of the site permitting process.

The remediation work area West of the ISFSI access road will be restored by installing a geotextile fabric will be installed to prevent migration of fines and potential soil loss. Where remedial activities occur, the slope will be restored to the pre-existing grades (or flatter) and backfilled with a subsoil and topsoil. An herbaceous conservation seed mix and an erosion blanket will be installed to provide erosion protection and vegetation cover in accordance with the post-remediation planting plan.

9.7 OPERATION PARAMETERS 9i7.1 Verification Samplingfor Area I through Area 4 Sampling Objectives The proposed sampling plan will focus on satisfying TSCA requirements in accordance with 40 CFR 761 Subpart 0, for verification sampling that is necessary to confirm whether or not remedial goals have been achieved.

Closure sampling data will be statistically analyzed and compared to site remedial goals (See Section 3.2.1). Additional sampling of the excavation bottom and sidewalls, ifapplicable, will be conducted to guide excavation activities and will be integrated as appropriate to meet TSCA requirements for verification sampling.

Verification Sample Locations A 30-foot by 30-foot sampling grid will be established over the remedial

excavation areas. Each 30-foot-grid will be divided into nine, 10-foot by 10-foot grid cells. Grab samples will be collected from center of the-floor

, and sidewall cells and homogenized for composite samples. This is illustrated in Figure 7.

ERM ERM 52 52 YANKEE/0028054-6/17/05 YANKEE/0028054-6/17/05

Sampling Methods Samples will be collected in accordance with YNPS Procedure DP-8120 Collection of Site Characterizationand Site Release Samples, Appendix E. The samples will be composited foranalysis of PCBs. Northeast Laboratory Services or Spectrum Analytical will conduct the analysis..

Grab samples will be collected at a depth of 7.5 centimeters (cm) utilizing a hand auger or equivalent that has a diameter greater than 1 inch (2 1/2 cm) and less than 1 1/2 (approximately 4'cm). The hand auger may be constructed of stainless steel or polycarbonate material, depending on the hardness/soil type of the excavated area. A small hand shovel may also be used if the hand auger is ineffective (i.e. the soil is too saturated or sandy). Dedicated sampling equipment will be used, where feasible.

Composite samples will be submitted for laboratory analysis from excavated areas. A nine-point composite will be collected from the floor of excavated areas and a three-point composite will be collected along the excavation sidewalls. Floor samples will be collected every 10 feet to create a 30 by 30-foot grid and a composite sample every 900 square feet.

Sidewall samples will be collected every 10 feet for a composite sample every 30 linear feet. Areas excavated to six inches will not contain sidewall grid cells.

9.7.2 Verification SamplingforArea 5 and SCFA Sampling Objectives The proposed sampling plan will focus on satisfying TSCA requirements in accordance with 40 CFR 761 Subpart 0, for verification sampling that is necessary to confirm whether or not remedial goals have been achieved.

Closure samplingdata will be statistically analyzed and compared to site remedial goals (See Section 3.2.1). Additionalsampling of the excavation bottom and sidewalls, if applicable, will be conducted to guide excavation activities and will be integrated as appropriate to meet TSCA requirements for verification sampling.

Verification Sample Locations A composite sam~ple will be collected from eacheexcavation. As described within the ISCA approval for the SCFA, grid cells five tosix feet in height andfive feet in length will be measured along the sidewall of each excavation lift and five-foot by five-foot grid cells will be measured along EI .5 .NKF/0

. , ,/1/0 EI, M 53 YANKEE/0028054-6/17/05

the excavation floor. Grab samples will be collected from the center of each cell and homogenized for composite samples. The proposed number of samples needed for each area is summarized in Table 9 and shown in Figures 9 through 13. The actual number of grab samples taken may increase or decrease depending on field measurements of each sidewall length.

Sampling Methods Samples will be collected in accordance with YNPS Procedure DP-8120 Collection of Site Characterizationand Site Release Samples, Appendix E, and will be analyzed for PCBs by EPA Method,8082. Northeast Laboratory Services or Spectrum Analytical will conduct the analysis.

Each grab sample within the composite will be collected to a depth of 7.5 centimeters (cm) utilizing a hand auger or equivalent that has a diameter greater than 1 inch (2 1/2cm) and less than 1 1/22 inches (approximately 4 cm). The hand auger may be constructed of stainless steel or polycarbonate material, depending on the hardness/soil type of the excavated area. A small hand shovel may also be used if the hand auger is ineffective (i.e. the soil is too saturated or sandy). Disposable sampling equipment will be used where feasible to increase efficiency.

Grab samples will be homogenized and submitted for laboratory analysis as composite samples. Floor samples will be collected from the center of each five-foot grid cell, resulting in nine-point composite samples every 225 square feet. Similarly, sidewall samples will be collected every five feet and compositing of up to three consecutive grab samples (representing 15 linear feet) will be performed.

9.7.3 Verification Samplingfor Area 6 - FormerShooting Range Sampling Objectives The proposed sampling plan will focus on satisfying MCP guidance for verification sampling that is necessary to confirm whether or not remedial goals have been achieved. Closure: sampling data will be statistically analyzed and compared to site remedial goals (See Section 3.2.4).

Verification Sample Locations The number of samples needed for the area will depend upon the actual excavated area. The planned sample locations are shown in Figure 8.

ERM 54 YANKEE/0028054-6/17/05

Sampling Methods I Samples will be collected in accordance with YNPS Procedure DP-8120 Collection of Site Characterizationand Site Release Samples, Appendix E, and will be analyzed for lead by EPA Method 8010. Northeast Laboratory Services or Spectrum Analytical will conduct the analysis.

To verify that lead impacted soils were removed to meet the cleanup objectives, at least seven samples will be collected. All samples will be from a depth of 0-3 inches. Samples should be collected as follows:

• One, five-point composite sample will be collected from the base of the 12-inch deep excavation area.

One, five-point composite sample will be collected from each of the targeted three-foot deep excavation areas (one grab sample from each wall and one grab sample from the base).

• One, composite samples will be taken from each wall of the 12-inch deep excavation area.

The locations of the verification samples are shown in Figure 8. A unique naming convention must be used to identify each of the samples collected.

Each sample name will contain the prefix EX (Excavation) and be followed by the sample number (e.g., EX-401). Based on the size of the excavation, samples are to be collected as a five-point composite over each wall and floor.

Soil samples will be collected manually utilizing a hand auger or equivalent that has a diameter greater than 1 inch (21/2 cm) and less than 1 1/2/2 inches (approximately 4 cm). The hand auger may be constructed of stainless steel or polycarbonate material, depending on the hardness/soil type of the excavated area. A small hand shovel may also be used if the hand auger is ineffective (i.e. the soil is too saturated or sandy).

Disposable sampling equipment will be used where feasible to increase efficiency.

9o. PLEMENTATION PROGRAM 9.8.1 Site and EnvironmentalImpacts Remedial activities will be limited to the duration needed to complete the ERM 55 YANKEE/0028054-6/17/05

removal, verification sampling, and restoration. Silt fencing will be installed in accordance with Best Practices to reduce erosion in the work areas.

Stockpiles will be contained entirely on an impermeable base such as polyethylene sheeting (or equivalent) and will be covered with polyethylene sheeting (or equivalent) when not being actively managed in order to minimize the infiltration of precipitation and erosion of the stockpile. Stockpile cover material shall be properly secured and possess the necessary physical strength to resist tearing by the wind. Failure of materials or procedures used in employing the base layer or cover will be immediately repaired, replaced, or re-secured so as to minimize precipitation infiltration and erosion/runoff of the contaminated soil. All stockpiled soil 'Willremain covered and in the stockpile area until transport, disposal, or re-use.

9.8.2 Inspections and Monitoring The IDS operation will be directed through a TSCA permit obtained from EPA for the treatment of PCBs in soils. Sampling includes the analysis of untreated soils entering the process, samples of treated soils, the analysis of exhaust emissions during a contaminated soils shakedown phase, demonstration preparatory phase, demonstration testing phase and operational phase. In addition, condensed water that is in excess of that required within the process will be tested and discharged under an NPDES exclusion permit. An SOP for the collection and handling of samples will be developed by Yankee prior to implementation, to assure soils being reintroduced to the site following treatment meet Yankee's acceptance criteria.

9.8.3 Health and Safety The site-specific Health and Safety plan was prepared in accordance with 310 CMR 40.0018 and YAEC's Job Hazard Assessment Program. A copy, of the plan is included in Appendix F. A specific Job Hazard Assessment will be completed prior to use of the on-site Thermal Desorption Unit.

9.&84 PropertyAccess No approvals for property access are expected to be required.

E: 56 YANKEE/0028054-6/17/05

9.8.5 Public NotificationActivities Public Involvement Activities will be conducted in accordance with 310 CMR 40.1400 through 40.1406. Specifically, notification letters of availability of this Phase IV Plan will be sent to the Rowe Town Manager and Board of Health. Copies of these notices may be found in Appendix B.

9.9 IMPLEMENTATION SCHEDULE The anticipated schedule for remedial activities at the site is presented below. The actual schedule will be dependent upon receiving the appropriate permits.

Implementation Schedulefor PhaseIV Date Event Spring 2005 Mobilize to site; initiate excavation of soil Summer 2005 Initiate thermal treatment of soil on-site.

Fall 2005 Complete thermal treatment of soil; complete off-site disposal of soil and other waste 57 YANKEE/0028054-6/17/05 ERM 57 YANKEE/00280"/17/05

10.0 REFERENCES

ERM (Mr. J. McTigue and Mr. G. Demers), "Immediate Response Action Status Report," Letter to MADEP (Mr. A. Kurpaska), 24 August 2000.

ERM (Mr. J. McTigue and Mr. G. Demers), "Immediate Response Action Completion Report," Letter to MADEP (Mr. A. Kurpaska), 22 February 2001.

ERM (Mr. J. McTigue and Mr. G. Demers), "Release Abatement Measure Plan," Letter to MADEP (Mr. A. Kurpaska), 13 March 2001.

ERM (Mr. J. McTigue and Mr. G. Demers), "Release Abatement Measure Status Report No. 1," Letter to MADEP (Mr. A. Kurpaska), 19 July 2001.

ERM (Mr. J. McTigue and Mr. G. Demers), "Phase I Report and Tier I!1 Classification Submittal," Report to MADEP (Mr. A. Kurpaska), 25 April 2001.

ERM,,"Phase II Comprehensive Site Assessment," April 2003.

ERM, "Phase III - Remedial Action Plan," April 2003.

ERM, "Phase IV - Remedy Implementation Plan," April 2004 ERM, "Phase I1Comprehensive Site Assessment," January 2005.

Framatome ANP. 12 November 2003 (2003b). YNPS Hazardous Waste Storage Area Closure, Document Identifier 51-5031656-0.

Gradient, "Quality Assurance Project Plan - Site Closure," 2003.

MADEP; "The Massachusetts Contingency Plan," 310 CMR 40.0000,29 October 1999.

MADEP, "Authorization for Implementation of Immediate Response Action (IRA),"' Letter to Yankee, May 2000.

ERM 58 YANKEE/0028054-6/17/05

US Environmental Protection Agency (USEPA), "Guidance on Remedial Actions for Superfund Sites with PCB Contamination,". EPA/540/G-90/007, Office of Emergency and Remedial Response, Washington, DC, 1990.

USEPA, "Engineering Bulletin: Thermal Desorption Treatment.

EPA/540/2-91-008," Office of Emergency and Remedial Response, Washington, DC, and Office of Research and Development, Cincinnati, OH, 1996.

USEPA, "A Citizen's Guide to Solidification/Stabilization," EPA 542-F 024, 2001.

Yankee (Mr. B. Wood), "Release Notification Form and Immediate Response Action Plan," Letter to MADEP (Mr. A. Kurpaska), 23 June 2000.

.Yankee (Mr. J. Kay), "Release Abatement Measure Status Report No. 2,"

Letter to MADEP (Mr. A. Kurpaska), 16 January 2002.

Yankee (Mr. J. Kay), "Release Abatement Measure Status Report No. 3,"

Letter to MADEP (Mr. A. Kurpaska), 16 July 2002.

Yankee (Mr. J. Kay), "Release Abatement Measure Status Report No. 4,"

Letter to MADEP (Mr. A. Kurpaska), 16 January 2003.

• Yankee (Mr. J. Kay), "Release Abatement Measure Status Report No. 5,"

Letter to MADEP (Mr. A. Kurpaska), 16 July 2003.

Yankee (Mr. J. Kay), "Release Abatement Measure Status Report No. 6,"

Letter to MADEP (Mr. A. Kurpaska), 16 January 2004.

Yankee (Mr. J. Kay), "Release Abatement Measure Status Report No. 7,"

Letter to MADEP (Mr. A. Kurpaska), 16 July 2004.

Yankee (Mr. J. Kay), "Release Abatement Measure Status Report No. 8,'

Letter to MADEP (Mr. A. Kurpaska), 21 January 2005.

Yankeel(Mr. J. Rollins), "Release AbatemenitMeasure Plan Modification,"

Letter to MADEP (Mr. A. Kurpaska), 17 February 2005.

Yankee (Mr. J. Rollins), "Proposed Remedial Plan - PCB Cleanup in Soil,"

4 April 2005a.

ERMC 59 YANKEE/0028054-6/17/05

Yankee (Mr. J. Rollins), "Notification and Certification of Self-Implementing Cleanup & Disposal of PCB Remediation Waste -

Southeast Construction Fill Area," Letter to USEPA (Ms. K. Tisa), 4 April 2005b.

Yankee (Mr. J. Rollins), "Notification and Certification of Self-Implementing Cleanup & Disposal of PCB Remediation Waste -

Yankee Nuclear Power Station," Letter to USEPA (Ms. K. Tisa), 6 May 2005c.

ERM 60 YANKEE/0028054-6/17/05

Tables Table 1 Summary of Areas & Volumes Targeted for Remediation Yankee Nuclear Power Station Rowe, MA LiigtL Wdth epl.. z. olm 1.1 VC/RSS 125 125 2.0 957 Volume decreased 200 cubic yards due to concrete foundations 1.2 VC Entry 100 75 0.5 139 Upper half foot only Entry Target Areas 10 10 3.0 11 Target area where PCB impacts extend deeper 1.3 Alley 100 50 2.0 370 Two feet over area 1.4 Yard 100 50 0.5 93 Upper half foot only 1.5 Building Trenches 1,000 2 2.0 148 Adjacent to slabs 2' x 2' 1.6 Crane Pad West 50 25 3.0 139 Lay-down area for demolition 1.7 Crane Pad East 50 25 1.5 69 Lay-down area for demolition 1.8 Fuel Oil AST (petroleum hydrocarbo 100 10 4.0 148 SubtotalArea1 2,075

2. id W I 001I200 I 0.5 ___1,__l I 2.1_________ _ ___________ 1, 48 1 .

3.1 Former Incinerator (Dioxin) 100 75 1.0 278 Target Area 60 30 1.0 67 Target area where PCB impacts extend deeper.

3.2 Building Trenches 1,000 2 2.0 148 Adjacent to slabs 2x2 3.3 Moat 100 100 0.5 185 SubtotalArea 3 678 4.1 Trenches "

4.2 Soil on Turbine Pad SubtotalArea 4 1 550 150 1 2 100 2.0 2.0 81 1,111 1,193

.l Adjacent to slabs 2x2 Lay-down area for demo 5.1 Southeast Construction Fill Area Subto ta IArea 5 I310 three areas of varying configurations 6.1 Former Shooting Range 1 1 Area I (lead) 151 8 Area 2 (lead) 32 1 Area 3 (lead) 3 3 2 1 Subtotal Area 6 1 Other ~ -Ž~I_____Cretysokie Soil generated during decommissioning 3I 0 ~retysokie nst Subtotal Other _ 3,000 TOTALJ VOL'UMEF O SOIL Targeted for excavation I 8,537 Contingency 75% 6,402 Stockpiled Soil 3,000 Total Volume of Soil 17,939 SitobTrted QnSit,-

PCB and Petroleum Impacted Soils,17651 Dioxin Impacted Soils 278 ]Area 3.1 Lead Im acted Soils 10 Area 6.1

Table 3 Cost Estimate for Alternative #1 - Excavation and Off-Site Disposal of Soil PCBs, Dioxin and PAHs' Yankee Nuclear Power Station Rowe, MA Remedial Cost Item No. of Units ý. Units Unit Cost ($) Notes Cost ($)

Site Preparation Mobilization 1 Lump Sum $25,000 $15,000 Excavation 18,000 cubic yard $15 $270,000 Off-site Treatment/Disposal Off-site T&D 54,834,000 pounds $0.16 $8,773,440 Profiling/Approvals 10 Lump Sum $i,500 $i5,000 Restoration Backfilling/grading 51,216,000 pounds $0.0044 $225,350 subtotal $9,298,790 Design/Construction Oversight - 15% $1,394,819 Contingency - 20% $1,859,758 Estimated Construction Cost $12,550,000 Notes:

The above cost estimate is intended for comparison of the alternatives, not for budgeting or contracting purposes. Actual costs will vary. Supplemental investigation activities and detailed-design phases would provide the specific information needed to increase the accuracy of the cost estimates.

Table 4 Cost Estimate for Alternative #2 - Excavation, On-Site Thermal Treatment & On-Site Reuse and Off-site Disposal of Soil PCBs, Dioxin and PAHs Yankee Nuclear Power Station Rowe, MA, Remedial Cost Item No. of Units Units Unit Cost ($) Notes Cost ($)

Site Preparation Mobilization/Demobilization 1 lump sum $100,000 $20,000 Excavation 18,000 cubic yard $15 $270,000 On-SiteThermal Treatment On-Site Thermal Treatment 54,000,000 pound $0.09 $4,860,000 Off-site Treatment/Disposal Off-site T&D (dioxin-impacted soil) 834,000 pound $0.16 $133,440 Profiling/Appiovals 1 lump sum $1,500 $1,500 Restoration Backfilling/grading 54,000,000 pound $0.0015 $81,000 subtotal $5,365,940 Design/Construction Oversight - 15% $804,891 Contingency - 20% $1,073,188 Estimated Construction Cost $7,240,000 Notes:

The above cost estimate is intended for comparison of the alternatives, not for budgeting or contracting purposes. Actual costs will vary. Supplemental investigation activities and detailed-design phases would provide the specific information needed to increase the accuracy of the cost estimates.

Assumes no additional backfill needed due to re-use on site of < 50 ppm stabilized soils.

-4

Table 4 Cost Estimate for Alternative #2 - Excavation, On-Site Thermal Treatment & On-Site Reuse and Off-site Disposal of Soil PCBs, Dioxin and PAHs Yankee Nuclear Power Station Rowe, MA, Remedial Cost Item No. of Units Units Unit Cost ($) Notes Cost ($)

Site Preparation Mobilization/Demobilization 1 lump sum $100,000 $20,000 Excavation 18,000 cubic yard $15 $270,000 On-StiteThermal Treiatment On-Site Thermal Treatment 54,000,000 pound $0.09 $4,860,000 Off-site Treatment/Disposal Off-site T&D (dioxin-impacted soil) 834,000 pound $0.16 $133,440 Profiling/Approvals 1 lump sum $1,500 $1,500 Restoration Backfilling/ grading 54,000,000 pound $0.0015 $81,000 subtotal $5,365,940 DesigrnConstruction Oversight - 15% $804,891 Contingency - 20% $1,073,188 Estimated Construction Cost $7,240,000 Notes:

The above cost estimate is intended for comparison of the alternatives, not for budgeting or contracting purposes. Actual costs will vary. Supplemental investigation activities and detailed-design phases would provide the specific information needed to increase the accuracy of the cost estimates.

Assumes no additional backfill needed due to re-use on site of < 50 ppm stabilized soils.

~2

Table 5 Cost Estimate for Alternative #1 - Excavation and Off-Site Disposal of Soil Lead Yankee Nuclear Power Station Rowe, MA Remedial Cost Item No. of Units Units Unit Cost ($) Notes Cost ($) -

Site Preparation Mobilization 1 Lump Sum $15,000 $15,000 Excavation 10 cubic yard $15 $150 Off-site Treatment/Disposal Off-site T&D 15 tons $80.00 $1,200 Profiling/ Approvals 1 Lump Sum $2,000 $2,000 Restoration Backfill 13 cubic yards . $15 $195 Backfilling/ grading 13 cubic yards $18.00 $234 subtotal $18,779 Design/Construction Oversight - 15% $2,817 Contingency - 20% $3,756 Estimated Construction Cost $30,000 Notes:

The above cost estimate is intended for comparison of the alternatives, not for budgeting or contracting purposes. Actual costs will vary. Supplemental investigation activities and detailed-design phases would provide the specific information needed to increase the accuracy of the cost estimates.

Table 6 Cost Estimate for Alternative #2 - Excavation, On-Site Stabilization/Solidification & On-Site Reuse of Soil Lead Yankee Nuclear Power Station Rowe, MA Remedial Cost Item No. of Units Units Unit Cost ($) Notes Cost ($)

Site Preparation Mobilization/Testing/Demobilization 1 lump sum $30,000 $30,000 Excavation 10 cubic yard $15 $150 On-Site Stabilization/Solidification Testing 1 lump sum $25,000 $25,000 Treatment 10 ton $150.00 $1,500 Restoration Backfilling/grading 13 cubic yard $18.00 $234 subtotal $56,884 Design/Construction Oversight - 15% $8,533 Contingency - 20% $11,377 Estimated Construction Cost $80,000 Notes:

The above cost estimate is intended for comparison of the alternatives, not for budgeting or contracting purposes. Actual costs will vary. Supplemental investigation activities and detailed-design phases would provide the specific information needed to increase the accuracy of the cost estimates.

Assumes 30% bulking during treatment

- Wý' 'W" -m -f -

am 4 -'A so Aft M-4 W9m Table 7 Comparative Analysis of Remedial Alternatives - PCBs, Dioxin, PAHs Phase III Remedial Action Plan Yankee Nuclear Power Station Rowe, MA

" t .. . . ....... . . . . . . ..lt ...

.~ei

.i... ...........

.s~

1. 1 - Excavation and Off-Site 3 222 2 1 3 35 Disposal 3

1. 2 - Excavation, On-Site Thermal Treatment and On- 3 Site Reuse and Off-Site Disposal Notes:

Weighting factors are assigned based on the relative importance of each criterion in meeting remedial action objectives:

High Importance - 3 points Medium Importance - 2 points Low Importance - 1 point Evaluation Scores (Score) are assigned to each remedial alternative based on the relative favorability of alternatives in meeting the evaluation criterion:

Effectiveness Implementability Relative Risk Timeliness 1 - Not likely to result in a Permanent Solution 1 - Most complex 1 - Highest 1 - Longer treatment time than desired 2 - May result in a Permanent Solution 2 - Moderately complex 3 - Lowest 2 - Acceptable treatment time 3 - Likely to result in a Permanent Solution 3 - Least complex 3 - Rapid treatment time Reliability Relative Cost Relative Benefits 1 - Not widely used or proven successful 1 - Highest 1 - Lowest 2 - Not widely used but likely to be applicable 3- Lowest 3 - Highest 3 - Widely used and proven successful The total score is determined by multiplying theweighting factor by the Score and summing the criteria-specific scores for each alternative.

The highest score represents that alternative deemed most favorable for abatement of that media.

1- IV  ;- w -

MR W "a m fop- Vw " "

Table 8 Comparative Analysis of Remedial Alternatives - Lead Phase III Remedial Action Plan Yankee Nuclear Power Station Rowe, MA

1. 1 - Excavation and Off-Site 3 3 3 3 2 3 2 3 1 3 2 2 1 3 40 Disposal

1. 2 - Excavation, Stabilization/Solidification 3 3 3 3 2 2 2 2 1 2 2 2 1 2 34 and On-Site Reuse Notes:

Weighting factors are assigned based on the relative importance of each criterion in meeting remedial action objectives:

High Importance - 3 points Medium Importance - 2 points Low Importance - 1 point Evaluation Scores (Score) are assigned to each remedial alternative based on the relative favorability of alternatives in meeting the evaluation criterion:

Effectiveness Implementability Relative Risk Timeliness 1 - Not likely to result in a Permanent Solution 1 - Most complex 1 - Highest 1 - Longer treatment time than desired 2 - May result in a Permanent Solution 2 - Moderately complex 3 - Lowest 2 - Acceptable treatment time 3 - Likely to result in a Permanent Solution 3 - Least complex 3 - Rapid treatment time Reliability Relative Cost Relative Benefits 1 - Not widely used or proven successful 1 - Highest 1 - Lowest 2 - Not widely used but likely to be applicable 3 - Lowest 3 - Highest 3 - Widely used and proven successful The total score is determined by multiplying the weighting factor by the Score and summing the criteria-specific scores for each alternative.

The highest score represents that alternative deemed most favorable for abatement of that media.

Table 9 Verification Sampling Summary Southeast Construction Fill Area Yankee Nuclear Power Station Rowe, MA

.Number of Composite Samples Location [NE Wall [NW Wall[ SW Wall SE Wall Floor 11 Total Area A ___ ______

Lift1 2 2 2 2 4 12 Area B Lift I 2 2 2 2 4 12 Area C Lift 1 4 4 4 - 12 Lift 2 4 4 4 - 12 Lift 3 5 4 5 - 14 Lift 4 5 5- 14 Lift 5 4 4 4 - 20 32 Total 108 Note:

There are no samples on the SE Wall for Area C because soil will be excavated to the edge of the slope.

Figures 0

C'4 YAEC Property Boundary Scale 1:25,000 0.5km 0 5OOm 0.5 mi 0 1,000 ft 0

Figure 1 - Locus Map Yankee Nuclear Power Station - Rowe, MA ERM

I I

Scale 1:12,500 0.25 km 0 250 m 0.25 mi 0 50Ift Compound TPH-DRO 1 (9) (mglkg)

YAEC Property Boundary Ran mmman c. F200 F RCS-1 Targeted Deep Sample SB-155M Targeted Surface Sample SB-168A Background Surface Sample SBle Former UST Scale 1:120 Comments

1. Value rpelpeser mAlmum cumiwi lmi detected at sampleIocalm.

Figure 3 - Soil Sample Locations (Non-Industrial Area) and OHM Results Exceeding MCP Reportable Concentrations Yankee Nuclear Power Station - Rowe, MA ERM

Legend

"-*-- Fence E Solt Samples 0 Proposd Grab Samples for Composit Samples Proposed Excavation Amato 1ir

- Proposed Excal*ion Am to 3 Figure 8 - Verification Confirmatory Sampling

-Lead Impacted Area Yankee Nuclear Power Station - Rowe, MA ERM

Appendix A BWSC TransmittalForm (BWSC-108)

BWSC108 LI Bureau of Waste Site Cleanup Release Tracking Number COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Massachusetts FORM & PHASE,Department COMPLETION of Environmental STATEMENT Protection - 13411 Pursuant to 310 CMR 40.,0484 (Subpart D) and 40.0800 (Subpart H)

A. SITE LOCATION:

1. Site Name: Yank-ee Atomic Electric Plant

2. StreetAddress: 49 Yankee Road

3. Cityrrown: Rowe 4. ZIP Code: 01367-0000

5. Check here if a Tier Classification Submittal has been provided to DEP for this disposal site.

LI a. TierlA j] b. TierIB [] c. TierIC LI d. Tierli

6. If applicable, provide the Permit Number:

B. THIS FORM IS BEING USED TO: (check all that apply)

F1 1. Submit a Phase I Completion Statement, pursuant to 310 CMR 40.0484.

LI 2. Submit a Revised Phase I Completion Statement, purspantto 310 CMR 40.0484.

LI 3. Submit a Phase II Scope of Work, pursuant to 310 CMR 40.0834.

4. Submit an interim Phase II Report This report does not satisfy the response action deadline requirements in 310 CMR 40.0500.

L] 5. Submit a final Phase Report II and Completion Statement, pursuant to 310 CMR 40.0836.

[] 6. Submit a Revised Phase I Report and Completion Statement, pursuant to 310 CMR 40.0836.

7. Submit a Phase III Remedial Action Plan and Completion Statement, pursuant to 310 CMR 40.0862.

] 8. Submit a Revised Phase III Remedial Acyon Plan and Completion Statement pursuant to 310 CMR 40.0862.

09.Submit a Phase IV Remedy Implementation Plan, pursuant to 310 CMR 40.0874.

[]10. Submit a Modified Phase IV Remedy Implementation Plan, pursuant to 310 CM R 40.0874.

[] 11. Submit an As-Built Construction Report, pursuant to 310 CMR 40.0875.

(All sections of this transmittal form must be filled out unless otherwise noted above)

Revised: 04122/2004 Page I of 5

Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup BWSC108 Release Tracking Number COMPREHENSIVE RESPONSE ACTION TRANSMITTAL

- 13411 FORM & PHASE I COMPLETION STATEMENT Pursuant to 310 CMR 40.0484 (Subpart D) and 40.0800 (Subpart H)

B. THIS FORM IS BEING USED TO (cont): (check all that apply)

12. Submit a Phase IV Final Inspection Report and Completion Statement, pursuant to 310 CMR 40.0878 and 40.0879.

Specify the outcome of Phase IV activities: (check one)

E a. Phase V Operation, Maintenance or Monitoring of the Comprehensive RemedialAction is necessary to achieve a L Response Action Outcome.

b. The requirements of a Class A Response Action Outcome have been met. No additional Operation, Maintenance or

[] Monitoring is necessary to ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement and Report (BWSC104) will be submitted to DEP.

c. The requirements of a Class C Response Action Outcome have been met. No additional Operation, Maintenance or

[] Monitoring is necessary to ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement and Report (BWSC1 04) will be submitted to DEP.

d. The requirements of a Class C Response Action Outcome have been met, Further Operation, Maintenance or E] Monitoring of the remedial action is necessary to ensure that conditions are maintained and that further progress is made toward a Permanent Solution. A completed Response Action Outcome Statement and Report (BWSC104) will be submitted to DEP.

Fi 13. Submit a Revised Phase IV Final Inspection Report and Completion Statement, pursuant to 310 CMR 40.0878 and 40.0879.

[] 14. Submit a periodic Phase V Inspection & Monitoring Report, pursuant to 310 CMR 40.0892.

[] 15. Submit a Remedy Operation Status, pursuant to 310 CMR 40.0893.

Status, pursuant to 310 CMR

16. Submit a periodic Inspection & Monitoring Report to maintain a Remedy Operation E j40.0893(2)-

[1 17. Submit a Termination of a Remedy Operation Status, pursuantto 310 CMR 40.0893(5).

LI 18. Submit a final Phase V Inspection & Monitoring Report and Completion Statement, pursuant to 310 CMR 40.0894.

Specify the outcome of Phase V activities: (check one)

a. The requirements of a Class A Response Action Outcome have been met. No additional Operation, Maintenance or

[] Monitoring is necessary to ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement (BWSC1 04) will be submitted to DEP.

b. The requirements of a Class C Response Action Outcome have been met No additional Operation, Maintenance or

[] Monitoring is necessary to ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement and Report (BWSC104) will be submitted to DEP.

c. The requirements of a Class C Response Action Outcome have been met. Further Operation, Maintenance or E] Monitoring of the remedial action is necessary to ensure that conditions are maintained and/or that further progress is made toward a Permanent Solution. A completed Response Action Outcome Statement and Report (BWSC1 04) will be submitted to DEP.

D 19. Submit a Revised Phase V Inspection & Monitoring Report and Completion Statement, pursuant to 310 CMR 40.0894.

[] 20. Submit a Post-Response Action Outcome Inspection & Monitoring Report, pursuant to 310 CMR 40.0897.

(All sections of this transmittal form must be filled out unless otherwise noted above)

Page 2 of 5 Revised: 04122(2004 Revised: 04/22/2004 Page 2 of 5

BWSC108 Li Bureau of Waste Site Cleanup COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Release Tracking Number FORM & PHASEDepartment Massachusetts I COMPLETION STATEMENT Protection of Environmental - 13411 Pursuant to 310 CMR 40.0484 (Subpart D) and 40.0800 (Subpart H)

C. LSP SIGNATURE AND STAMP:

I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4.02(1), (ii)the applicable provisionsof 309 CMR 4.02(2) and (3), and 309 CMR 4.03(2), and (iii) the provisions of 309 CMR 4.03(3), to the best of my knowledge, information and belief,

> if Section B indicatesthat aPhase 1,Phase 11, Phase III, PhaseIV or Phase V Completion Statement is being submitted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed and implemented in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, (ii)is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, and (iii) comply(ies) with the identified provisions of all orders, permits, and approvals identified in this submittal;

> if Section B indicates that aPhasei Scope of Work or a Phase IV Remedy ImplementationPlanis being submitted,the response action(s) that is (are) the subject of this submittal (i) has (have) been developed in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, and (iii) comply(ies) with the identified provisions of all orders, permits, and approvals identified in this submittal;

> if Section B indicatesthat an As-Built ConstructionReport Phase V Inspection and MonitoringReport ora Remedy OperagonStatus is being submitted, the response action(s) that is (are) the subject of this submittal (i) is (are) being implemented in accordance with the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21 E and 310 CMR 40.0000, and (iii) comply(ies) with the identified provisions of all orders, permits, and approvals identified in this submittal.

I am aware that significant penalties may result, including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete.

1. LSP #: 6423

2. First Name: John 3. Last Name: McTigue

4. Telephone: (617) 646-7800 5. Ext: 7842 6. FAX (617) 267-6447

7. Signature: 8. Date: 9. LSP Stamp: i) frdyyy) JO"N MeTIGUIE ed NO. 6423

• Page 3 of 5 Revised: 0412212004 Revised: 04122/2004 Page 3 of 5

Bureau of Waste Site Cleanup BWSC108 Li COMPREHENSIVE RESPONSE ACTION TRANSMITTAL FORM & PHASEDepartment Massachusetts ICOMPLETION STATEMENT Protection of Environmental Pursuant to 310 CMR 40.0484 (Subpart D) and 40.0800 (Subpart H)

D. PERSON UNDERTAKING RESPONSE ACTIONS:

Release Tracking Number

[ij - 13411

1. Check all that apply: [] a. change in contact name [] b. change of address [] c. change in the person undertaking response actions

2. Name of Organization: Yankee Atomic Electric Company

3. Contact First Name: Frank 4. Last Name: Helin

5. Street 49 Yankee Road 6.

Title:

Decommissioning Director

7. City/Town: Rowe 8. State: MA 9. ZIP Code: 01367-0000

10. Telephone: (413) 424-5261 11. Ext: - 12. FAX:

E. RELATIONSHIP TO SITE OF PERSON UNDERTAKING RESPONSE ACTIONS:

[n 1. RPorPRP [2 a. Owner [] b. Operator [] c. Generator [] d. Transporter LI e. OtherRPorPRP Specify-.

LI 2. Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L. c. 21 E, s. 2)

[I 3. Agency or Public Utility on a Right of Way (as defined by M.G.L. c. 21 E, s. 5(j))

LI 4. Any Other Person Undertaking Response Actions Specify Relationship:

F. REQUIRED ATTACHMENT AND SUBMITTALS:

1. Check here if the Response Action(s) on which this opinion is based, if any, are (were) subject to any order(s), permit(s)

LI and/or approval(s) issued by DEP or EPA. If the box is checked, you MUST attach a statement identifying the applicable provisions thereof.

Iil 2. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the submittal of any Phase Reports to DEP.

3. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the availability of a Phase III Remedial Action Plan.

4. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the availability of a Phase IV Remedy Implementation Plan.

15. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of any field work involving the implementation of a Phase IV Remedial Action.

E] 6. Check here if any non-updatable information provided on this form is incorrect, e.g. Site Name. Send corrections to the SDEP Regional Office.

MV 7. Check here to certify that the LSP Opinion containing the material facts, data, and other information is attached.

Page4of 5 Revised: 04/2212004 Revised: 04/22/2004 Page 4 of 5

Bureau of Waste Site Cleanup BWSC108 Lit COMPREHENSIVE RESPONSE ACTION TRANSMITTAL FORM & PHASEDepartment Massachusetts I COMPLETION STATEMENT Protection of Environmental Pursuant to 310 CMR 40-0484 (Subpart D) and 40.0800 (Subpart H)

G. CERTIFICATION OF PERSON UNDERTAKING RESPONSE ACTIONS:

Release Tracking Number H-7 - 13411 1, ',Frank Helin , attest under the pains and penalties of perjury (i) that I have personally examined and am familiar with the information contained in this submittal, includi ng any and all documents accompanying this transmittal form, (ii) that, based on my inquiry of those individuals immediately resýponsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge an d belief, true, accurate and complete, and (iii) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this submittal. I/the person or entity on whose behalf this subnvittal is made amlis aware that there are signilicaint penalties, including, but not limited to, possible fines and impriso n forf}villfully submitting false, inaccurate, or incor mplete information.

2. By: 3.

Title:

Decommissioning Director

.* Signature

4. For 5. Date: 01, ///, hw-i- I (Name of person or entity recorded in Section D) (mK~ddfyyyy)

LI 6. Check here if the address of the person providing certification is differentfirom address recorded in Section 0.

7. Street

8. City/Town: 9. State: 10. ZIP Code:

11. Telephone: 12. Ext: - 13. FA YOU ARE SUBJECT TO AN ANNUAL COMPLIANCE ASSURANCE FEE OF UP TO $10,000 PER BILLABLE YEAR FOR THIS DISPOSAL SITE. YOU MUST LEGIBLY COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBMIT AN INCOMPLETE FORM, YOU MAY BE PENALIZED FOR MISSING A REQUIRED DEADUNE.

Date Stamp (DEP USE ONLY:)

Revised: 04/22/2004 Page 5 of 5

Appendix B Public Notification Documentation

Environmental Resources Management 399 Boylston Street, 61" Floor Boston, MA 02116 (617) 646-7800 (617) 267-6447 (fax) http://www.erm.com 17 June 2005 Mr. Geoffrey N. Bagley Chairman, Board of Selectmen Rowe Town Hall 321 Zoar Road ERM.

Rowe, Massachusetts 01367 RE: Notice of Availability Amended Phase III Remedial Action Plan/Phase IV Remedy Implementation Plan Yankee Nuclear Power Station Rowe, Massachusetts RTN # 1-13411

Dear Mr. Bagley:

On behalf of Yankee Atomic Electric Company (Yankee), Environmental Resources Management (ERM) has submitted an Amended Phase III Remedial Action Plan/Phase IV Remedy Implementation Plan for the above referenced site to the Massachusetts Department of Environmental Protection (DEP) Western Regional Office. In accordance with 310 CMR 40.1403(3)(e), the Chief Municipal Officer and the Board of Health are being notified of the availability of this submittal.

Information regarding the submittal can be reviewed at:

Massachusetts Department of Environmental Protection Western Regional Office 436 Dwight Street, 5th Floor Springfield, MA 01103 Phone: (413) 784-1100 Fax: (413) 784-1149 Since y, ohn W. McTigue, P.G., LSP LSP of Record

Environmental Resources Management 399 Boylston Street, 6 " Floor Boston, MA 02116 (617) 646-7800 (617) 267-6447 (fax) http://www.erm.com 17 June 2005 Mr. James D. Brown Chairman, Board of Health Rowe Town Hall 321 Zoar Road ERM 0 Rowe, Massachusetts 01367 RE: Notice of Availability Amended Phase III Remedial Action Plan/Phase IV Remedy Implementation Plan Yankee Nuclear Power Station Rowe, Massachusetts RTN # 1-13411

Dear Mr. Brown:

On behalf of Yankee Atomic Electric Company (Yankee), Environmental Resources Management (ERM) has submitted an Amended Phase III Remedial Action Plan/Phase IV Remedy Implementation Plan for the above referenced site to the Massachusetts Department of Environmental Protection (DEP) Western Regional Office. In accordance with 310 CMR 40.1403(3)(e), the Chief Municipal Officer and the Board of Health are being notified of the availability of this submittal.

Information regarding the submittal can be reviewed at:

Massachusetts Department of Environmental Protection Western Regional Office 436 Dwight Street, 5th Floor Springfield, MA 01103 Phone: (413) 784-1100 Fax: (413) 784-1149 Sincerely,

• • cTigue, P.G., LSP

Appendix C List of Supporting CharacterizationDocumentation

APPENDIX C - SUPPORTING DOCUMENTS The following supporting documents are available at www.yankee.com or the Site Closure Information Repository in Greenfield, Massachusetts.

License Termination Documents:

License Termination Plan, Revision 1 - November 19, 2004 Site Closure Documents:

Site Closure Project Brochure Site Closure Project Plan Site Assessment Documents Abbreviated Notice of Resource Area Delineation (ANRAD), March 2004 Archaeological Reconnaissance Survey and Archaeological Resources Management Plant - November 2003 Baseline Environmental Report - April 30, 2004 Phase IV Remedy Implementation Plan - April 23, 2004 Quality Assurance Project Plan (QAPP) - August 6, 2004 Southeast Construction Fill Area Beneficial Use Determination (BUD)

Application - September 2004 Historical Site Assessment Hydrogeologic Report of 2003 Supplemental Investigation - March 16, 2004 Natural Resources Inventory and Management Plan - April 2004 ERM APPENDIX C-PAGE I YANKEE /28054 /6/20/05

Post-Decommissioning Planting Plan - August 2004 Post-Decommissioning Grading Plan and Stormwater Management Analysis - August 2004 Site Characterization Status Report and Appendices - June 4, 2004 Phase II Comprehensive Site Assessment - 28 January 2005 Permitting Documents:

Expanded Environmental Notification Form (EENF) - March 31, 2004 Integrated Permit Package and Appendices - May 7, 2004 Secretary's MEPA Certificate on the EENF - May 7, 2004 Risk-Based Disposal Approval Application (RBDAA) - June 30, 2004 Water Quality Certification - September 9, 2004 Wetland Restoration and Replication Plan - August 2004 Application for Beneficial Use Determination - Southeast Construction Fill Area - November 4, 2004 Southeast Construction Fill Area Corrective Action Design (CAD) -

November 4, 2004 Application for Beneficial Use Determination for Structures - March 22, 2005 Notification and Certification of Self-Implementing Cleanup & Disposal of PCB Remediation Waste, Southeast Construction Fill Area - April 4, 2005 Notification and Certification of Self-Implementing Cleanup & Disposal of PCB Remediation Waste - May 6, 2005 ERM APPENDIX C-PAGE 2 YANKEE /28054 /6/20/05

Appendix D Indirect Thermal Desorption System Information

MAXYMILLIAN TECHNOLOGIES' INDIRECT THERMAL DESORPTION SYSTEM (IDS)

The Indirect Thermal Desorption System (IDS) is a transportable, indirect-fired -rotary desorber, with collection of off -gas organics by condensation. Water from the system is processed through a mobile water treatment system. In the water treatment system, contaminants are removed, concentrated and collected. Treated water is used to cool and remoisturize the treated soil, thereby providing a closed loop for the process water.

Parameters S. System footprint: 70' by 80'

• Soil retention time: 10 minutes

• Operating temperatures: 400-900°F

• Throughput ranges: 10-20 tons per hour at 15% moisture content

• Rapid mobilization penod due to small footprint and structural mobility

• Solid record of successful contaminant removal from soil, gases, and water

• Condense and collect technology; non-destructive

• Limited waste products; closed-loop system

" Commercially available, proven technology.

System Design and Operation Summary The Indirect Thermal Desorption System is comprised of multiple components to treat contaminated soil, debris, and the associated vapor and liquid steam resulting from the treatment process. The system consists of (i) an indirectly heated desorber to remove contaminants from soil, (ii)gas treatment components, including a condenser to remove contaminants from the carder gas, and (iii) water treatment components to remove and concentrate contaminants from the water stream.

The IDS operates at desorption temperatures up to 1400'F, to treat soils contaminated with a range of compounds including naphthalene, BTEX, PAHs and PCBs.

The IDS is a modular, completely transportable system. Individual components are linked together on three separate trailers and controlled by System Operator(s)/Technicians. Also, a separate water treatment trailer will be a part of the treatment system. The IDS has a footprint of approximately 70 feet by 80 feet for efficient utilization of space.

The IDS is comprised of multiple components to treat contaminated soils (feed materials) and the resulting vapor stream. The system consists of:

1. materials feed system;

2. indirectly heated desorber to volatilize contaminants from feed materials;

3. baghouse;

4. materials discharge system;

5. vapor treatment system to filter contaminants from the vapor stream;

6. liquid treatment system to collect, and treat contaminants from the liquid stream.

Soil from the feed area is loaded into a Screen/Feed Hopper via a front-end loader. Soil then travels along a feed conveyor to a feed pugmill, from which it is fed to the indirectly heated Thermal Desorber. In the Thermal Desorber, the contaminants are desorbed as the indirect heat increases the temperature of the soil. Contaminants are filtered and condensed from the carder gas and are treated and removed from the liquid stream. The vapor phase gas stream enters a quench where it is cooled with water; contaminants are further removed incondensers. The gas stream exiting the condensers then enters the Air Pollution Control system, where the vapor stream is treated to further remove contaminants. Vapors are also carried through coalescing filters to remove suspended oil mist, and high efficiency particulate (HEPA) filters for particulate removal. The induced draft (ID)fan maintains a negative draft through the process gas stream. A liquid treatment system treats condensate from the quench and condensers. Once treated, soils are stockpiled and tested to demonstrate compliance with applicable soil cleanup standards.

Permitting In September of 1998, EPA granted Maxymillian Technologies, Inc. a national permit under authority of the Toxic Substances Control Act (TSCA) to operate the IDS. The permit is the first of it's kind in permitting the use of a non-incineration treatment technology to remove PCBs from contaminated soils.

Indirect System Technology Description Overview MT's Indirect System (IDS) is an indirectly fired rotary desorber, with collection of off-gas organics by condensation. The system is fully indirect, using a non-contact heat source and non-oxidation colleetion devices. The system also uses closed loop processes to minimize the waste residuals for disposal. Water and condensate from the system is processed through the primary stages of MT's mobile water treatment system. In this water treatment system, particulate and oils are removed, concentrated, and collected for off-site disposal.

The IDS indirectly heats soil in an enclosed rotary drum desorber where contaminants are volatilized from the soil. Remediated soils are passed through a soil remoisturizing and discharge system and are then stockpiled and tested to verify decontamination. Volatilized contaminants are both filtered and condensed from the carrier gas. Contaminants are then treated and removed from the liquid stream. Remaining vapors are carried through a HEPA filter for particulate removal, then through a vapor phase carbon and another HEPA filter/polymer tray system. An induced draft (ID) fan maintains negative pressure throughout the system during operations.

IDS Components The IDS is a modular, completely mobile system. Individual components are linked together on three separate trailers and are computer operated from a control room by System Operator(s)/

Technicians. A separate water treatment trailer is also a part of the treatment system.

Multiple components of the IDS treat contaminated soils (feed materials) and the resultant associated vapor stream. The system consists of:

" materials feed system, including feed screen, conveyor, weigh scale and feed pugmill

• indirectly heated desorber (or calciner) that volatilizes contaminants from feed materials

• high temperature baghouse

" soil discharge system

• vapor treatment system, that condenses and collects liquid and vapor phase contaminants

° liquid treatment system that collects and treats contaminants from the liquid stream.

The Indirect Thermal Desorption System components are described in the following subsections.

Material Feed System Soil is loaded into the system using a front-end loader that feeds the material into a self-contained hydraulic screen/feed hopper. The soil is passed through a screen, then into a hopper and up a feed conveyor that includes a weigh scale. The conveyor drops soil into another hopper mounted with a feed pugmill to empty soils into the calciner. A soil seal is maintained in the feed pugmill to ensure that ambient air does not enter the indirectly heated desorber. The feed rate into the desorber is monitored from the control room and controlled by variable speed drives. The operator oversees the material as it moves up the main conveyor and discharges to the feed pugmill hopper. If necessary, the soil feed into the desorber can be slowed or stopped from the control room.

Indirectly Heated Desorber From the feed pugmill, contaminated materials are fed through a sealed end plate into the thermal desorber. Once in the thermal desorber, the soil is heated to the temperatures required for sufficient desorption of the soil contaminants. No flame comes in contact with the soil during the heating process. Rather, the heat is transferred indirectly from an outer desorber shell to the inner heating chamber containing the contaminated soil.

The desorber consists of an inner rotating shell surrounded by an outer refractory insulated shell.

The soil is moved via slope and rotation through the 5-foot diameter by 48-foot long rotating shell, which is indirectly heated to the required temperature. Six burners situated along the outside of the shell fire into the annular space between the inner and outer shells. Heat is transferred through the inner shell providing heat indirectly to the soil. The steel outer shell has been insulated to minimize potential heat loss. Shell temperatures throughout the length of the thermal desorber are carefully monitored and controlled. The burner management system operates the burners in three distinct zones to allow precise heating of soil to required temperatures. Both ends of the inner shell are sealed to prevent ambient airflow or cross-contamination into the system.

Vapor Treatment System The gas stream containing volatilized contaminants, vaporized water, and entrained particulate, exits the IDS breach and enters the baghouse. The baghouse is capable of filtering high temperature gases to remove particulate from the gas stream. Maintaining a high temperature in the baghouse prevents condensation and allows clean particulate to be removed from the volatilized waste stream. The clean particulate falls into the soil discharge breach where it is combined with clean material exiting the desorber.

The gases, which are now filtered and essentially free of particulate, exit the high temperature baghouse and enter the quench. Gases are first overspray saturated and then further cooled by recirculated water. Water is drawn from the bottom of the quench sump and recirculated through nozzles at the top of the quench to sub-cool the gases below vaporization temperatures. By sub-cooling the gas stream, steam contained in the gas stream is changed to the liquid phase. This

liquid accumulates in the quench sump, and is drawn off by gravity, as required to maintain an adequate quench water level. The water that is drawn off from the quench is sent through a filter press then to the liquid treatment system. The IDS system is designed to condense and collect the contaminants in the liquid phase at the quench.

Gases leaving the quench are now free of bulk contaminants and contain only trace amounts of contaminants. The remaining air pollution control devices are designed to separate the trace contaminants from the gas stream. Gases leave the quench and enter the condenser. The condenser is a single pass shell and tube design. Non-contact coolant fluid consisting of a water and glycol mixture is supplied by the chiller and routed through the system's condenser. The purpose of the condenser is to reduce the moisture content of the gas stream by further sub-cooling the process gas stream. Any moisture collected from the condenser is routed back to the liquid treatment system. The condenser is designed with an identical standby unit, which can be placed into service without interruption of soil feed, should it be necessary to take the lead condenser off-line.

Upon exiting the condenser, the gases are routed through a pre-filter box into a coalescing filter.

The pre-filter box helps to protect and extend coalescing filter life by trapping any trace, very fine particulate that may be suspended in the gas stream. The coalescing filter is designed to trap very fine oil droplets which might be suspended in the gas stream following the quench and condenser. Any mist or droplets collected by the pre-filter or coalescing filter are routed to the liquid treatment system. Filters are removed and replaced from the pre-filter box, as required, and disposed of with other site residuals.

Process gases exit the coalescing filter cabinet and pass through a High Efficiency Particulate Air (HEPA) filter. This HEPA filter is designed to further polish the gas stream and remove any entrained particulate.

Gases now pass through the vapor phase carbon pre-heater. The pre-heater is a non-contact fin and tube heat exchanger that uses a glycol solution to raise the gas stream temperature. The pre-heater is used under cold weather conditions. The pre-heater reduces the relative humidity of the

gas stream entering the vapor phase carbon bed, eliminating any moisture carryover into the vapor phase carbon bed, and optimizing carbon efficiency.

The vapor phase carbon beds consist of three vessels; each containing 1000 pounds of activated carbon. The vessels are arranged to provide continuous filtering through lead and lag vessels.

The third vessel provides a further polish for the gas stream.

Upon exiting the final vapor phase carbon vessel, the gases are routed through a HEPA filter to capture any carbon particulate escaping the final carbon vessel. Included in the final HEPA filter cabinet is a polymer bed designed to provide a final gas stream polish in the event that there are trace contaminants not absorbed by the GAC system. The gas stream is moved through the system by an ID fan.

The air pollution control equipment and all interconnecting piping are grounded against static electricity. The ID fan is constructed of non-sparking materials with an explosion proof drive system. These safety measures will prevent the possible ignition of any vapors in the gas stream.

Treated Soil Handling System The decontaminated soil exits the thermal desorber inner shell and enters a soil exit breach hopper. This treated soil, combined with clean particulate removed from the gas stream by the baghouse, travels down the soil discharge chute to the base of the bucket elevator. The soil discharge chute is fully enclosed and sealed to prevent fugitive emissions. The bucket elevator vertically transports the soil to the soil cooling silo. The elevator is designed to handle a maximum of 50 tons of soil per hour. From the elevator discharge chute, the soil enters the top of the soil-cooling silo. Soil travels vertically down through the silo and is discharged via a double dump valve at the bottom.

The interior of the silo contains several 8-inch diameter carbon steel pipes. Non-contact ambient air is forced upward through the pipes. The heat of the soil is transferred through the pipes to the non-contact air.

The treated materials exit the cooling silo and enter soil cooling and remoisturization components. Water nozzles located in the pugmill provide soil cooling, and use recycled water

that has been treated in the water treatment system. The IDS is designed to return original water to the soil through a process wherein water and contaminants are driven from the soil, the water is cleaned, and then returned to the soil.

Treated materials exit the discharge pugmill via a hooded radial-stacking conveyor to a processed soil stockpile area to await decontamination verification. Water sprays are located in the hooded portion of the conveyor to provide additional dust control as needed.

Process Control Systems The IDS is operated from the control room. The system's instrumentation controls and data acquisition system (DAS) are automatically controlled and overseen by the Control Room Operator. The control room is a fully-equipped operations station with a temperature controlled climate, as well as phone and field radio service.

A strip chart recorder and the computer DAS constitute the system for performing feedback functions that maintain positive operational control of the IDS. The DAS also serves to record operational data.

The strip chart recorder acts as an interface between operational field points and the computer.

In addition, the strip chart system performs soil feed cutoffs for applicable operating parameters and operational control through relay outputs. Strip chart system functions include:

" Scanning the input data for alarm conditions, annunciating alarms and initiating actions

" Processing data

" Displaying the results on a screen

• Allowing access to the data from the computer The computerized control and data acquisition software serves as the IDS' data acquisition and management system. Communications with the strip chart recorder occur through an input/output driver software system and a serial communications port. The computer monitors operational field point data and acknowledges alarms from the strip chart recorder on the computer screen. This facilitates visual interpretation of the data. Data is archived on the

computer hard drive. The 'software package is used to print reports of data, averages, and display trends.

The IDS is equipped with a number of controls to maintain safe reliable and consistent system.

operations. Monitoring points have been selected to provide applicable regulatory information and process operation data for use by the system operator. Alarms and delays have been incorporated to.minimize disruptions in soil feed operations. Effective system operation will be assured by qualified MT personnel using vendor supplied instrumentation and controls.

Waste Streams MT designed the IDS to maximize the use of non-contact and closed loop systems for heating and cooling process materials. These closed loop systems isolate the contaminated material, which minimizes the waste streams requiring treatment or disposal. IDS operations generate four primary waste streams that are collected, and stored for disposal. Wastes produced from the IDS treatment process include:

1. Filter cake from the filter press.

2. HEPA filters.

3. Expended Vapor Phase Carbon.

4. Condensed oils.

m; :-  ?// m.*I!*L!

• i--?

EXHAUST MATERIAL FEED SAMPLING rH~ILFR 0 -LOCATION I NON-CONTACT FURNACE I EXHAUST

.j-1I, H O I IILQUENCH EiEk -__j S- ATER COL II II SOIL DISCHARGE SYSTEM TREATED W'ATER FRESH W~ATER TO IREMOISTURIZE SOIL 04 PROCESS SOIL STOCKPILE SOIL MONITORINGLOCATION FOR SOIL FEED:

PERFORMANCE TEST: MOISTURE, DIOXINS, VOCO, SVOCs, METALS PROOUCTION: MOISTURE. DIOXINS. VOCv,SVOC., METALS GAS STREAM MONITORINGLOCA11ON FOR POST CARBON: MAXYMILLIAN TECHNOLOGIES PERFORMANCE TEST: DIOXINS%VOC,. SVOC's. HCI, PM. METALS. 02, C02 CLEAN VATER PRODUCTION: OIOXINS, 02. 002 - 1 PER MONTH 1801 EAST ST., PITTSFIELD, MA 01201

-

• QUENCH RECYCLE IWATER MONITORINGLOCATION FOR OESORBEIR VENT:

PERFORMANCETEST: CO. THC. 02 TDS - PROCESS FLOW DIAGRAM PROOULC:ON: NONE REQUIRED .DRWN. WPL REV. DESCRITON DATE I -* NON-CONTACT DESORBER MONITORINGLOCATION FOR TREATED SOlIL FUEL / EXHAUST STREAM NON-CONTACT CHILLER VATER PERFORMANCE TEST:-MOSTURE. DIOXINS. VOC*, SVOCs, METALS PRODUCTION: MOtSTURE. DIOXINS, VOC., SVOC@,METALS APP. JHM I YANKEE ROWE REMEDIATION CONTAMINATED WATER FIG.

GE SOUTH GLENS FALLS DRAG STRIP SOIL REMEDIATION PROJECT Maxymillian Technologies (MT) mobilized its Indirect Thermal Desorption System to remediate approximately 14,000 tons of PCB contaminated soil under US EPA TSCA approval and regulation. During the 1960's, the unpaved areas of this 40-acre, former drag strip racing site had been repeatedly sprayed with PCB-containing oil to control dust. MT's scope of work included site preparation, erosion control, clearing, grubbing, IDS pad installation, site security, excavation, thermal soil treatment and water treatment using MT's transportable Series III Water Treatment System.

Based on MT's preliminary demonstrations, the US EPA classified the Indirect System as an Innovative Technology. This enabled MT to performed a full-scale Demonstration Test, Performance Test and associated Research and Development. MT conducted the highly successful tests under TSCA approval using contaminated soil from the site and varying infeed and operating parameters. Following the Demonstration Test, MT commenced and completed full-scale remedial operations to cleanup the site.

FAIRGROUNDS AVENUE SOIL STOCKPILE REMEDIATION Maxymillian Technologies (MT) thermally treated two contaminated soil stockpiles under MA DEP Release Abatement Measure (RAM) and Immediate Response Action (IRA) contracts. MT treated soil with the MT-designed and operated Indirect Thermal Desorption System. The scope of work for both projects involved:

mobilizing the IDS to the stockpile site, on-site thermal treatment of PCB and VOC-contaminated stockpiled soils, and using MT's Series III Water Treatment Unit to treat the contaminated condensate. Clean water from the Series III was used to remoisturize and cool the treated soil, which was then reused for the site's grading

ýnaterials.

During installation of a utility line, MT discovered buried drummed waste. MT was contracted to excavate, characterize, categorize and dispose of over 450 drums of waste that contained PCBs and TCE.

The first batch of approximately 4,000 tons was contaminated at levels of 1500 ppm for Polychlorinated Biphenyls (PCBs) and 100 ppm of Volatile Organic Compounds (VOCs). MT collaborated with US EPA to conduct a Toxic Substances Control Act (TSCA)

Demonstration Test in September 1997, midway through the first RAM contract stockpile remediation project. All treated soil results for contaminant levels were below the required limits for PCBs and VOCs. The emissions results from the system far exceeded the established standards for PCB destruction and removal efficiency and for all other parameters.

After successfully processing the original 4,000 ton stockpile, MT re-contracted under a MA DEP IRA to thermally treat a second PCB and VOC-contaminated stockpile of approximately 5,000 tons. Total PCB concentrations ranged from about 920 mg/kg to 3,100 mg/

kg. The IDS successfully treated all contaminated soils to acceptable regulatory cleanup standards.

Client: Confidential Consulting Engineers: Blasland, Bouck &Lee Engineers Location: North Adams, MA Project Managers: John Anthony Anthony Pisanelli

LOCKHEED MARTIN ASTRONAUTICS SOIL REMEDIATION PROJECT Foster Wheeler Environmental contracted Maxymillian Technologies (MT) to remediate 21,342 tons of VOC and PCB contaminated soil with a transportable Indirect Thermal Desorption System (4DS). MT also used the transportable Series III Water Treatment System to treat resultant liquid waste streams. The Lockheed Superfund site was contaminated with oils, solvents, and metal finishing wastes during site operations occurring from 1959 to 1980.

-' -~ t:

After receiving the Notice to Proceed on August 28, 1998, MT took only 15 calendar days to assemble the IDS, perform clean and contaminated shakedown, and complete the Proof of Performance Test (POP).

Treated soil and emissions measurements (shown in the following table) surpassed all site treatment standards and requirements of the Colorado Department of Public Health and Environment Air Permit for the IDS. The emissions limits were especially stringent because they were added to existing emissions of the Lockheed Martin facility that required the entire facility to stay within their permit as a synthetic minor source. The on-line factor of the IDS during the Lockheed project was 90% and the average feed-rate was 14 tons per hour. MT completed extensive soil operations inonly 5 months time.

LOCKHEED MARTIN SUPERFUND SITE - EMISSION MEASUREMENTS 10.0016 gr/dscf@7%02 HCI <0.00025 lb/hr SVOCs <0.00028 Ib/hr PCBs 7.77 E-08 lb/hr PCDD/F <0.034 ng/dscm @ 7%02 VOCs 0.0283 lb/hr 99.99989 Control Removal Efficiency CO 3.4 ppmv @ 7%02 THC 1.7 ppmv @ 7% 02 Client: Lockheed Martin Astronautics Consulting Engineers: Foster Wheeler Environmental Location: Littleton, CO Project Manager: Anthony Pisanelli

BOSTON CONVENTION CENTER REMEDIATION PROJECT Maxymillian Technologies (MT) was contracted by the Boston Redevelopment Authority to conduct fast tracked contaminated material treatment/disposal for the future Boston Convention & Exhibition Center. The site was located in a heavily populated industrial/urban area of South Boston and involved daily, intensive interaction with EPA and MA Department of Environmental Protection (MA DEP) regulators. This site cleanup was part of a public sector, highly fast-tracked brownfields project that had never before been attempted inNew England.

This site was formally operated as a recycling facility that handled transformers and scrap metal. The primary contaminants were Polychlorinated Biphenyls (PCBs), lead, and solvents. Prior to conducting demolition work, MT dt Inirc Sytmagis characterized, categorized, consolidated and disposed of several unknown drums.

theBsto sklie MT segregated, thermally treated, and disposed of 6000 tons of contaminated soils and debris. This  :*,

involved TCLP Lead stabilization of soil and -

debris. MT also mobilized their Water Treatment System to treat ponded waters and dewatering liquids. The site was restored for future use after 7-7:

placing a temporary soil containment cap. At - -F several stages during the project, community concerns prompted MA DEP and EPA to request additional data and air quality management. MT worked closely with the regulators to develop a timely response which satisfied all parties involved.

MT maintained a highly accelerated, City-imposed schedule to meet Convention Center deadlines, that was initially considered unrealistic - even to the Owner. To successfully achieve this schedule, MT used rail cars that were site below Foam appicaio to coto odr an dust, accessible, worked weekends, and operated the thermal system 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. Inaddition, to work within the limited available land area, MT conducted several site activities simultaneously, under very tight spatial constraints. In choosing on-site thermal treatment, the client saved $6.5 million in hauling/treatment costs. MT's successful project completion reinforced a 30 year company reputation of highly responsive and reliable service.

Remedial Site Operations:

- Site clearance (i.e. clearing and grubbing the site vegetation).

• Removed and treated ponded surface water.

• Segregation and off-site disposal of 6000 tons of contaminated soils and debris.

• Thermal treatment of several thousand tons of contaminatedsoil using the Indirect DesorptionSystem (IDS).

• TCLP Lead stabilizationprocessof soil anddebris.

• Water treatment using system of. filter press, Rosedale filters, polymer bed, and liquid phase carbon treatment.

• Direct rail transport of treated soil and debris to rail served disposal facilities.

• Placeda temporarysoil containment cap.

• Restored site for future Convention Center activities.

M a E." Client: Boston Redevelopment Authority u Or Consulting Engineers: Weston &Sampson Engineers, Inc.

Location: Boston, MA Project Managers: Anthony Pisanelli

. Alan Steinhoff

PENNY'S BAY, HONG KONG DECONTAMINATION WORKS SITE Maxymillian Technologies, Inc. (MT) teamed with Leighton Asia Environmental Services Ltd.

(LAES) to perform remedial action at the former Cheoy Lee Shipyards site at Penny's Bay on Lantau Island in Hong Kong. LAES managed the overall site remediation, while MT provided technical assistance and thermal treatment equipment.

The fast-tracked site remediation is part of the Disneyland Theme Park construction by Hong Kong International Theme Parks Ltd. The Shipyard operations on the 19 hectare parcel of reclaimed land commenced in 1964, and lasted until the recent site decommissioning process began.

MT processed 54,000 tons of contaminated soils through their TSCA permitted, Indirect Thermal Desorption System (IDS). The IDS is a transportable, indirect-fired rotary desorber, with collection of off-gas

• .- . organics by condensation. It consists of a feed preparation system, indirectly heated desorber, emissions control system, treated soil handling system, water treatment system, and associated controls and monitoring equipment.

An Environmental Impact Assessment was conducted

.. by Maunsells in 2002 to assess cleanup methods and their potential health risks. Site Assessments discovered the primary site contaminants to be dioxins, metals, and TPH/SVOCs. The IDS treatment system operation was assessed to fall well below the Federal guideline risk value.

Prior to full-scale treatment operations, MT conducted a rigorous and highly regulated Compliance Test Program (CTP). Although the IDS has a longstanding and proven track record, the CTP ensures that system parameters treat site-specific materials in accordance with license conditions. The CTP includes Process Instrument Calibration Tests, Shakedown Test, Evaluation Test, Continuous Emissions Monitoring Performance Specification Test, Proof of Performance (POP) Test, Post POP Test Confirmation testing. Based on the CTP results, the Environmental Protection Department (EPD) granted LAES the license approval to conduct remedial operations.

Client: Government of Hong Kong, China Consulting Engineers: Leighton Asia Environmental Services Location: Lantau Island, Hong Kong Project Manager: Gary Polumbo

Appendix E YNPS ProcedureDP-8120 Collection of Site Characterizationand Site Release Samples

Proc. No. DP-8120 Rev. No. 8 Issue Date .. 02/2004 Review Date 05/2006 COLLECTION OF SITE CHARACTERIZATION AND SITE RELEASE SAMPLES SCOPE To provide instructions for the collection of surface'and subsurface soils, shoreline sediments, asphalt and liquids. This procedure also provides instruction for the collection of soil, asphalt and concrete from ongoing or completed excavations, and the decontamination of equipment used to collect the samples. This procedure is intended to be used during the decommissioning period for both radiological and nonradiological site characterization and site release- sampling.

Concrete core sampling is addressed in Procedure<DP-8121.

Split spoon sampling is addressed inProcedure DP-8122.

Pond sediment sampling is addressed in Procedure DP-8124.

Groundwater monitoring is addressed in Procedure DP-9745.

ENCLOSURES DP-8120 Pgs. 1-10 Table1 -Pg. 1 Appendix A - Pgs.. 1-4 Appendix B - Pgs : 1-2 DPF-8120.1 - Pg. 1

• DPF-8120.2 - Pg. 1I REFERENCES

1. DP-8121, "In-Plant Radiological Surveys to Support the RadiologicalCharacterization Program"

2. DP-8123, "Sample Custody and Control"

3. Deleted

4. EPA/625/12-91/002 "Description and Sampling of Contaminated Soils

- A Field Pocket Guide" 5.- EPA/600/R-92/128 "Preparation-of Soil Sampling Protocols: Sampling Techniques and Strategies"

6. 40 CFR Part 136

7. SW-846, "Test Methods for Evaluating Solid Waste", USEPA 3rd edition, March 1995.

8. .OP-8100, "Establishing -and Posting Radiological Areas"

9. DP-8813, "Sample Receipt and Preparation" 10,. AP-0052, "Radiation Protection Release of Equipment, Material and vehicles" a 11i AP-0227, "Condition Reporting, Investigation and Self Assessment" 12, AP-0221,' "Plant Record Management" -"

13. DP-9508, -Tritium Analysis of Concrete and Soil" DISCUSSION Environmental samples are collected from surface soils, subsurface soils, sediments, asphalt, and liquidstoidentify a media's contamination status for site characterization and'site release

. purposes. Soil, asphalt and concrete stockpiles will be sampled to determine their final disposition (e.g., soil for'back fill or release, asphalt and concrete for free release). The-type of sample to be collected (e.g., grab, composite, etc.). and. the suite of contaminants for which it will be analyzed should be identified in the field sampling plan. All samples will be prepared for analysis in accordance with DP-

DP- 8120 Re v. 8 8813 [91 Free release of soil, asphalt and concrete will be in accordance with AP-0052 [10]. This procedure addresses the steps to collect each.type of sample..

Quality control measures will be an integral part of all activities related to obtaining and testing of samples. These measures are intended to, help. assure the. accuracy of all data. They include:.-

Implementation of all work based on written procedures

• iDirection.and documentation of all-activities by a cognizant engineer Performance of key activities by individuals qualified to carry out such activities

• Precautions to prevent cross-contarhination of samples

• Verification: of analysis results by an independent laboratory

• Use of analytical laboratories with QA/QC programs

• Chain-of-custody documentation of samples.

PRECAUTIONS

1. All samples collected from within the Radiological Control Area (RCA) will be initially handled as if contaminated. A GM frisker will be used to periodically screen equipment and newly-collected samples for gross contamination. If radioactivity is detected above background. Label the sample as "Caution Radioactive Material" in accordance with OP-8100 (8] and take the necessary precautions to prevent the contamination of other samples, equipment or personnel.

2. Latex, nitrile or equivalent gloves shall be worn when handling sample. material collected -from on.site, and when cleaning tools that were used in.the collection of- those samples. Clean gloves shall be used at each new sampling site.

3. When collecting samples in the RCA, hands and feet should be periodically monitored for contamination with a GM frisker.

4.>. For safety purposes, .holes in concrete floors, soil or asphalt shall be patched or filled as soon as practicable.

5.. For major excavations a Job Hazards Checklist will be completed and reviewed with the Safety department.

6. Methanol is flammable, do not use in the presence of open flame or ignition sources.

PREREQUISITES

1. Each tool coming in contact with sampling media or any other potentially contaminated surface must be decontaminated prior to the collection of the next sample.

2:. The. type of sample being collected will determine which tools and materials are needed. Given below is a list of-suggested tools and materials to choose from:

Site map 0 Chain of custody forms (DPF-8123.1) 0 Field Log Book 0 Location marking supplies, ,e.g., spray paint and stakes 0 50 or 100-foot tape measure 0 Digging implements, e.g., trowel or shovel Soil auger 0 Soil core sampler 0 Sample containers, e.g., -"ZipTop" plastic bags or paint cans Plastic bags (approx. 10 gal. size) for vegetation collection 0 Aluminum Foil S Hammer drill or demolition tool, with chisel. or* asphalt bits 0 Hearing and eye protection S Leather gloves.,:

DP-8120 Rev. 8 a Grass clippers.

• pruning shears

• Indelible pen

.* Latex (or equivalent) gloves

• GM frisker

• Equipment cleaning supplies:

Clean water Brushes Laboratory grade detergent (such as Alconox)

Paper. towels . .

Trash bag. for solid waste Methanol

- Concrete:coring or cutting equipment:

Drill rig, bits and extensions Hilti drill and bits.

Water hose Electrical extension cordi w/.GFCI Adjustable wrench, hammer Hearing.and eye protection PROCEDURE A. SAMPLING CONTAINERS, PRESERVATION REOUIREMENTS. AND HOLDING TIMES FOR SOIL AND LIQUID SAMPLES The type of. sample container, volume required for analysis, and the maximum-holding time. for various-constituents and media are presented in Appendix A.'

)-

B. SOIL and SEDIMENT SAMPLING, NOTE: These sampling-..techniques are not appropriate for soil and sediment collected for-Volatile Organic Analysis (VOC). In addition, stainless steel tools or equivalent are to be used

ýýfor the-collection of samples for nonradiological analysis.

I.- If soil is under a paved area or concrete floor, remove the asphalt or concrete.

.a.. If an asphalt sample is to be collected, perform Section C before proceeding -to step B.3.

b. If a concrete sample is to be collected, refer to r .Reference 1. -

.2. if required, cut vegetation to approximately the soil surface level, and remove any "litter" on the ground surface (e.g., stones or dead/dry sticks and leaves that are not part of the soil humus layer).

NOTE:- If. desired, cut vegetation may be saved for a separate analysis. In such a case, cut the vegetation over a

- measured area (e~g., one square -meter), recording that area in the Field Log Book and place in a plastic bag.

3. Using a new or decontaminated'(according to Section H of this procedure) stainless -steel or equivalent tool (i.e.

trowel, shovel, hand auger, etc.), remove soil or'sediment at the selected sampling location (or locations for -

composite sampling) to the desired depth. -

DP-8120 Rev. 8 NOTE: Ideally enough soil should be collected to provide for a one liter sample after preparation.

NOTE: For soil. samples collected outside of the Owner Controlled Area, dig a straight-sided hole with measured surface dimensions (e.g., 6" x 6") and record in the Field Log Book.

4. Place the sample into the appropriate container as specified in Appendix A. Ensure sufficient sample has been collected.

a. If additional soil or'sediment "is required due to the number and volume of-samples: that must be collected, obtain the soil or sediment from a location immediately adjacent to the first by following steps 1

.. through, 3.as necessary'and remove a similar amount of sample.

b. Composite samples collected for nonradiological analysis should be mixed in a stainless steel bowl or ziptop'plastic bag.-:,

5. Large sticks or rocks greater than approximately three inches in size should be discarded while digging the sample, unless otherwise instructed. Compensate for the lost volume at that depth by collecting additional sample from the. same- depth as the discarded, rock/stick.

NOTE: Where a large rock(s) prevents the collection of an adequate sample:, the sampling point should be moved slightly to allow a better sample. In such a case, the movement and. its reason should'be noted in the Field Log Book.

NQTE: Sticks and rocks less than three inches in size must remain in the sample. They will typically be removed

.:at the laboratory during the sample preparation stage.

Their weight will -be -accounted for at that time.

6. If required by Appendix A,,preserve samples accordingly.

.7. Close the container to prevent loss of material.

8. . Label the container with the sample identification number

.(or bar code label) , date of collection, time of collection, type of analysis (if non-rad), preservation method (if non-rad), and sampler's initials.

9. Ensure that the sample is secure and that the appropriate sample custody documentation (if required) is completed in accordance with DP-8123 [2]. as soon- as practicable.

C. ASPHALT SAMPLING NOTE: Ideally enough asphalt should be collected to provide for a one liter-sample.after preparation.

1. Using a hammer drill or demolition tool (with the appropriate bit), a cold chisel, or any other appropriate tool, cut a circular hole in the asphalt through its entire thickness.

2. Break up the asphalt sample into small pieces with the hammer drill..

DP-8120 Rev. 8 NOTE: Be careful- when breaking up the asphalt pieces with a power tool so that excessive mixing of- the asphalt rubble with the upper layer of soil does not occur.

3. Remove the asphalt pieces, taking care to minimize any dirt clinging to the pieces. Place in a suitable container.

4. If required by Appendix A. preserve accordingly.

5. Close the container.

6. Label the container with the 7ample identification niiinber" (or bar code label), date of collection, time of collection, and sampler's initials.

7. Ensure that the sample is secure and that the appropriate sample custody documentation (if required) is completed in accordance with DP-8123 [21 as soon as practicable.

.D. LIOUID SAMPLING

1. Using the appropriate sample collection container as identified in the Table in Appendix A, collect the sample directly into the container without pre-rinsing from the liquid.

2. Submerge the lip of the sample container below the liquid surface, filling the container until a slight headspace is present. Remove from the liquid and cap.

3.. Samples collected for volatile organic analysis (e.g.

VOC, pesticides)- must contain no headspace or air bubbles after capping. To-collect these samples:

a. Collect the sample in a separate unused container.

b. Pour the water to the appropriate container using a continuous -stream into apre-preserved container; do not overflow.

c. When the container is full and a meniscus is present, cap the container and turn the container upside down and inspect for bubbles.

d. If bubbles are present, remove cap and add sample to

. re-establish meniscus prior to capping. Repeat as necessary.

4. If required by Appendix A, preserve accordingly if not previously provided.

5. Label the'container with the sample identification number, date of collection, time of collection, and sampler's initials; G6. Ensure that the sample is secure and that the appropriate sample custody documentation. (if required) is completed in accordance with DP-8123 (2] as soon as practicable.

DP-8120 Rev. 8 E. IDENTIFICATION OF SAMPLING POINTS 1 If not already described in a sampling plan, describe the location of the sampling site in the Field Log Book by one of the following means:.

• Distance measurements to two or more structures (or other identifiable points)

Detailed drawings

• Reference to a grid coordinate system

• Global Positioning System (GPS) measurements

• Any other equivalent mdt-hod.

2. Mark the sample location with a semi-permanent marker (e.g.,

wood stake) when one of the methods in step I can not be used to identify the:sample location;

3. A revised sample location code. for: radiological samples will be effective with Rev 7 of this procedure. The Safety Oversite Manager or designee will assign the first nine characters in the Location Code for each survey unit material listed using.Table 1, Survey Location Codes and Appendix B, Survey AreaDescription,- as guidance. The Location Code is composed of a 12 -character alpha numeric string as follows:

Characters 1-5 = Survey Area Identification Character 6 Survey unit Code Character 7 Survey. Unit Classification. Code' Character 8 = Survey Type Code Character.9 = Material Code Characters 10 -,12 = Survey Point F. SAMPLING SOIL. ASPHALT, AND CONCRETE FROM EXCAVATION STOCK PILES

1. STOCK PILE SEGREGATION AND IDENTIFICATION:

a. Ensure that individual-piles of soil, asphalt, and concrete are segregated on the following bases:

1) Area. of excavation - Soil, asphalt, and. concrete excavated from- any-single area should be kept segregated from other piles until final disposition. Any pile consolidation must be documented.

S2) Type of material- Soil should be segregated from asphalt, concrete should be segregated from soil or asphalt. Other materials (e.g., wood, rebar, metals, or construction debris) are not addressed. in this procedure and should be separated from the soil, asphalt and concrete.

3) Contamination potential - Any soil, asphalt, or concrete known or suspected to be contaminated should be segregated; placed onto a poly tarp and sampled separately. This may be based on site characterization or other survey results, or on knowledge of the area's previous activities. Since site characterization surveys

DP-8120 Rev. 8 have shown that soil contamination in the RCA is' generally limited to the top six inches, initially, the top'six-inch layer approximately should be segregated and sampled separately when excavating within the RCA.

b. The Safety Oversite Manager or designee will assign a unique number to each soil, asphalt, or concrete stock pile, log the number and other pertinent information on form DPF-8120.1, and provide the number to the RP Technician performing the sampling.

A revised pile numbering system will be effective with Rev. 7 of this procedure. The new system will consist of a 14 digit field starting with a P, designating Pile; followed by a 4 digit field for the year; a five digit field for the survey Area ID code; a two digit field for pile type (TS for soil, AS for Asphalt, CT for concrete); and a two digit sequential pile number.

This method retains all of the features of the old system while~adding the Survey Area ID so that the pile number identifies the origin of the excavated material.:

For example; P20000G021TS04 is the fourth soil pile from survey area OG021 assigned in year 2000 P20000GO21ASOI is the first asphalt pile from survey area 0G021 assigned in year 2000 NOTE: Form DPF-8120.1 will be controlled by the Safety Oversite: Manager or his designee.

A

c. Prepare a suitable map to identify the location of each pile. Label the map with the pile number.

d. Write the pile number (obtained from the Safety Oversite Manager or designee) on two wooden stakes (with a Sharpie or other indelible pen) and drive the stakes solidly into the pile (front and back).

e. Cover each pile with a tarp to minimize the migration of potential contamination due to the forces of wind and rain, etc.

f.. Where a. pile is placed on a slope., place bales of hay or silt fence on the down-slope side to' catch any run-off.

NOTE: In the event .that piles are moved, the Safety Oversite Manager or designee should be notified so that the pile's location can be tracked,- and to ensure that the pile is clearly labeled in its new location. The new location should be noted on Form DPF-8120.1.

2. SAMPLING FROM AN EXISTING PILE:

a. If. the pile is large enough to make access to the inner volume of the pile difficult, split the pile into two or more sub-piles (e.g., with a backhoe) to.

allow access.-

) -

DP-8120 Rev. 8

b. Collect approximately 30 samples of at least 100cc each,. placing the samples into a plastic bag (more than one (1) plastic bag will be needed). In addition to the pile's unique number the plastic bags will be numbered "I of ##" i.e., 1 of 2, 1 of 6, etc.

NOTE: A roughly determined grid should be used, and a

• shovel should be -used to allow sampling at varying depths. The goal is to systematically (i.e., uniformly) sample throughout the entire pile volume. Use a Hilti drill as necesAary.to break up the aspidlt and concrete into small pieces. Every effort should be made to ensure that one third of the samples collected are from

• the surface of the asphalt being excavated.

c.. During sampling of soil piles, remove and return to the pile rocks and sticks. greater than approximately M inch in size. For asphalt and concrete samples, such rocks bound up in the asphalt or concrete may be removed later during sample preparation.

NOTE: If any large man-made objects are encountered during sampling (e.g., barrel rings, sheet metal), remove them from the pile for separate monitoring. (Monitoring and disposition of this material is outside the scope of this procedure).

3. SAMPLING DURING EXCAVATION:

a. By talking to the excavating contractor, determine how often samples need to- be collected to achieve 30 samples from each excavation/pile. A "pile" will consist of no more than approximately 15 cubic yards of soil, asphalt, or concrete.

NOTE: Multiple "piles" may result from a single excavation,. based on the criteria in F.1.

b. At the frequency determined above, collect inaividual samples at least 100cc each directly from the bucket, placing all of these samples in a plastic bag (more than one (1) plastic bag will be needed). In addition to the stock pile-'s unique number the plastic bags will be numbered "i of ##1" i.e., I of 3, 1 of 5, etc.

NOTE: When the excavation is completed, 30 or more samples should have been collected from each stock pile.' If not, collect enough additional samples from the stock pile (sample uniformly through the pile's volume) to achieve 30 samples.

c. During sampling, remove and return to the pile rocks

.and sticks greater'than approximately H inch in size.

For -asphalt or concrete samples, such rocks bound up in the asphalt or concrete may be removed later during sample preparation.

NOTE: If any large man-made objects are encountered during sampling (e.g.,. barrel rings, sheet metal), remove them from the pile for separate monitoring. - (Monitoring and disposition of this

DP-8120 Rev. 8 material is outside the scope of this procedure).

G. SAMPLE DOCUMENTATION AND HANDLING S1. If the samples are part of site characterization:

a. Record all appropriate-information in the Field Log Book. As a minimum, include:

Sample date S7.. Sample time

• Sampler's name(s)

I Sample location identification code/pile number

.- Sufficient description and/or measurements to allow the sampling-site to be identified in the future. ,

. map of area excavated and pile placement as appropriate .

b. Any deviations from this procedure -that are forced by field conditions (e.g., large rocks or ledge obstructing sampling, etc..) should be noted here.

c. Record sampling information on DPF-8120.1 and DPF-8120.2 as appropriate.-

2. If the samples are in support of site release, record sampling information in accordance with AP-0052 [10].

3. Deliver or arrange delivery of the samples to the designated sample prep or storage location, the DE&S Environmental Lab (DESEL) or another off-site analytical facility.

a. Ensure that a tamper evident seal is affixed to each sample container. Seals shall be initialed and dated by the preparer..

b. For samples submitted to the DESEL, complete form YELF 605.1 and send it with the samples.

c. Fill out a chain of custody form in accordance with DP-8123 "[2].:'"  : " ":

d. Contact the Radwaste Coordinator for -the shipment of any sample(s) containing plant-related radioactivity to any off-site facility.

H. DECONTAMINATION OF EQUIPMENT NOTE: Decontamination is performed in three stages, generally by using three buckets as described below. The same method may be used. in a sink, if available, as long as the same three-step process is used and the drain line is suitably connected for radioactively contaminated waste. The first container is used for removal of gross residue and scrubbing with detergent. The second container, half-filled with clean water, is used for the first rinse. The third container,

) 'bottle, initially empty, is used to collect the.rinsate from a spray and is generally used only in areas where

DP-8120 Rev. 8 contamination is suspected. Determine in advance whether the decontaminated, tool is to be sprayed. with methanol as a final step (non-radiological analysis only).

1. Set up three 5-gallon containers as follows:

a. The first container is half filled with water and a small. amount of laboratory grade detergent (such as Alconox).

b. The second container is half-filled with clean-water.

c. The third container is initially empty. (This container is not needed in areas where contamination is not suspected, e~g., outside the Radiological Control Area.)

2. Don a new pair of latex, nitrile or equivalent gloves.

' 3. Remove any gross residue from the sampling tool, letting the material (e.g., soil) fall into the hole from which it was sampled. If the sampled hole is not immediately available, save the material for appropriate waste disposal. If the tool had last been used outside the Owner Controlled Fence, the material may simply fall onto the ground.

4.. Place the used sampling tool in the first container and scrub.with a brush .

5. Remove the tool from the first bucket and place the tool in the second bucket. Scrub with another brush.

.6. Holding the tool over the third. container (or over the

'ground if in an area where contamination is not suspected, e.g., outside the Radiological Control Area), completely rinse the tool with..a squirt. bottle. of Methanol or clean water.

7. Wrap the cleaned tool in new aluminum foil.

8... Remove the gloves and dispose of appropriately.

9. Place the decontamination fluids into a container labeled

."Decontamination Waste". Disposal should be based on a representative sample and analysis of the water, or as prescribed by the Radiation Protection Department.

FINAL CONDITIONS

1. Samples have been collected and delivered to the appropriate laboratory.in accordance with this procedure.

2. At the discretion of the Sample Manager/Senior Chemist, the YAEC Condition Reporting System, as-defined in -APýO22-7 .[.11], has been initiated to report and evaluate adverse conditions potentially affecting data qualityand to track corrective actions through completion..

3. Documentation has been reviewed and retained in accordance with

-AP 0221. .[12. ,..

0

ow Aw -) low/ 0 - ... - -1

-I1-Rev. 8.

Table I Table*I - Survey Location Codes 2

1 4 S 6 7 9 101 2 x ..... , X X . #

Survey Area ID Code Survey Unit Coda Survey Unit Classification S.urvey Type Code Survey Material Code . Survey PFint Code See Survey Area A - Upper Waliae/Ceiling A - Kffected C - Characterisation A . Asphalt (Exterior) Numbered

.List S .Floors/.9oer .Walls N . Non-Supeet. Affected F

• Final Status B - Poured Concrete Floor l1' Sequentially C - Ceiling S . Suspect Affected . . - General information C - Concrete D - Sub Ploor U - Unaffected I - Investigation 0 - Soil (Disturbed) 900 SQries Sample 2 . Equipment 1 Class I M - MARSSIM B . Poured Concrete Wall' Numbers Raeserved F - Ploos 2 - Class 2. R - Free Release F - Poured Concrete Floor' . . for QA Samples 0 OrO.du "s 3 Class 3 . S- special a - Generic.

S. L ower W8s11.. 4 - Non-IZspacted; T - Turnover H . Block Wall' P - pile, X NA I - Ignored

'. S System *

• Generic',2 U . Upper alls* K Generic

-X Structural Exterior L - Sediment (Silt)

H - AsApalt (Interior)

N 'Sediment (Sand)

O Other.

P - Porcelain

. - Acoustic Ceiling Tile R

• Roof Material S -Poured Concrete Floor W2' T

• Poured Concrete Floor 1,11 U. Soil (Undisturbed)

V . Poured Concrete Ceiling .1'

. . Water X .- Poured Concrete Ceiling L2' Y* Poured Concrete Ceiling L3' 2 Generic Li.......

Survey material codes used for-the Turbine Building survey units Survey material code used for the interior surfaces of System survey areas Piles of Soil, Asphalt or ConCrete

O)P-8120 AppendIx A Ra,. e RE.,XREMONT8 VOt MMTAINERS, PRESERVATION TECRNIOUES. SAHILE VOLUMES, AND HOLDING TIMkS (Ref. 7)

_ _ _ Name Container Preservation b,__,d MinimumorSample Volume Weight Maximum Holding Time

-Alkalinity G 4C 100 ml 14 days Common anions PG None Required 50 ml -28 Days for Br- F-, and SO,'2, 48

.... __hours .. for N03', NO,-, and PO,4 Cyanide,total and P,G,T 4*C;NaOH to pH>12, 500 ml each 14 days (water and soil) amenable to 0.6g ascorbic acid chlorination

.ilterable residue P,G 4C 100 ml 7 days 0

Nonfilterable residue P,*G 4 C 100 ml 7 days Hydrogen ion (pH) . ,G None required N/A Analyze immediately Nitrogen, nitrate + PoG 46C, HISO 4 to pH <2 100 ml 28 days Conductance., PG None required 100 ml .28 days Temperature P,G None required N/A Analyze immediately Dissolved oxygen G None required 500 ml Analyze immediately Turbidity PG 40C 100 ml 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Settleable Solids PG None required 1000 ml 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> Total organic.carbon P,G,T 4*C, HCI or H2SO4 2S ml or 10 g 28 days (water and soil).:

to pH <2* _" '

Chromium (VI) P,G,T 46C 200 g 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (water and soil)'

Mercury P,G,T .HN01 to pH <2, 41C 100 ml or 10 g 28 ..days (water and soil)

Metals (except chromium P,G,T HNOj to pH .<2, 46C 200 ml or 10 g 180 days (water and soil)

(VI) and mercury) (I liter or 500 g Includes .Radiological * ' for radiological)

I Radionuclides d, e P,G HN03 or HCI to pH

<2.0 .

1 liter or 500 g 90 days

a. Polyethylene (P); glass(G): brass sleeves in the sample barrel, sometimes called California brass (T).

b. -No pH adjustment for soil.

c. Preservation with 0.008 percent NAISzO, is only required when -residual chlorine is present.

4. Samples for radionuclides do not need to be cooled to 40C unless the time to analysis is greater than about 2 weeks.

e. " Do not acidify samples to be analyzed for carbon, tritium or iodine. Determine preservation requirements from contract laboratory for these analyses.

f.. The maximum recommended holding time for completion of extraction into water is 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. The extract shall be analyzed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of completion-of extraction.

Appew.e- A Rev, 8 Name Container Preservation Minimum Sample Maximum Holding Time Co e Pre o Volume or Weight Total petroleum G, Teflonr - lined 4ýC,HCl to pH<2 2 x 40 ml or 4 14 days (water and soil); 7 days if hydrocarbons (TPH) - septum, T ounces unpreserved by acid volatile Total petroleum Gamber,T 40C 1 liter or 7 days until extraction and 40 days hydrocarbons (TPH) - 8 ounces after extraction (water): 14 days extractable until extraction and 40 days after

. .. . ._ _ _ _... .e x t r a c t ion (s o i l )

Volatile aromatics 0 G, Teflon* - lined 4 C, HCl to pH<2, 2 x 40 ml or 14 days (water and soil); 7 days if

__ _ _ septum,T 0.008V Na2S20 4 ounces unpreserved by acid Halogenated volatiles G, TeflonO - lined 40C, HCl to pH<2, 2 x 40 ml or 14 days (water and soil); 7 days if septum,T 0.008% Na 2S2 O3 4 ounces unpreserved by acid Nitrosamines G, Teflon - lined cap, T 41C 1 liter or 10 9 7 days until extraction and 40 days after extraction (water); 14 days until extraction and 40 days after

.... __ extraction (soil)

Chlorinated herbicides G, Teflon - lined cap, T 40C, pH 5-9 1 liter or 10 g 7 days. until extraction and 40 days after extraction (water); 14 days

__ _ _extraction

__ - until extraction (soil) and 40 days after

a. Polyethylene (P); glass(G); brass sleeves in the sample barrel, sometimes called California brass (T).

b. NopH adjustment for soil.

C. Preservation with 0.008 percent NA2S 20 is only required when-residual chlorine is present.

DP-8120 Appendix A Rev. a Name Container Preservation Minimum Sample Maximum Holding Time b ,o, Volume or Weight Organochlorine G, Teflon - lined cap, T 46C, pH 5-9 1 liter or 30 g 7 days until extraction and 40 days pesticides and after extraction (water); 14 days polychlorinated until extraction and 40 days after biphenyls (PCBs) ,,_.. ....... .......... .. _ extraction (soil) 0 Organophosphorus G, Teflon - lined cap, T 46C, pH 5-9 1 liter or 7 days until extraction and 40 days pesticides/ compounds 8 ounces after extraction (water); 14 days until extraction and 40 days. after extraction (soil)

Semivolatile organics G, Teflone - lined cap, T 4*C, 0.008k Na2 S O,2 1 liter or 7 days until extraction and 40 days 8 ounces after extraction (water); 14 days until extraction and 40 days after extraction (soil)

Volatile organics6 0. TeflonO lined 4-C, 0.o08% Na 2S20 3 2 x 40 ml or 14 days (water and soil); 7 days if septum, T (HCl to pH <2 for 4 ounces unpreserved by acid.

volatile aromatics.:

by SW8240 and SW8260)b Polynuclear aromatic a, Teflon - lined cap, T 41C; store in 1 liter or 10 g 7 days until extraction and 40 days hydrocarbons (PAHs) dark, 0.00S' after extraction (water); 14 days Na2 SZ0 3 . until extraction and 40 days after extraction (soil)

a. .Polyethylene (P); glassa(G) brass sleeves in the sample barrel, sometimes called California brass (T)..

b. No pH adjustment for soil.

C. preservation with 0.008 percent HA*S 2 Oj is only required when residual chlorine is present.

n*mm aL A 4W Ow MW 'A", AM nM-) <1 M_ .0 Am 0 D

AppeI1 P- A Rev, 8 HAA Container Preservation Minimum Sample Maximum Holding Time lVolu or Weigt Dioxins and furans G,TeflonO- lined cap, T 49C, 0.008% NaSkO* I liter or 10 g 30 days until extraction and 45 days after extraction (water and

______soil)

Ethylene dibromide G,TeflonO- lined.cap, T 46C, 0.008% Na 2S,Oj 2 x 40 ml 28 days (water)

(EDB) ___

Explosive residues P,G,T Cool, 4*C 1 liter or 7.days to extraction (water), 14 8 ounces days to extraction (soil); analyze-within 40 days after extraction TCLP GTeflonO- lined cap, T Cool, 4*C 1 liter. or 250 g 14 days to TCLP extraction and 14 days after extraction (volatiles);

"14:.days to TCLP extraction and 40 days after extraction (semivolatiles); 28 days to TCLP extraction'and 28 days after extraction (mercury);180 days to TCLP extraction and 180 days after

'.______ extraction (metals).

a. Polyethylene (P);glass (G); brass sleeves in the sample barrel, sometimes called California brass (T).

b. No pH'adjustment for soil.

c. Preservation with 0.008 percent NaSgO, is only required when residual chlorine is present.

" .DP-8120 Rev. 8 Appendix a APPENDIX B SURVEY AREA DESCRIPTION Area Survey Axea Description Area Survey Area Description "

DG001 'A' Diesel Generator Room SBO17 Clean Maintenance Shop Tool Crib DG002 'B' Diesel Generator Room SB018 Clean Maintenance Shop .

DG003 'C' Diesel Generator Room DG004 MCC Switchgear Room SB019. Clean Maintenance Shop Mezzanine' 2nd DGOOS Battery Room Floor DG006 Safety Injection System Area SB020 Northeast Office Areas.

DG007 Accumulator Tank Room SB021 Service Building East Corridor DG008 Electrical Manhole SB022 Service Building Main Stores Area OB001 Maintenance Pole Building SB023  ; 3ocument Control Center OB002 Training Complex SB024 Instrumentation Calibration OB003 YAEC Visitors Center Laboratory OB004 Gate House SB025 Service Building Southeast Stores OB005 ,Office Building Area OB006 Pump House SB026 Service Building Lunch: Room 08007 Modular Office Building SB027 Second Floor Corridor -

OB008 Warehouse SB028 Second Floor: West. Offices.

OB009 South Trailer Complex SB029 Second Floor East Offices 0010 North Trailer Complex SB030 Second Floor South Offices..

OB011 Security Diesel Generator Buil lding SB031 Mechanical Equipment Room O001 Southwest Structural Exterior. SS003 Circulating Water/Service Water OE002 Northwest Structural Exteriors SS010 Fire Protection and Detection*.

0003 North Structural Exteriors SS016 Turbine Building Floor'Drains::.;..

OE004 Northeast Structural Exteriors .' SS027 Potable H20 OE005 East Structural Exteriors SS028 Roof Drains i/s OCA and o/s RCA 0006 Warehouse Exterior SS029 Roof Drains i/s- RCA 00001 Northwest Buffers Zone SS030 Misc. Ventilation 0G002 Northeast Buffers Zone TB001 Southwest Stairwell - Ground Floor:.

00003 Southeast Buffers Zone TB002 Boiler Feed Pump Area - West 0(304 Southwest Buffers Zone TB003 Boiler Feed Pump Area - East 0G00S Switch Yard Area TB004 Turbine Building Elevator/Machine6 00006 Southwest open Land Area  : .. Room 00007 South Open Land Area TB005 Heating and. Boiler Room 00008 Southeast Construction Fill A,rea TBOO6 Ground Floor - Southeast General Area 00009 East Open Land Area TB007 Ground Floor - South Central General OG010 Northeast open Land Area Area 00011 North Open Land Area TB008 Ground Floor - Southwest General Area 0G012 Northwest Open Land Area TB009 Ground Floor - Northwest General Area 0G013 East Storm Drain Outfall Area TB010 Ground Floor - West Central General G0014 Training Center Parking Lot Area OG015 Primary Parking Lot TB011 Ground Floor - North Central General 0G016 East Construction Fill Area Area 00017 West Storm Drain Outfall TBO12 Ground Floor - Central General Area::

OG018 North Buffers Zone TB013 Ground Floor - East Central General'.

0GO19 Sherman Pond Outfall Area Area 0G020 South Buffer Zone TB014 Ground Floor - Northeast General Area 0G021 ISFSI Access Road TBO15 Ground Floor.- Lube Oil Room PA001 .Charging / Purification Cubicl eas TBO16 Southwest Stairwel! - Mezzanine Floor PA009 PAB Sump/Gravity Drain Tank Caibicle TBO17 Switchgear Room.

PA012 Primary Drain Collection Tank Room TBOlS Battery Room-PA013 Cubicle Corridor Pipe Trench TBO19 Fan Room PAW14 Vertical Pipe Chase TB020 Mezzanine Floor -"Northeast Generalý PA015 LPST / SDC Cubicles I Area PA020 CCW/EFW Pumps Area TB021 Mezzanine Floor -. SoutheastGeneral PA021. Cubicle Corridor Area PA022 South General Area TB022 Mezzanine Floor -Southwest General:

PA023 North General Area Area PA024 Hydrogen Storage Room TB023 Mezzanine Floor - Northwest.General "

PA025 CCW HTX/Surge Tank Room Area PA026 Chem Sample/PASS Room TBO24 Control Room Kitchen Area PA027 Valve Room Control Room PA028 Low Pressure Surge Tank Room TB027 Operating Floor - Southeast Hallwayý PA029 Ventilation Equipment Room TB028 Operating Floor - Southeast General PA030 Non-Radioactive Pipe Gallery Area PA031 Radioactive Pipe Tunnel TB029 Operating Floor - South Central PRO01 YAEC Property Residuum General Area S8001 South Decontamination Room TB030 Operating Floor - Southwest General SBO02 North Decontamination Room Area S8003 Hot Weld Shop- TBO31 Operating Floor - Northwest General:

SB004 Maintenance Shop Area SB005 Decon Room TB032 Operating Floor - Modular Offices S8006 Radiation Protection Counting Room TB033 Operating Floor - North Central S8007 RCA Egress Area General Area SBOO8 RCA Access Area TB035 Operating Floor - Northeast General. -:

Area " " " _-,

SB0O9 RCA Dressout Area SB0 10. Radiochemistry. Laboratory TB036 Operating Floor Crane.

SBOI Locker Room TB037. Operating:.Floor Ceiling.

SB012 Body Count Room/Clean Faciliti es TB038 Cable Tray Room SB013 Plant Laboratory UA907 Unaffected 75 Percent GLV SBO14 Service Building Main Corridor UG001 Under PrimaryAuxiliary.Building SB01s Water Treatment Room UG002 Under Waste Disposal Building SBO16 Radiation Protection Office Ar eas UGO03 Under PCA Warehouse

DP-8120 Rev. a Appendix B Area Survey Area Description Area Survey Area Description UG004 Under PCA Storage Building #1 YE015 VC Elevator Structural Exterior VC001 VC Skin Under BioShield - SW Quad YE016 Small Activated Area on Top of VC VC002 VC Skin Under BioShield - NW Quad YE017 Exterior Surface of VC Below VC003 VC Skin Under BioShield - NE Quad Equipment Hatch VC004 VC Skin Under BioShield.- SE Quad YE018 Miscellaneous Yard Exteriors VC005 Underside of BioShield - SW Quad YGO01 Transformer Yard VC006 Underside of BioShield - NW Quad YGO02 Northwest: Yard Area VC007 Underside of BioShield - NE Quad YG03, Southwest Yard Area VC008 Underside of BioShield - SE Quad YGO04 South Yard Area VC009 VC Skin Lower Section - SW Quad YGOO5. Southeast Yard Area VC010 VC Skin Lower Section - NW Quad YGO06. Northeast Yard Area VC011 VC Skin Lower Section - NE Quad YGoo7 Central Yard Area VC012 VC Skin Lower Section - SE.Quad YGOO8 !'-Tank Farm.-

VC013 Lower Outer BioShield Wall. - SW Quad YSo01 Fire. Water Pump House VC014 Lower Outer BioShield Wall - NW Quad YS002

• Safe Shutdown System Building - South VC015 Lower Outer BioShield Wall - NE Quad YS003 Safe Shutdown System Building -

VC016 ,Lower Outer BioShield Wall - SE Quad Center VC017 Brass Drain Box Sloped Floor Area - YS004 Safe ShutdowrL System Building - North South YS005 PCA Storage Building #2 VC018 Brass Drain Box Sloped Floor Area - YS006

• PCA Storage Building #1 North YS007 Waste Holdup Tank Moat VC019 VC Equipment Hatch YS008 Activity Dilution Storage Tank Moat VC020 Brass Drain Box. Area YS009 Ion Exchange Pit Pipe Trench.

VC021 Loop #1"Mezzanine Area YS010 Ion Exchange Pit VC022 Pressurizer Mezzanine Area YS011 Vapor Container Elevator VC023 Loop #2 Mezzanine Area YS012

• Miscellaneous Yard Structures VC024 Loop #3 Mezzanine Area YS013 Radioactive Laboratory Sump:'Cubicle VC025 Loop #4 Mezzanine Area VC026 Feed & Bleed HTX Room VC027 Loop#1 Area VC028 Pressurizer Area VC029 Loop#2 Area VCD30 Loop#3 Area VC03 Loop#4 Area VC032 Shield Tank Cavity VC033 Reactor Vessel Bioshield Concrete "VC034 Charging Floor - Loop#l G/A VC03S Charging Floor - Loop#2 G/A VC036 Charging Floor - Loop#3 G/A YC037 Charging Floor -. Loop#4 G/A VC038 Charging Floor - Central G/A VC039 Upper Outer BioShield Wall - SW Quad.

VC040 Upper Outer BioShield Wall - NW Quad*

VC041 Upper Outer BioShield Wall - RE Quad VC042 Upper Outer BioShield Wall - SE Quad VC043 VC Skin Upper Section - SW Quad VC044 VC Skin Upper Section - NW Quad VC04S VC Skin Upper Section - NE Quad VC046 VC Skin Upper Section - SE Quad VC047 VC Skin Dome Area - SW Quad VC048 VC Skin Dome Area - NW Quad.

VC049 VC Skin Dome Area - NE Quad-VC050 VC Skin Dome Area - SE Quad VCOS2 VC Airlock and Platform VC900 Vapor Container Test VC907 VC Weighted Mean WD001 PCA Warehouse - West General Area WD002 PCA Warehouse - East General Area WD003 Waste Disposal Building Corridor WDO04 Drumming Pit WDOOS Drum Drying Area WD006 Waste Compactor Building.

WD001 North-General Area "WD008 Waste.-Disposal Building Pipe Trenches WD009 Liquid Waste Transfer Pump Room 14D010 Distillate Accumulator Cubicle WD011 Evaporator Cubicle WD012 .Waste Gas Compressor Room YE001 Turbine Building Exterior YE002 Auxiliary Bay .Exterior YE003 Service Building Exterior YE604 Vapor Container Exterior -. Top Half YE00S Vapor Container. Exterior -- Bottom Half YE006 Diesel Generator Building Exterior YE007 Primary Auxiliary Building Exterior YEO08 Primary-Auxiliary Building Roof "YE609

• Safe Shutdown System Building Exterior YE010 Fire Water Storage Tank/Pumphouse Exterior YE011 Waste bisposal Building Exterior YE012 PCA Storage Building #2 Exterior YE013 PCA Storage Building #1 Exterior YE014 Tank Farm Exteriors

DECOMISSIONING SOIL, ASPHALT, AND CONCRETE EXCAVATIONS SAMPLE COLLECTION LOG PIEN.SAMPLE NOS'. SAMPLE

• DATE ILOCATION DESCRIPTION COMMENTS ANALYSES REQUESTED

_ _ ...... _ _ ,_,,,, DAT,

.. e.g., 'P20000GO21TS04 is the fourth soil pile from survey area 0G021 assigned in year '2000 P20000G021AS01 is the first asphalt pile from survey area 0G021 assigned in. year 2000 D' '1l20, 1 R-. 8

DECOMMISSIONING EXCAVATION SAMPLE RESULTS AND PILE DESCRIPTION

-?ile Number Date/Time of Sample Collection _____________________/________

Samplers Name Soil [ I Asphalt ]

Concrete Part 1: LABORATORY RESULTS Sample Spectrum Net Positive Activity (pCi/g) Fraction 2of Sum of Number Number Guideline Fractions 2 (Each (Total Nuclide) Sample)

Nuclides Concentration' "ND"

" indicates no positive activity detected 2 Soil only Evaluation performed by Date Part 2: DISPOSITION OF MATERIAL The determination of acceptance of material for unconditional release is accomplished utilizing AP-0052.

Disposition of pile: Date:

Final Review by: Date:

(RP Supervision).

/

DPF-8120.2 Rev. 8

- ----- m--m s -_ m - *-m - -I CHAIN OF CUSTODY PAGE _OF i t Recd InLab:

$2-` 1 ALPHA Job 0: /(n76'4 Prcject~~~~ ~ Inomto Reor Inorato -

DaaDlvrbe Billing Infermation Eight Walkup Drive Westborough, MA 01581 TEL: 508-898-9220 FAX: 508-898-9193 Project Name: ?al Irooid, 0 FAX O-eMAIL ,1ame as ClientinfloI PO #: --

Clen Inomto .i Client: ft A tL Project#: Noksll 0) ReuaoyRqieet/eotLmt

ý 9DEx U. Add'l Deliverables Pro~d~aage~ state ,.-ed Program Cntena AdJress: qcý I -- .- PrjctMnae.

P__ -1 r

,%Y~AM(/AA I" C

ý;

Phone: GrYes 0 No Are MCF Analytical Methods Required?

ý0ýs No Are Drinking Water Samples Submitted?

Fax: ' . L? L,1 j . n, a.. Yes 0 No Have you met minimum field QC reauirements?

OR U ISH( :.,,-& ,,,*,.-_ m

, /

,Time:

O These samples have been pre41ousty analyzed by Alpha Filtration Other Project Specific Requirements/Comments!Detection Limits:

I

! /

/ Done Q Not needed UL~LU- Gw-I1,ý C \ I6r'd S / / OLabto do Preservation

/ Labtodo ALPHALabU1 Collection I Sample iSampler's (Lab Use Only) SamplelID

-D6ata "-I Tune ' Matri : Initials If / f SapeSpecific commants;

]

m m I 4. ,==*m,..,=,+k,,.,*

1 I L~ŽVoA__ 2-:L) t _3C _ L

~iW '5 bbItV

ŽLA~) t84.

r ao-o1 C-V QUESTIONSABOVE MUST BE ANSWERED FOR PRESU MPTIVE CERTAINTY 4-.---.. Ccntainer Type "

Please pitnt clearly, legilbly and completely. Samples can not be IS YOUR Preseative

-. - logged in and turnaround time clck e.Re*

I_

'*' uished B8,: ........ ...... . By.. vAI not at until any ambiguities aI PROJECT" ... . .. S..

Datefrime resolved. AD samples submitted aem subject to Alpha's Payment Termis.

1MCP  ?-

Appendix F Cianbro Health & Safety Plan

C IANBRO CORPORATION SITE SPECIFIC HEALTH AND SAFETY PLAN SITE DEMOLITION ACTIVITIES YANKEE NUCLEAR POWER STATION; ROWE MA YANKEE ATOMIC ELECTRIC Submitted to:

Yankee Atomic Electric Company 49 Yankee Road Rowe MA 01367 Preparedby:

Cianbro Construction 1801 East Street Pittsfield MA 01201 April 2005

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 TABLE OF CONTENTS 1.0 PROJECT IDENTIFICATIO N ............................................................. 1

2.0 INTRODUCTION

..................................... 1 2.1 SCOPE AND APPLICATION OF HASP ............................................................................ 1 2.2 APPLICABILITY TO VISITORS & INSPECTORS .................................................................. 1 2.3 AMENDMENTS AND REVISIONS TO HASP ..................................... 2 3.0 ORGANIZATIONAL ROLES AND RESPONSIBILITIES .............. 2 3.1 YANKEE ATOMIC ELECTRIC ...................................................................................... 2 3.2 CIANBRO CONSTRUCTION ........................................................................................... 2 4.0 SITE DESCRIPTION & OPERATIONS ANALYSIS ..................... 3 4.1 SITE LOCATION ...................................................................................................... 3 4.2

SUMMARY

OF W ORK ................................................................................................... 3 4.3 CHEMICAL, PHYSICAL, AND BIOLOGICAL SAFETY HAZARDS ..................................... 4 4.3.1 Chemical Hazards ...................................................................................... .................. 4 4.3.2 Physical & Safety Hazards .......................................................................................... 5 4.3.3 Biological Hazards ................................................................................. ..................... 5 4.4 HAZARD ANALYSIS .................................................................................................... 6 4.4.1 General Project Hazards and Precautions .................................................................... 6 4.4.2 Material Handling .................................................................................................. 8 4.4.3 Compressed Gasses and Systems ............................................................................... 8 4.4.4 Confined Space ............................................................................................................. 9 4.4.5 Welding, Cutting and Brazing .................................................................................... 9 5.0 HAZARDOUS W ASTE OPERATIONS ............................................................................. 9 5.1 Initial / Pre-Assignment Training .................................................................................. 9 5.2 INITIAL HEALTH & SAFETY BRIEFING ..........................................................................9 5.3 DAILY ACTIVITY BRIEFINGS ....................................................................................... 10 6.0 PERSONAL PROTECTIVE EQUIPMENT .................................... 10

6.1 DESCRIPTION

OF LEVELS OF PROTECTION ............................................................... 10 6 .1.1 L evelA ............... .......................................................................................................... 11 6.1.2 LevelB ......................... ......................................................................................... 12 6.1.3 L evel C ......................................................................................................................... 13 6.1.4 Level D (Modified) ....................................................................................................... 14 6.1.5 L evel D .......................................................................................................................... 15:

6.2 INITIAL LEVELS OF PROTECTION ................................................................................ 15 6.3 REASSESSMENT OF PERSONAL PROTECTION ................................................. ................ 16 6.4 STANDARD OPERATING PROCEDURES AND INSPECTION FOR PERSONAL PROTECTIVE EQUIPMENT ......................... I............................................................. . . . . . . . . . 16 7.0 RESPIRATORY PROTECTION . ..................................... . .... ........ 17 i

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 7.1 AIR PURIFYING RESPIRATORS................................................................... 18

7. 1.1 Cartridge Change-out Frequency .............................................................. 18 7.1.2 Daily Cleaning Procedure ...................................................................... 18 7.1.3 Inspection'& Checkout ......................................................................... 19 7.1.4 Storage of Air Purifying Respirators.......................................................... 19 7.2 AIR-LINE BREATHING AIR COMPRESSORS .............. ............ 19 8.0 MEDICAL SURVEILLANCE REQUIREMENTS.................... 20 8.1 BASELINE & PRE-,ASSIGNMENT MEDICAL MONITORING ................................... 20 8.2 PHYSICIANS OPINION FORM................................................................. 20 8.3 HEAT STRESS EVALUATION .................................................................... 21 8.3.1 Heat Stress Management....................................................................... 21 8.4 COLD STRESS ..................................................................................... 22 9.0 SITE CONTROL MEASURES........................................... 22 9.1 WORK ZONE DEFINITION........................................................................ 23 9.2 BUDDY SYSTEM...................I................................................................ 23 9.3 SITE COMMUNICATIONS......................................................................... 23 9.3.1 Hand Signals..................................................................................... 24 9.4 SPILL PREVENTION ............................................................................... 24 10.0 DECONTAMINATION PLAN ........................................... 24 10.1 ROUTINE PERSONAL DECONTAMINATION .................................................... 25

10. 1. 1 Level C Decontamination......................................................  ;............... 25

10. 1.2 LevelI D & D Modified Decontamination................................................... 26 10.2 EMERGENCY DECONTAMINATION ............................................................. 26 10.3 EQUIPMENT DECONTAMINATION............................................................... 26 11.0 ILLUMINATION &~SANITATION..................................... 26 11.1 ILLUMINATION... .......................... .................... 27 11.2 SANITATION....................................................................................... 27 11.3 HOUSEKEEPING................................................................................... 27 12 MEIR(ENCY~ PROCEDURES............................................27 12.1 P RE-EMERGENCY PLANNING ................................................................... 27

.12.2 EMERGENCY EQUIPMENT & FACILITIES ....................................................... 28 12.3 PERSONNEL ROLES AND LINES OF AUTHORITY ............................................... 28 12.4 ACCIDENT & ILLNESS REPORTS................................................................ 28 12.5 EVACUATION PROCEDURES ..................................................................... 28 12.5.1 Alerting System............................................ .......... ***......... 29 12.5.2 Emergency Conta~ts & Notification Systems.............................................. 29 12.6 EMERGENCY MEDICAL TREATMENT ................. ........................................ 31 12.6.1 Directions to Hospital ......................................................................... 31 12.7 FIRE & EXPLOSION PROCEDURES.............................................................. 32 12.8 ,SPILL & LEAK PROCEDURES.................................................................... 32 ii

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 12.8.1 Spill Containment Equipment .................................................................................. 33 12.9 INCIDENT FOLLOW-UP AND CRITIQUE ..................................................................... 33 13.0 INSPECTION PROGRAM .............................................................. 33 13.1 INSPECTIONS REPORTING AND RECORDKEEPING ...................................................... 33 13.1.1 Safety Inspections ................................................................................................... 34 13.1.2 G eneral Facility Inspections ................................................................................... 34 13.1.3 Cianbro Guard Devices .......................................... 35 iii

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 LIST OF TABLES Table 4-1 General Project Hazards and Precautions Table 4-2 Material Handling Table 6-1 Level C PPE Table 6-2 Level D Modified PPE Table 6-3 Level D PPE Table 6-4 Initial Levels of PPE Table 9-1 Air Horn Alerts Table 9-2 Hand Signals Table 13-1 General Facility Inspection Schedule LIST OF FIGURES (ALSO IN ATTACHMENT 7)

Figure 12-1 Map to Franklin Medical Center LIST OF ATTACHMENTS List of Cianbro Safety Bulletins NIOSH Chemical Cards LIST OF ACRONYMS AND ABBREVIATIONS APR Air Purifying Respirator CGI Combustible Gas Indicator CRZ Contamination Reduction Zone DEP Department of Environmental Protection EZ Exclusion Zone HASP Health and Safety Plan IDLH Immediate Danger to Life and Health LEL Lower Explosive Limit MSDS Material Safety Data Sheet CIANBRO Cianbro Construction NIOSH National Institute for Occupational Safety and Health OSHA Occupational Safety and Health Administration PEL Permissible Exposure Limit (per OSHA)

PM Project Manager PPE Personal Protective Equipment ppm Parts per million iv

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 PID Photo-Ionization Detector SAR Supplied Air Respirator SCBA Self-contained Breathing Apparatus SSO Site Safety Officer SVOC Semi-Volatile Organic Compounds SZ Support Zone VOC Volatile Organic Compound v

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 1.0 PROJECT IDENTIFICATION Client: Yankee Atomic Electric (YAE)

Site Name: Yankee Rowe Nuclear Power Plant Site Location- 49 Yankee Road, Rowe, MA Yankee Atomic Electric Personnel:

Project Manger: Norm Rademacher Cianbro Construction Personnel:

Project Manager: Bob Seegmiller Site Supervisor: Brigitte Reid

2.0 INTRODUCTION

2.1 SCOPE AND APPLICATION OF HASP The purpose of this HASP is to define the requirements and designate protocols to be followed during Site Demolition activities at the Yankee Rowe Site in Rowe, Massachusetts. Applicability extends to contractors, subcontractors, governmental officials, and visitors that enter the site while Site Demolition activities are occurring. For the purposes of this HASP, the term "site" shall be used to identify construction and remedial areas associated with this project and under direct control of Cianbro Construction (CIANBRO).

All personnel, on-site contractors and subcontractors included (hereafter referred to as "project personnel"), shall be informed of the site emergency response procedures and any potential fire, explosion, health, or safety hazards in the operations. This HASP summarizes those hazards, and defines protective measures planned for the site.

This plan must be reviewed by all project personnel, and an agreement to comply with the requirements contained herein, must be signed by all project personnel and visitors who may enter the Exclusion or Contamination Reduction (Decontamination) Zones of the site, prior to their commencement of work. See Attachment 1, HASP Acknowledgement Sheet. The Exclusion or Contamination Reduction Zones of the project site are designated based on the potential for contact with, or exposure to, identified contaminants.

2.2 APPLICABILITY TO VISITORS & INSPECTORS All visitors and inspectors entering the Exclusion Zone (EZ) or the Contamination Reduction Zone (CRZ) at the site will be required to read and sign a written compliance statement stating that they are knowledgeable and will comply with all provisions of this HASP. In addition, visitors will be expected to comply with all OSHA requirements and Cianbro Safety Bulletins, I

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 such as medical monitoring, training, and respiratory protection, as addressed in this plan.

CIANBRO shall provide and care for all personnel protective equipment used by CIANBRO and any subcontractors. All visitors and inspectors will provide and care for their own protective equipment or arrange to acquire personal protective equipment (PPE) from CIANBRO.

All other visitors entering the site, but not performing work will be required to receive an abbreviated Health and Safety Plan (HASP) briefing covering site specific operational hazards and emergency procedures.

In the event that any project personnel, visitor, or inspector does not adhere to the provisions of the HASP, he/she will be requested to leave the site immediately. All non-conformance incidents will be recorded in the site log and will be reported to Cianbro Management and YAEC Management.

2.3 AMENDMENTS AND REVISIONS TO HASP Due to the nature and extent of the project changes are made to this plan and they will be developed onsite. All changes shall be made by the Cianbro Health and Safety Manager and announced at the daily activity plan meetings.

3.0 ORGANIZATIONAL ROLES AND RESPONSIBILITIES 3.1 YANKEE ATOMIC ELECTRIC Yankee Atomic Electric (YAE) will manage and oversee the implementation of the activities associated with the remediation of the Yankee Rowe Demolition site.

The Yankee Atomic Electric project team shall consist of the following individuals:

YAE Project Manager: Norm Rademacher Phone: (413) 424-2264 3.2 CIANBRO CONSTRUCTION CIANBRO's responsibility is supplying personnel and equipment for Site Demolition operations under a Project Manager's (PM) oversight and direction. The contractor will also have an oversight function to ensure that the health and safety of all site personnel is a primary concern.

Prime Site Contractor: Cianbro Construction (CIANBRO)

CIANBRO Project Manager (PM): Bob Seegmiller Phone (413) 424-2485 2

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 CIANBRO Site Supervisor (SS): Brigitte Reid Phone (413) 424-2484 CIANBRO's PM has overall responsibility for ensuring that all aspects for the project are implemented and progress is constant. He will serve as a liaison among Owner/Engineer, site personnel, and office personnel.

The SSO is responsible for the implementation of the HASP. The SSO will establish and ensure compliance with site control areas and procedures. The SSO oversees the safety of any visitors who enter the site and all field work.

Equipment operators will be trained and experienced in the safe operation of construction equipment and will hold valid operating licenses for the piece(s) of equipment they are assigned to operate.

4.0 SITE DESCRIPTION & OPERATIONS ANALYSIS This section of the Health and Safety Plan provides an overview of the scope of project activity, as well as a historical analysis of the project areas. The purpose of this section is to review the potential project chemical and physical hazards to which workers may be exposed when working with or near the site.

4.1 SITE LOCATION The site is located at 49 Yankee Road in Rowe, Massachusetts.

4.2

SUMMARY

OF WORK CIANBRO summarized activities at the Yankee Rowe IDS Site will include:

Site Preparation:

- Protection of Work and Property;

- Mobilization;

- Temporary Facilities; Site Demolition

- Structure Demolition;

- Underground structure removal;

- Soil movement;

- Site remediation.

Site Restoration:

- Decontamination of Equipment;

- Restorations; 3

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005

- Demobilization.

4.3 CHEMICAL, PHYSICAL, AND BIOLOGICAL SAFETY HAZARDS 4.3.1 Chemical Hazards Previous site investigation indicated PCB, Lead, and Barium paint chips in the site soil. Also there may be dioxins, and total petroleum hydrocarbons (TPH) from diesel fuel oil present and asbestos. See Attachment B for NIOSH Chemical Cards, which list signs and symptoms of overexposures.

Dioxin Contaminated Areas have been identified in the Radiological ControlledArea north of the Fire Water Tank 55. These areas are scheduled for excavation and remediation. These areas are currently secured and access is controlled.

There is material containing or coated with asbestos. All asbestos work will be in accordance with Massachusetts DOLI regulations and in posted asbestos work areas.

PCB contaminated paint is located in various locations across the site. The PCB can be found still on surface's as well as in chip form in soils around some concrete slabs. The paint results range from 1 ppm to 210 ppm. There is one area that the concentration from 8,000 ppm to 11,000 ppm. This area is approximately 100 square feet. These areas are scheduled for excavation and remediation. These areas are posted and controlled with PCB work Permits.

There is also paint that contains lead and barium. The lead levels are from 20 ug/m to 400 ug/m.

The barium levels are from 8,000 ppm to 11,000 ppm. These areas are isolated on concrete slabs. These areas are scheduled for excavation and remediation. These areas are posted and controlled with lead permits-.

Also on the site has been reported radiation contaminated soil. Training on necessary precautions will be provided by Yankee Rowe to CIANBRO and sub-contract employees.

There is one structure on the site, Fire Water Tank 55, that has not been totally characterized. At the present time there is a potential for:

• Asbestos

• PCB>50 ppm

• Radiological Material

• Lead Contaminated Material

• Barium.

These areas are scheduled for excavation and remediation. These areas are posted. The most conservative approach, asbestos, will be used as a plan for removal of this material. All work will be in accordance with Massachusetts DOLI regulations and in posted asbestos work areas.

4

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 Exposure to these contaminants occurs primarily through the inhalation route of exposure.

Additionally, some of the site contaminants can be absorbed through unbroken skin. Non-use of PPE, and incomplete personal hygiene and decontamination may lead to skin exposure and possibly ingestion due to contact of hands with food, cigarettes, etc., after leaving the work areas or the site.

Additionally, as with any construction site, hazardous materials can be expected to be present in various everyday forms. Some common types may include:

• Fuel and Lubricants (e.g. gasoline, diesel fuel, hydraulic oil)

" Cleaning agents (e.g. detergents, respirator sanitizes, hand cleaners)

" Miscellaneous chemicals (e.g. marking paint, bulk office supplies)

A Material Safety Data Sheet (MSDS) is required for all hazardous materials brought on site pursuant to 29 CFR 1910.1200. The YAEC Control Room will maintain a central file, accessible to all workers, which contains all Material Safety Data Sheets for any hazardous materials brought to the site. See Appendix F. "

4.3.2 Physical & Safety Hazards Remedial Construction sites may present numerous safety hazards such as:

• Energized electrical lines;

• Excavations, holes and ditches;

• Precariously positioned objects, such as boards that may fall;

• Sharp objects, such as nails, metal shards, and broken glass;

• Slippery surfaces;

• Uneven terrain;

" Dangers related to working near heavy equipment;

• Heat stress i Cold stress;

" Pedestrian & Vehicle Traffic;

• Loud noises.

As such, workers must be aware of these hazards and exercise caution at all times. All unsafe conditions must be reported immediately to the SSO.

4.3.3 Biological Hazards Potential biological hazards on the site are relatively minor yet not insignificant and may include the following: ticks, bees, mosquitoes and other insects which may carry disease; or other wildlife may be present posing the potential for bites and disease, such as rabies; poison ivy, oak, or sumac may be found in overgrown areas posing skin hazards.

5

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 4.4 HAZARD ANALYSIS The evaluation of potential health and safety hazards related to this project is based upon the knowledge of site conditions, and anticipated risks posed by the specific operation are covered by this HASP. As hazards are identified the SSO will determine the extent of the hazard what will be done to protect the work force. The SSO will then review the hazard with thework force and protection measures during the daily brief.

4.4.1 General Project Hazards and Precautions Certain hazards potentially exist throughout all phases of the project. These hazards and preventative measures designed to minimize or eliminate the risk of the manifestation of these hazards are presented in the tables below.

Table 4-1 General Project Hazards and Precautions Boetack Strain s pro eralsuigrechius Usvetaie Back Strain 0 Use proper lifting techniques.

0 Use 2 or more employees for lifting large, heavy items.

0 Take sufficient rest breaks.

Heat Stress 0 SSO shall monitor heat stress.

• Take sufficient rest breaks and drink fluids.

Vehicle Traffic

• All employees on site will wear orange safety vests 0 Spotters will be used when determined necessary by the SSO.

Eye Injuries

• All employees on site shall wear Safety glasses with side shields.

• Double eye protection shall be worn when using power tools that have the possibility of creating any airborne particles.

Hand Injuries

• Employees will wear leather gloves during most operations Foot Injuries a Steel toed work boots will be used.

Head Injuries

• Hard hats will be worn on site.

Ear Damage 0 Hearing protection shall be required in operations at 85 dB and above.

Slips, Trips and Falls 0 Good housekeeping shall be implemented.

• Be alert while walking.

• Tripping and poor footing hazards will be repaired as they are discovered or will be clearly identified.

Electrical Shock 0 Lockout/tagout procedures shall be followed.

• GFCI electrical outlets shall be utilized.

6

Demolition %Activities,Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005

• The YAEC Electrical Power Tool procedure shall be followed.

Falling Hazards

• Any work above six feet shall require fall protection such as harnesses or hand rails. All holes deeper than four feet shall be barricaded.

Fire Hazards/ Bums

• Air monitoring for flammable atmospheres.

• Cianbro promotes a smoke free work area. Cianbro employees are not allowed to smoke on site.

• Combustible chemicals shall be stored properly.

• No fueling operations will be left unattended.

• Personnel will not attempt to service/fuel any piece of equipment until it has sufficiently cooled down.

Biological Hazards 0 Avoid wildlife when possible.

• Wear insect repellant as necessary.

• Use good personal hygiene.

• Personal inspections for ticks should be performed.

Hot Work Hazards (non- 0 Fire extinguishers will be available.

radiological, potential fire hazards o SSO shall approve a hot work permit prior to hot work being performed.

• Appropriate PPE shall be worn.

• Compressed gas shall be stored properly.

Radiological Hazards

• Radiological Work Permits shall be required to work in the Radiological Controlled Area

• Radiological Technicians will give oversight in these areas and determine appropriate PPE.

• The radiological Technician will determine appropriate sampling requirements.

Chemical Hazards

• The SSO will determine the chemical area at the construction site.

• These may include PCB, Lead, Dioxin, Barium and some asbestos material.

• The SSO will determine appropriate work permits for the area.

• The SSO will determine appropriate PPE for the hazard level. The PPE shall be used to minimize exposure to contaminants.

• The SSO will determine appropriate sampling requirements.,

i Air monitoring in work breathing zones shall be performed.

• Dust and vapor controls, as necessary, shall be implemented on site.

7

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 I Proper decontamination procedures shall be followed.

4.4.2 Material Handling Table 4-2 Material Handling: Excavation, Transportation, Backfilling, Compacting IPotentil Hzr II Meas Pinching/injuries caused from

• Guards shall be maintained on all equipment as objects/equipment in motion appropriate.

• Heavy equipment and vehicles shall have back up alarms. -

• Vehicles that have inoperable back up alarms must use a spotter.

• Equipment, cables, chains and loads shall be inspected at least daily and prior to use.

• Workers shall wear work gloves when handling rough or sharp material.

• No personnel shall be permitted under the crane radius during operation.

• All operations shall be performed under a competent person.

• Hand signals shall be established.

• All personnel will establish eye contact with operators prior to approaching equipment.

• Personnel will avoid equipment swing areas and blind sides.

• All slings, chains, and ropes will be rated for the load which it is expected to lift.

• Only qualified and trained personnel will set-up rigging prior to hoist/lift.

Rollovers

• Equipment will have rollover protective structures and seat belts.

• Operators will wear seat belts when operating equipment.

• Equipment will not be operated on grades that exceed manufacturer's recommendations.

Injuries due to falling items into

• Visible barriers shall be placed around all open excavations, excavations where leading edge is not visible.

• Excavated material shall be kept at least 2' from the excavation depending on the depth of excavation.

4.4.3 Compressed Gasses and Systems 8

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 Compressed gases will be properly used according to the supplier's instructions and the Compressed Gas Association guidelines. Cylinders will be handled carefully. Compressor hose segments will be secured using chains and/or locking pins. A pressurized hose will be connected to the compressor through a pressure-sensing device that will discharge the pressure if the hose pressure system fails. Safety glasses and gloves will be worn when handling/hooking up compressed gas cylinders or systems.

As per 29 CFR § 1910.253, inspection of compressed gas cylinders, the SSO shall determine that compressed gas cylinders in use are in a safe condition to the extent that this can be determined by visual inspection.

4.4.4 Confined Space Confined space entry procedures adhere to Cianbro Safety Bulletin 19 Confined Space Entry.

Identified Confined Spaces include man holes, pipe tunnels and chases, open pits and possible excavations.

4.4.5 Welding, Cutting and Brazing Welding, cutting and brazing will be performed in accordance with Cianbro Safety Bulletin 7 Watch for Fire, Smoke and Sparks.

5.0 HAZARDOUS WASTE OPERATIONS 5.1 Initial / Pre-Assignment Training All workers that have potential to enter the Construction Site are required to attend YAEC's General Employee Training as well as Cianbro's Site specific Training. This training consists of two days of Radiological Training, Site Security Training, site specific safety training and Cianbro Safety Bulletin reviews.

5.2 INITIAL HEALTH & SAFETY BRIEFING The SSO shall conduct a site specific Health and Safety briefing for all employees of CIANBRO, Subcontractor(s), Owner/Engineer, visitors (e.g. inspectors), or any others who will work on site.

The Health and Safety briefing shall include, at a minimum, the following:

• The contents of this site specific Health and Safety Plan;

• Names of personnel and alternates responsible for site health and safety;

• Project roles and responsibilities;

• OSHA training and medical surveillance requirements to enter the Exclusion and Contamination Reduction Zones;

• Potential health hazards associated with known or potential contamination present in the various work areas; 9

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005

• Work practices by which the employee can use to minimize risks of safety and health;

• Visitor requirements;

" Evacuation routes and signals;

• Health and safety emergency procedures;

• Respiratory protection, if required;

• Emergency and contingency procedures;

• Location of First Aid, Eyewash, Decontamination areas and Emergency Equipment;

• Location of Emergency Contact Phone List;

• Hospital Route.

5.3 DAILY ACTIVITY BRIEFINGS Daily Activity Briefings will be presented to all site personnel each morning just prior to the onset of work activities. It will be the responsibility of the SSO to conduct these meetings. All Activity Briefings are mandatory for all project personnel. At the conclusion of the meeting, each individual will be required to sign the Activity Plan Late arrivals will see the SSO for a brief meeting about hazards associated with the days remaining activities.

The SSO will determine the topics of each meeting based on activities to be conducted that day and any incidents or items identified during previous days. These topics shall include, but are not limited to, heat stress, PPE requirements, chemical hazards, physical hazards, emergency procedures, and injury or incident analysis, near misses, and any other special considerations.

CIANBRO will keep on file, at the job site, records of safety meetings that have occurred, including topics covered, safety related concerns, and action follow-up items coming out of those meetings.

6.0 PERSONAL PROTECTIVE EQUIPMENT This section describes the general requirements of the U.S. Environmental Protection Agency (EPA) designated levels of protection (A-D), and the specific levels of protection required for each task at the site. The following subsections define the specific personal protective equipment requirements and the individual skin protection materials required for this particular site.

6.1 DESCRIPTION

OF LEVELS OF PROTECTION Personal protective equipment (PPE) will be used when project and support activities involve known or suspected atmospheric contamination, when vapors, gases, or particulate may be generated by site activities, or when direct contact with skin affecting substances may occur.

Full-face piece respirators protect lungs, gastrointestinal tract, and eyes against airborne contaminants. Chemical resistant clothing protects skin from contact with skin destructive and absorbent chemicals.

10

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 The specific levels of protection and necessary components for each have been divided into four categories according to the degrees of protection afforded:

Level A: Should be worn when the highest level of respiratory, skin, and eye protection is needed.

Level B: Should be worn when the highest level of respiratory protection, but when lesser level of skin protection is needed Level C: Should be worn when the criteria for using air-purifying respirators are met, and a lesser level of skin protection is needed Level D Modified: Should be worn when respiratory protection is not warranted but dermal protection is necessary.

Level D: Provides minimal protection against chemical hazards. It is normally worn only as a work uniform and not in any area with significant respiratory or skin contact hazards.

Modifications of these levels are permitted and routinely employed during site work activities to maximize efficiency. Likewise the type of chemical protective ensemble will depend upon contaminants, concentration and extent of contact.

The level of protection selected is based upon the following:

" Type and measured concentration of the chemical substance in the ambient atmosphere as well as its toxicity;

" Potential for exposure to substances in air, splashes of liquids, or other direct contact with materials due to work executed;

" Knowledge of chemicals on site along with properties such as toxicity, route of exposure and contaminant matrix;

" Understanding of chemical, physical and biological hazards that may be encountered.

In situations where the type of chemical, concentration and possibilities of contact are not known or if unforeseen conditions are encountered, the appropriate level of protection will be selected based on professional experience and judgment of the SSO until the hazards can be better identified.

6.1.1 Level A Level A attire offers the highest level of respiratory and skin protection available through the use of self contained breathing apparatus inside a fully encapsulated, air tight, vapor tight, chemical protective suit. Only specially trained and qualified individuals may don Level A, usually only under emergency conditions. The use of Level A is not anticipated on this project.

11

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 6.1.2 Level B Level B attire offers the highest level of respiratory protection, but lesser level of skin protection through the use of self-contained breathing apparatus inside a chemical protective suit. Only properly trained and qualified individuals may don Level B. The use of Level B is not anticipated on this project.

12

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 6.1.3 Level C Table 6-1 Level C PPE PPE Description Respiratory Protection: Air purifying respirator, full or half face, cartridge equipped organic vapor/acid gas/P-100 (HEPA) filter cartridge.

Clothing: For job tasks were splashing of wet material is likely:

Pro/Shield 2 or 3, or polyethylene coated Tyvek coveralls, with attached hoods.

Where only dry material contact is likely:

Any of the above, Tyvek, Pro/Shield 1, or NexGen.

7 Gloves (outer): Nitrile rubber (leather/cotton type to be left in the zone may be substituted in dry conditions only).

Gloves (inner): Latex or nitiile surgical type.

Boots: Construction work boots.

Boot Covers (outer): Latex (disposable) or slush boots (reusable).

Head Protection: Hard Hat Other: Warning vests when appropriate; fall protection devices, as needed;,

hearing protection, safety glasses, as needed.

13

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 6.1.4 Level D (Modified)

Table 6-2 Level D (Modified) PPE PPE Description Respiratory Protection: None required.

Clothing: For job tasks were splashing of wet material is likely:

Pro/Shield 2 or 3, or polyethylene coated Tyvek coveralls, with attached hoods.

Where only dry material contact is likely:

Any of the above, Tyvek, Pro/Shield 1, or NexGen.

Gloves (outer): Nitrile rubber (leather/cotton type to be left in the zone may be substituted in dry conditions only).

Gloves (inner): Latex or nitrile surgical type.

Boots: Construction work boots.

Boot Covers (outer): Latex (disposable) or slush boots (reusable).

Eye/Face Protection: Chemical splash goggles or safety glasses with side shields at all times.

Head Protection: Hard Hat Other: Warning vests when appropriate; fall protection devices, as needed;:

hearing protection, as needed.

14

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 6.1.5 Level D Table 6-3 Level D PPE PPE Description Respiratory Protection: None required.

Clothing: Cloth coverall or short sleeve shirts and full length pants.

Gloves (outer): None required.

Gloves (inner): None required.

Boots: Construction work boots.

Boot Covers (outer): None required.

Eye/Face Protection: Chemical splash goggles or safety glasses with side shields at all times.

Head Protection: Hard Hat Other: Warning vests when appropriate; fall protection devices, as needed; hearing protection, as needed.

6.2 INITIAL LEVELS OF PROTECTION Table 6-4 Initial Levels of PPE Job Tasks Initial Level of Protection Mobilize, Set up Level D IDS Treatment of Soil Level D Modified Site Demobilization Level D Prior to each activity performed onsite, PPE for that activity will be developed by each subcontractor and will be approved by the SSO and reviewed at the daily Activity Plan briefing.

15

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 6.3 REASSESSMENT OF PERSONAL PROTECTION The level of protection provided by PPE selection shall be upgraded or downgraded based upon a change in site conditions or findings of investigation. The reevaluation process will be ongoing during the project. The SSO will have discretion to modify PPE ensembles as his/her observations dictate.

When a significant change occurs in the process or tasks performed, that hazard and PPE would be re-assessed. Some indicators of the need for reassessment are:

" Commencement of a new work phase, such as the start of work that begins on a different portion of the site;

" Change in job tasks during a work phase;

• Change of season/weather or ambient temperature;

• When temperature extremes or individuals medical considerations limit, the effectiveness of PPE;

• Contaminants other than those previously identified are encountered;

• Change in work scope which effects the degree of contact with contaminants;

• Capacity of personnel to work in PPE.

Before the workers actually begin work in their PPE ensembles, the anticipated duration of the work mission will be established. This will be determined at the daily tailgate safety briefing.

Situations which may limit emission length, include:

• Weather conditions;

" Job tasks;

" PPE permeation rates;

" Respirator end of service life.

6.4 STANDARD OPERATING PROCEDURES AND INSPECTION FOR PERSONAL PROTECTIVE EQUIPMENT Proper inspection of PPE features several sequences of inspection depending upon specific articles of PPE and its frequency of use. The different levels of inspection are as follows:

" Inspection and operational testing of equipment received from the factory or distributor;

• Inspection of equipment as it is issued to workers;

" Inspection before each use;

" Inspection after use training and prior to maintenance;

" Periodic inspection of stored equipment;

" Periodic inspection when a question arises concerning the appropriateness of the selected equipment, or when problems with similarequipment arise.

161

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 The following inspection list for PPE will be in use and should be implemented prior to immediate use and shall be conducted by the user. This ensures that the specific device or article has been checked out by the user and that the user is familiar with its use.

Before use:

Determine that the clothing material is correct for the specified task at hand.

Visually inspect for:

• Imperfect seams;

" Non-uniform coatings;

• Tears;

• Malfunctioning closures;

• Defects.

During the work task, periodically inspect for:

• Evidence of chemical attack such as discoloration, swelling, stiffening, and softening.

Keep in mind, however, that chemical permeation can occur without visible effects;

" Closure failure;

" Tears;

• Punctures;

• Seam discontinuities.

7.0 RESPIRATORY PROTECTION The following subsections define standard operating procedures for air purifying respirators and self-contained breathing apparatus. For more information, see CIANBRO's Safety Bulletin 5 Protection 9/7/04 All types of respiratory protection will be utilized as per the manufacturers recommendations.

The respirator will be put on in non-contaminated areas and taken off last after decontamination.

Respiratory protection will be worn in all Exclusion Zones (EZ) and Contamination Reduction Zones (CRZ) as required by the task. Deviation from or non-adherence to respirator requirements will result in removal from such area followed by disciplinary action and possible termination.

All workers will be fit tested with their specific brand/model/size of respirator prior to donning the respirator for use in contaminated areas of the job site. Appropriate documentation should be furnished to the site SSO prior to use. In the absence of appropriate documentation, the SSO will see that the worker is fit tested and that the appropriate documentation is completed. As required, all personnel donning respiratory protection will be clean shaven.

All workers will be trained in compliance with 29 CFR 1910.134, the proper use, care, limitations, maintenance, fitting, etc. of respirators. CIANBRO shall provide all respiratory protective equipment for all CIANBRO personnel and subcontractors on the site.

17

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 7.1 AIR PURIFYING RESPIRATORS Air-purifying respirators (APR) shall consist of those pieces of respiratory protection specified under Level C personal protective equipment (PPE). Typically this will consist of either a half or full-face piece cartridges respiratory fitted with the appropriate filter cartridge or canister.

7.1.1 Cartridge Change-out Frequency At the current time no planned job tasks are anticipated to utilize APR's. If conditions warrant an upgrade to Level C protection a cartridge change-out schedule will be developed as discussed at Daily Activity Plan meetings prior to donning Level C. Results of air monitoring will be utilized to determine levels of air contaminants. This data along with cartridge maximum use and end of service life levels will be utilized to determine the appropriate change-out schedule. At a minimum, cartridges will be changed daily when in use.

7.1.2 Daily Cleaning Procedure Each user of a respirator is responsible for cleaning, maintaining and inspecting his/her own respiratory protective devices. The steps to be followed for cleaning and disinfecting daily are as follows:

1. Respirator Disassembly - Respirators are taken to a clean location where the filters, cartridges or canisters are removed. For a thorough cleaning, inhalation and exhalation valves, speaking diaphragm and any hoses are to be removed.

• 2. Cleaning - In most instances the appropriate cleaning and disinfecting solution provided by the manufacturer is used and is dissolved in warm water in an appropriate tub. Using gloves, the respirator is placed in the tub and swirled for a few moments. A soft brush may be used to facilitate cleaning.

3. Rinsing - The cleaned and disinfected respirators are rinsed thoroughly in water to remove all traces of detergent and disinfectant.

4. Drying - The respirators may be allowed to air dry in the room on a clean surface. They may also be hung upside down, but care must be taken not to damage or distort the face pieces.

5. Re-assembly and Inspection - The clean, dry respirator face piece should be re-assembled and inspected in an area separate from the disassembly area to avoid contamination. Special emphasis should be given to inspecting the respirators for detergent or soap residue left by inadequate rinsing. This problem appears most often under the seat of the exhalation valve and can cause valve leakage or sticking.

18

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 7.1.3 Inspection & Checkout

1. Each respirator used will visually inspect the entire APR unit for any obvious damages, defects or deteriorated rubber.

2. Make sure that the face piece harness is not damaged. The serrated portion of the harness can fragment which will prevent proper face seal adjustment.

3. Inspect lens for damage and proper seal in face piece.

4. Exhalation Valve - Pull off plastic cover and check valve for debris or for tears in the neoprene valve (which could cause leakage).

5. Inhalation Valves (two) - Screw off cartridges/canisters and visually inspect neoprene valves for tears. Make sure that the inhalation valves and cartridge receptacle gaskets are in place.

6. Make sure a protective cover lens is attached to the lens.

7. Make sure the speaking diaphragm retainer ring is hand tight.

8. Make sure that you have the correct cartridge.

9. Don respirator and perform negative and positive pressure tests.

7.1.4 Storage of Air Purifying Respirators OSHA requires that respirators be stored to protect against dust, sunlight, heat, extreme cold, excessive moisture, damaging chemicals, and mechanical damage.

Storage of respirators should be in a clean, secure area which minimizes the chance for contamination or unsanitary conditions. APR's will be stored in a secure area.

7.2 AIR-LINE BREATHING AIR COMPRESSORS The contractor will be responsible for the operation of any air compressor. The steps to be followed for performing inspections of the air compressors are as follows:

• Prior to job startup, the contractor will conduct an air test of the compressor air to verify Grade D status. Results of this test will be maintained by the SS.

" The compressor will be set up in an area so that the exhaust from vehicles, other equipment and the compressor itself does not have an influence upon the quality of air at the air intake.

19

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 The placement of the compressor should be such that no outside contaminants could be introduced into the compressor.

• Perform required maintenance to the air compressor prior to use.

• Inspect and test emergency backup air supply. Insure that backup air supply is full.

" Oil lubricated air compressors must comply with OSHA 1910.134 and contain a temperature alarm and a carbon monoxide alarm. Alarms will be located in close proximity to the operation and monitored continuously by CIANBRO.

• In addition, all manufacturers maintenance and inspection requirements must be followed.

8.0 MEDICAL SURVEILLANCE REQUIREMENTS Medical monitoring programs are designed to track the physical condition of all personnel on a regular basis as well as survey pre-employment or baseline conditions prior to potential exposures. All personnel that have the potential to enter the CRZ or EZ will be fit for duty and able to wear respiratory protection prior to reporting to the job site. The SSO will require documentation of acceptable medical clearance prior to each worker's entry into the CRZ to EZ.

The medical surveillance program is a part of each employer's Health and Safety Program.

8.1 BASELINE & PRE-ASSIGNMENT MEDICAL MONITORING Prior to being assigned to a hazardous activity involving exposure to toxic materials, each person must have received a HAZWOPER type medical examination within the previous 12 months As suggested by NIOSH, OSHA, EPA's Occupational Safety and Health Guidance Manual:

The minimum medical monitoring requirements for work at the site is as follows:

• Complete medical and work history;

" Review of medical history and general exam by a Board Certified Physician;

• Determination of fitness for duty.

8.2 PHYSICIANS OPINION FORM All personnel authorized to enter the CRZ and/or the EZ will be required to supply proof that the appropriate medical examinations and surveillance were completed prior to the first day of work at the site. Emergency contact information and notification of allergies and/or previous medical conditions will be given to the SSO prior to work at the site. All site personnel will complete a Physicians Opinion Form, prior to entry into work areas.

20

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 8.3 HEAT STRESS EVALUATION Cianbro's Safety Bulletin 14 Exposure to Heat & Cold will be used to control Temperature extreme conditions. Temperatures inside protective equipment can be as high as 25% over external ambient temperatures with humidity near 100%. Excessive temperatures and loss of body fluids can result in a range of health conditions ranging from heat rash, cramps, exhaustion.'

heat stroke and possibly death.

Heat stress can be caused by a number of factors including workload, weather conditions, personal protective equipment, and physical condition of the individual. Work activities related to materials handling will require the use of personal protective equipment, increasing the risk of worker heat stress. Heat stress includes several types of heat related illnesses, each with specific symptoms, listed below:

• Heat rash caused by continuous exposure to heat and humid air. Decreases the body's ability to tolerate heat.

• Heat cramps caused by excessive perspiring without proper and adequate electrolyte replacement. Symptoms include:

• pain in the hands, feet, and abdomen;

• muscle spasms.

" Heat exhaustion caused from inadequate blood circulation due to cardiovascular dehydration. Symptoms include:

• pale, cool skin;

• excessive perspiring;

• fainting;

• nausea;

• dizziness.

" Heat stroke, most serious form of heat stress, body temperature regulation fails and body temperature rises rapidly. Immediate action must be taken to cool the body. Medical attention is required. Symptoms include:

• red, hot, dry skin;

• lack of perspiration;

• nausea / dizziness;

• rapid pulse;

• coma.

8.3.1 Heat Stress Management When necessary, these general controls will be used to control heat stress:

21

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005

• Workers will be given verbal instructions and reminders during tailgate safety meetings;

• The drinking of water in small volumes (about 1 cup) throughout the day will be encouraged.

• Worker will be allowed to self-limit their exposures if they detect signs and symptoms of heat strain in themselves or others;

• Individuals taking medications which may put them at greater risk, such as for blood pressure, cardiovascular medication, body temperature regulation, renal or sweat gland functions, and those who abuse or are recovering from alcoholism, will be counseled on the dangers. A healthy lifestyle will be encouraged;

" Personnel must be able to recognize signs and symptoms of heat stress and administer immediate attention;

• Work/rest schedules planned according to weather conditions, workload, and level of personal protective equipment;

" Provide shaded rest area on sunny or hot days;

• Allow personnel to become acclimated to site conditions, personal protective equipment, and workload. Rotate teams of personnel in hot weather;

• Utilize cooling devices to assist body cool down (i.e., showers, cooling jackets, etc.);

• Encourage personnel to maintain their physical fitness.

8.4 COLD STRESS Personnel working in extreme cold, even for a short time, may experience severe injury to the surface of the body (frostbite), or profound generalized cooling (hypothermia). Frostbite usually occurs to parts of the body having high surface to volume ratios, such as fingers, toes, ears, and nose. Incipient frostbite is characterized buy a blanching or whitening of the skin. Superficial frostbite is characterized by skin with a waxy or white appearance that is firm to the touch, but the skin underneath is resilient. Deep frostbite is characterized by cold pale skin that is solid to the touch.

Systematic hypothermia is caused by exposure to freezing or rapidly dropping temperature. Its symptoms include shivering, apathy, listlessness, sleepiness, unconsciousness, freezing of the extremities, and even death.

The extent of frostbite and hypothermia are influenced greatly by wind speed, wind chill and wetness of the skin. Thus the body can cool rapidly when chemical protective equipment is removed and the clothing underneath is soaked with perspiration. Workers experiencing signs of hypothermia should be immediately removed from the environment, placed in a warm location, covered with dry blankets and provided with warm liquids. Wet clothing should be removed and replaced with dry clothing and outerwear.

9.0 SITE CONTROL MEASURES The following section defines measures and procedures for maintaining site control. Site control is an essential component in the implementation of the site health and safety program. In addition 22

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 to the following, all personnel are required to sign in and out at the job site office trailer.

Whenever personnel leave the site at the end of their workday or visit, they must sign out.

9.1 WORK ZONE DEFINITION When working with hazardous substances Cianbro will define three general work zones will be established at the site. They are the Exclusion Zone (EZ), Contamination Reduction Zone (CRZ), and Support Zone (SZ). The EZ will be located only in those specific areas where potential for over exposure to the identified contaminants exists. Plans in the field office should be current and personnel should be briefed on the locations and limits of each zone.

The EZ is defined as the area where contamination is either known or likely to be present, or because of activity, will provide a potential to cause harm to personnel. This are will be denoted with material designated by the SSO.

Entry into the EZ requires the use of PPE and proper training. The EZ for this project will be established by the SSO onsite. No eating, drinking, or smoking will be permitted in this area.

The CRZ is the area where personnel conduct personal and equipment decontamination. It is essentially a buffer zone between contaminated areas and clean areas. Activities to be conducted in this zone will also require PPE and training. No eating drinking or smoking will be permitted in this area.

The SZ is situated outside the EZ and the CRZ in a clean area in which the chance to encounter hazardous materials or conditional is minimal. PPE is, therefore, not required. All external roadways leading to the site, other than those identified as possibly contaminated, are considered to be in the clean zohe. The SZ will generally be positioned upwind of the EZ when possible.

9.2 BUDDY SYSTEM During intrusive activities, the implementation of a buddy system is mandatory. A buddy system requires at least two people who work as a team, each looking out for each other, via voice or visual contact.

9.3 SITE COMMUNICATIONS Successful communications between field teams and personnel in the SZ is essential. The following communications systems may be available during activities on the site.

• Two way radios;

. Intrinsically safe radio (if deemed necessary);

• Gaitronics, or paging system

• Hand signals;

• Land line phones.

23

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005

. Site wide Alarms on the Gaitronics system 9.3.1 Hand Signals Table 9-2 Hand Signals Signal Definition Hands clutching throat Out of air - cannot breathe Hands on top of head Need assistance Thumbs up OK /I am OK / I understand Thumbs down No / Negative Arms waiving upright Trouble / Send backup support Grip partner's wrist Exit area immediately 9.4 SPILL PREVENTION CIANBRO does not anticipate and spill occurrences on this project. All CIANBRO personnel are trained to handle the materials necessary. All containers will meet legal requirements for size, shape, etc. and will be properly containerized and stored. Cianbro's Safety Bulletin 12 Hazard Communication Program shall be used in the event of a spill.

Miscellaneous spills may inadvertently occur from potential machinery and equipment leaks. In the event that an oil spill is observed on site, CIANBRO will use oil absorbent materials to prevent migration. Once absorbed, the used material will be properly stored and disposed of.

All spills will be immediately reported to the YAEC Security Control Room and the SSO.

10.0 DECONTAMINATION PLAN Decontamination involves the orderly, controlled removal of contaminants. Standard decontamination sequences are presented in the examples below. All site personnel should minimize contact with contaminants, when conceivable, in order to minimize the need for extensive decontamination.

Personnel decontamination will consist of safe work practice, use of disposable PPE, personal hygiene, and personal decontamination before breaks and at the completion of each day.

Decontamination for workers using Modified Level D and Level C is described below. In the case Level B PPE is utilized on the site, specific decontamination procedures for Level B will be thoroughly discussed on site prior to donning Level B. The level of protection for decontamination personnel will be one level lower that the personnel exiting the EZ.

24

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 For radiological decontamination all Cianbro personnel will follow the guidance of the Radiological Control Department of YAEC.

10.1 ROUTINE PERSONAL DECONTAMINATION

1. All liquid resistant suits will be scrubbed with water and industrial soap solution, if needed, in a total body wash pool with a long handle brush, followed by a fresh water rinse. The boots will be included in this step of the decontamination.

2. Disposable coveralls will be removed and placed in a plastic trash bag.

3. Disposable gloves will be removed and placed in a plastic trash bag.

4. Respirators will be decontaminated with a damp paper towel prior to removal to remove gross contamination as required. Respirators shall be washed in a respirator sanitizing solution, rinsed and then air-dried at least daily, when in use.

5. Hands, face and any other potentially contaminated area will be thoroughly washed with a water/mild soap solution, rinsed and dried with paper towels.

6. Hard hats shall be thoroughly washed with a water/industrial soap solution, rinsed and dried.

(OR, the dirty hard hat may be kept in the EZ for reuse there)

7. If leather/cotton work gloves are used, they will be removed and stored in the work area.

10.1.1 Level C Decontamination Station 1: Equipment Drop Deposit equipment used on site (tools, sampling devices and containers, monitoring instruments,' radios, clipboards, etc.) on plastic drop cloths. Segregation at the drop reduces the probability of cross contamination. During hot weather operations, cool down stations may be set up within this area.

Station 2: Outer Garment, Boots, and Gloves, Wash Rinse Wash outer boots, outer gloves and splash suit (if being used) with water and detergent solution. Rinse off using large amount of water.

Station 3: Outer Boot and Glove Removal Remove outer boots and gloves. Place in storage area.

Station 4: Canister or Mask Change If worker leaves the EZ to change canister (or mask), this is the last step in the decontamination procedure. Worker's canisters are exchanged. New outer gloves and boot covers donned, joints taped and worker returns to duty.

Station 5: Boot, Gloves and Outer Garment Removal Boots, chemical resistant splash suit (if being used), inner gloves removed and deposited in storage area.

Station 6: Field Wash 25

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 Hands and face are thoroughly washed.

10.1.2 Level D & D Modified Decontamination Station 1: Equipment Drop Deposit equipment used on site (tools, monitoring instruments, radios, clipboards, etc.)

on plastic drop cloths. Segregation at the drop reduces the probability of cross contamination. During hot weather operations, cool down stations may be set up within this area.

Station 2: Outer Garment, Boots, and Gloves, Wash Rinse Wash outer boots, outer gloves and splash suit (if being used) with water and detergent solution. Rinse off using large amount of water.

Station 3: Outer Boot and Glove Removal Remove outer boots and gloves. Place in storage area.

Station 5: Boot, Gloves and Outer Garment Removal Boots, chemical resistant splash suit (if being used), inner gloves removed and deposited in storage area.

Station 6: Field Wash Hands and face are thoroughly washed.

10.2 EMERGENCY DECONTAMINATION Should workers be splashed with hazardous chemical contaminants, the worker. will immediately be escorted to the field decontamination station and be decontaminated as follows:

1. Wash off under pressurized shower or sprayer

2. Remove all 'contaminated clothing

3. Remove all wet clothing

4. Cover with blanket or-dress in clean, dry clothing

5. Transport to hospital if necessary 10.3 EQUIPMENT DECONTAMINATION All earthmoving/transportation equipment and temporary sheeting in contact with contaminats will be decontaminated with a dry decontamination method, high pressure steam, or pressure washer at the decontamination pads prior to the removal of the equipment from the site.

11.0 ILLUMINATION & SANITATION 26

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 11.1 ILLUMINATION Site operations will cease in time to permit personnel to exit the EZ and-secure the site prior to

• dusk.Conversely, operations will not begin until lighting is adequate at dawn. If work schedules require work outside of these parameters, then portable lights, sufficient to provide adequate lighting, 'will be provided.

11.2 SANITATION Portable restrooms sufficient to meet the requirements of 29 CFR 1910.120(n) will be provided.

Potable water will be provided for workers at each work area. Hand and face wash as well as respirator sanitizing supplies will be available on site in sufficient quantities for all employees.

11.3 HOUSEKEEPING To minimize potential accidents and cross contamination, the site will be maintained in a generally clean condition. Personal waste materials, such as PPE, paper towels, and respirator cartridges, etc. will be disposed of in waste containers.

This site will be set up so as to be reasonably free from significant safety hazards. Wires and hoses will be positioned so they do not obstruct or present a safety hazard in walkways and evacuation routes. Staged equipment and materials from the EZ will be positioned in the CRZ while not in use until cleaned for removal from the site.

12 MERGENCY PROCEDURES This section describes contingencies and emergency procedures to be implemented at the site.

This plan should be coordinated with the -local authorities disaster and emergency management plans as appropriate. In addition, meetings or other communication with the local hospital, rescue squad, hazardous materials unit and fire department will occur so as to advise the emergency response representatives of the nature and type of contaminants victims may have been exposed to while on site. Directions to the hospital will be posted on site when this' HASP is in effect.

Emergency procedures will be posted and covered indaily site briefings.

12.1 PRE-EMERGENCY PLANNING The Site Supervisor will ensure that Cianbro has established appropriate lines of communications with local hospitals, government agencies and other emergency response organization prior to site activities. During the site briefings'held periodically, all employees will be trained in and reminded of provisions of the emergency response plan, communications systems, and evacuation routes.

27

2Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 12.2 EMERGENCY EQUIPMENT & FACILITIES The following emergency equipment will be available at the site:

" First Aid Kit;

• Fire Extinguisher, appropriate to potential fire hazards;

• Potable Eye Wash, near any areas of chemical use or splashing;

• Emergency Shower, potable water garden hose, or pressurized sprayer;

• Two-way Radio;

• Chemical Spill Kits and/or absorbents.

Generally emergency equipment will be stored in the CRZ. If during the period of operation, the CRZ should be located at such a distance for the work that, in the opinion of the SS, it is not feasible to store the emergency equipment at that location, a mobile unit, such as a pickup truck will be employed as the temporary location.

12.3 PERSONNEL ROLES AND LINES OF AUTHORITY The PM/SSO has primary responsibility for responding to and correcting emergency situations.

This includes taking appropriate measure to ensure the safety of site personnel and the public.

Possible actions may involve evacuation of adjacent personnel. Additionally, they are responsible for ensuring that corrective measures have been implemented, appropriate authorities notified, and follow up reports completed.

12.4 ACCIDENT & ILLNESS REPORTS Notes:

1. The YAEC Project Manager (PM) will be notified within 60 minutes of any spill, crime, vandalism, evacuation or personal or property damage to any site worker or the general public.

2. Any inquires by the general public, news media or regulatory agencies will be referred to the YAEC PM.

Written confirmation of verbal reports are to be submitted within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />..

12.5 EVACUATION PROCEDURES If anyone discovers a fire, chemical spill or release, or other process upset necessitating emergency action, he or she will immediately notify the PM, SSO or Security Control Room. An immediate decision will be made as to whether to evacuate the site or other actions to be taken.

The SSO is primarily responsible for this decision.

28

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 An evacuation map will be developed and posted onsite (typically in the job trailer) and will be reviewed at a Toolbox Safety meeting prior to work. The evacuation map shall show 2 entrances/exits and offsite assembly points.

The primary response to any emergency will be to protect the health and safety of employees, contractors and visitors on site, as well as the community and environment. Steps will be taken to identify, contain, treat, and properly dispose of the materials involved as a secondary response.

In the event of an emergency that necessitates an evacuation of the site, the following alarm procedures will be implemented:

12.5.1 Alerting System On site - Paging system and two way radios are the primary systems for alerting personnel.

When notified to evacuate, all personnel will be expected to proceed to the closest site exit with their buddy, and mobilize to the predetermined safe distance area associated with the evacuation route. Personnel will remain at that area until the re-entry alarm is sounded or an authorized individual provides further instructions. Air horns will be located in the work area.

In general, employees should proceed to a designated meeting location that is upwind and uphill from the site or location of the incident, unless otherwise instructed by supervisory personnel. A wind socks and /or flagging will be employed on site to indicate the upwind direction to which evacuation should proceed.

12.5.2 Emergency Contacts,& Notification Systems The following tables provide names and telephone numbers for emergency contact personnel and key project contacts. It will be kept on site for the duration of the project. In the event of a medical emergency, personnel will take direction for the PM/SS/SS and notify the appropriate emergency organization. In the event of a fire or spill, the site supervisor will ensure that the appropriate local, state, and federal agencies are notified. Prior to posting, the SS/SS shall confirm the appropriate contact names and phone numbers are listed.

29

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 EMERGENCY CONTACT LIST POLICE, AMBULANCE, FIRE, HOSPITAL ....... 911

• Rowe Police Department ................................................................ (413) 339-5546

" Rowe Fire Department ............. ....... .............. (413) 339-4001

• Baystate Ambulance Service ....................................................... (413) 773-4100

" Primary Hospital (Franklin Medical Center) ............................... (413) 773-0211 164 High Street, Greenfield, MA 01301 Map to Hospital: See Figure 13-1 and/or Attachment 7

" NIOSH Technical Information Line ............................................ (800) 356-4674

" Massachusetts Poison Information Center ................................... (800) 682-9211

" EPA National Response Center ...................... (800) 424-8802

" DEP W estern Region ................................................................... (413) 784-1100

• EPA National Response Center ................................................... (800) 424-8802

• NIOSH Technical Information Line ............................................ (800) 356-4674

• Poison Control Center ................................................................. (800) 962-1253 PERSONNEL PHONE NUMBERS

• Cianbro Construction - Headquarters .......................................... Phone (413) 424-2486

• Cianbro Construction Personnel:

• Project Manager: Bob Seegmiller ................ Phone: (413) 424-2485 o Site Supervisor: Brigitte Reid Phone (413) 424-2484:

Yankee Atomic Electric Personnel:

o Project Manager, Norm Rademacher ............................... Phone: (413) 424-2264 30

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 12.6 EMERGENCY MEDICAL TREATMENT Any person who becomes ill or injured must notify the Security Control room immediately.

They will determine what the appropriate medical requirements will be. In the event that the injury' is in the EZ must be decontaminated to the maximum extent possible. If the injury or illness is minor, full decontamination should be completed and first aid administered prior to transport. If the patient's condition is life threatening, at least partial decontamination should be completed (i.e., complete disrobing of the victim and redressing in clean coveralls or wrapping in a blanket. First aid should be administered while awaiting an ambulance or paramedics. All injuries and illnesses must be immediately reported to the SSO.

Any person being transported to a clinic or hospital for treatment will take with them information on the chemical(s) they have been exposed to at the site, along with a copy of the individual's Medical Data Sheet, Attachment 3.

12.6.1 Directions to Hospital Prior to the start of work, the PM, SSO or SSO shall confirm the nearest hospital's location and phone number. This information along with directions from the site to the facility shall be posted in the office trailer.

SITE ADDRESS: HOSPITAL ADDRESS:

Yankee Rowe Franklin Medical Center 49 Yankee Road 164 High Street Rowe, MA 01367 Greenfield, MA 01301 (413) 773-0211 DIRECTIONS TO HOSPITAL:

Go Southwest on Yankee Road Continue onto Monroe Hill Road Turn Right on to Hazelton Road Bear Left onto Tunnel Road Bear left onto Brittingham Hill Road Turn Right onto Zoar Road Continue onto Rowe Road Turn Left on Zoar Road Turn Left onto Route 2, into Greenfield' At rotary take the first exit to Route 2A Turn Left to stay on Route 2A, High Street Franklin Medical Center, Follow signs for emergency care.

31

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 12.7 FIRE & EXPLOSION PROCEDURES In the event of a fire or explosion, the Security Control Room shall be notified immediately.

They will determine if the local Fire Department should be summoned. Upon their arrival, the Control Room Supervisor will advise the fire commander of the location, nature, and identification of the hazardous materials on site. Alert office personnel to wait at site entrance to direct emergency response units to the emergency.

If it is safe to do so, site personnel may:

1. Use fire fighting equipment available on site to control or extinguish the fire, and

2. Remove or isolate flammable or other hazardous materials which may contribute to the fire.

12.8 SPILL & LEAK PROCEDURES In the event of a spill or leak that may enter any sanitary sewerage pipeline, storm sewer or other off-site conveyance, site personnel will:

1. Notify the Security Control Room

2. Inform supervisor immediately

3. Terminate work activities (at the discretion of the SS)

4. Prevent entry of spill materials into any waterways

5. Follow site emergency notification and evacuation procedures, when necessary

6. Locate the source of spillage and stop the flow if it can be done safely

7. Begin containment and recovery of the spilled materials if it can be done safely.

If the spill or release is expected to pose significant hazards or is beyond the capabilities of the immediate personnel, then the SSO will be contacted immediately. When contacted, the SSO will obtain and assess the following information:

1. The material spilled or released

2. Location of the release or spill

3. An estimate of the quantity released and the rate at which it is being released

4. Any injuries involved

5. Fire and/or explosion'or possibility of these events occurring

6. The area and materials involved in the location of the fire or explosion In the event of a chemical spill that is not contained within a dike or bermed area, an area of isolation will be established around the spill and the material(s) involved. When any spill occurs, only those persons involved in the oversight or performance of the emergency cleanup operations will be allowed within the designated hazard area. If possible, this area will be roped or otherwise blocked off.

32

Demolition Activities, Yankee Nuclear-Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 If an incident may threaten the health or safety of the surrounding community, the public will be informed and possibly evacuated from the area. The PM/SSO will inform the proper agencies in the event that this is necessary. The telephone numbers of emergency response organizations are listed above and also in Attachment 7.

If the control and cleanup of the spill or release is within the capabilities of onsite personnel and the release does not migrate beyond the perimeter of the site, the PM/SS will determine reporting requirements. Reporting of spills or releases in accordance with other federal, state and local regulations is also the responsibility of the PM/SS.

12.8.1 Spill Containment Equipment In the chance a spill does occur, CIANBRO, will be equipped with the following spill or containment equipment:

• Loose dry absorbent (i.e. sawdust, vermiculite, multipurpose sorbent);

" Oil containment booms ;

• Shovels - wooden handle, steel type;

" Brooms - wooden handle, push type;

• Wrenches and tools for tightening fittings and valves.

12.9 INCIDENT FOLLOW-UP AND CRITIQUE Following all emergency response actions and activation of this plan, the PM/SS will conduct a debriefing session of all key personnel involved. The response will be critiqued, documented, and response plans revised, if necessary. Corrective actions will be listed where procedures were inadequate or need improvement. Responsible persons will be listed and held accountable for follow-up.

13.0 INSPECTION PROGRAM 13.1 INSPECTIONS REPORTING AND RECORDKEEPING CIANBRO's Project Manager and Site Supervisor will coordinate inspections of CIANBRO's operations. Inspections will be conducted according to the schedule outlined in the following sections..

General Facility: Personnel will be observed to ensure compliance with health and safety requirements, in particular the use of personal protective equipment. The availability of usable safety and emergency equipment will be verified.

33

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 13.1.1 Safety Inspections Periodic site safety inspections will be performed by the SSO during the operational phase of the Yankee Rowe Site. The purpose of these safety inspections is to ensure personnel are performing their duties in the safest manner possible and provide continuing analysis and modification to the safety program. Records of inspection shall be kept onsite.

13.1.2 General Facility Inspections Inspections of the general facility will focus on the consistent compliance with safety requirements and availability of safety and emergency gear. The focus of these inspections is listed in Table 14-1, General Facility Inspection Schedule. The frequency of these inspections may be altered/amended as deemed necessary by CIANBRO's SSO. Records of inspection shall be kept onsite.

Table 13-1 General Facility Inspection Schedule SPECIFIC ITEMS TYPES OF PROBLEMS FREQUENCY Electrical lines Frays, splices, trip hazards Weekly Non-emergency lighting Bulbs burned out or Weekly missing All personnel trained New workers may not Once per work shift know emergency procedures All personnel using May not be complying with Once per work shift appropriate PPE PPE requirements Fire extinguishers Broken seal, inadequate Weekly/After use pressure, access blocked Emergency alarms Power or battery failure Weekly/After use Self-contained breathing Inadequate air supply Weekly/After use apparatus Cartridges, respirators Inadequate supply of new Weekly cartridges, damaged seals or straps Face shields, safety glasses Inadequate supply, Weekly damaged or scratched lenses Hard hats, boot covers, Inadequate supply, Weekly construction boots damaged Gloves, glove liners Inadequate supply, Weekly damaged 34

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 Chemical-resistant suits Inadequate supply, Weekly damaged Moistureproof chemical- Inadequate supply, Weekly resistant suits damaged Eyewashes Low liquid level Weekly/After use First-aid supplies Low stock Weekly/After use Emergency lights Battery or bulb failure Weekly Personal protective gear will be maintained in the personnel decontamination area, with additional emergency supplies kept in the administrative trailer. First Aid supplies are kept in the personnel decontamination area, with additional stations located at strategic positions onsite.

13.1.3 Cianbro Guard Devices The following devices will be present on equipment to be used at the site:

• Self-propelled equipment will be equipped with a reverse signal alarm, sufficiently audible during equipment operation.

• Sprockets, gears, pulleys, belts, flywheels, chains, shafts, or other moving parts will be guarded.

" Hot surfaces will be guarded/insulated and labeled accordingly.

• Equipment to be operated/supervised by personnel will be provided with the appropriate guardrails, toe boards, hand grabs, walkways, steps, and platforms.

• No guards or safety devices will be removed during the operation of the equipment.

Maintenance will be performed when equipment is inoperative.

• All guarded equipment will be checked prior to use.

35

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 SAFETY BULLETIN INDEX

1. Ergonomics-Backs and Soft Tissues 03/06/2001

2. Blasting Operations Program 09/16/02

3. Office Ergonomics and VDT's 11/04/2002

4. Excavation Safety 09/16/02

5. Respiratory Protection 9/7/04

6. Workplace Protection Program for Lead and other Heavy Metals 12/02/2004

7. Watch for Fire, Smoke and Sparks 11/22/2004

8. Safe Rigging Operations 11/16/2004

9. Concrete Demolition 10/01/2002

10. Hearing Conservation Program 01/2003

11. Fall Protection Program 6/2/2004

12. Hazard Communication Program 11/15/2004

13. Operating a Chain Saw Safely 6/30/2000

14. Exposure to Heat & Cold 7/5/2001

15. Welding and Cutting Hazard Assessment 09/16/02

16. Zero Energy State (ZES) Lock-Out/Tag Out 02/17/04

17. Hand and Finger Protection 11/22/2004

18. OSHA Recordable Cases 01/08/2002

19. Confined Space Entry 12/01/2004 19A. Confined Space Rescue Team 12/01/2004

20. Electrical Safety Program 12/23/04

21. Eye Protection 11/22/2004

22. Hoisting Personnel is the Last Resort 9/30/03

23. Incident Investigation 12/01/2004

24.

• This bulletin has been temporarily retired. *

25. Bloodborne Pathogens 11/22/2004

26. Scaffold Safety is Everyone's Responsibility 11/18/2004

27. Guidelines for Establishing a Safety Health Awareness Raises Excellence Committee 12/31/01

28. Crane Safety 11/16/2004

29. Safe Handling and Storage of Compressed Gas 7/3/2001

30. Placing Concrete 06/30/2000

31. Personal Protective Equipment 8/23/04

32.

• This bulletin has been temporarily retired. *

33. Elevating Work Platforms 09/19/02

34. Workplace Crystalline Silica Protection Program 10/9/02

35. Work Zone Traffic Control 2/14/2000

36. Lyme Disease and West Nile Virus 11/22/2004

37. Fleet Operations and Driver Safety 05/17/04

38. Injury Management 11/22/2004

39. Safety Accountability 9/7/04

40. Work Area Barricade Protection 1/28/2002 36

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005

41. Water Rescue Safety 07/23/2003

42. Automatic External Defibrillators (AEDs) 11/22/2004 37

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 International Chemical Safety Cards 2,3,7,8-TETRACH LORODIBENZO-p- ICSC: 1467 DIOXIN Dibenzo b,e 1,4dioxin, 2,3,7,8-tetrachloro-2,3,7,8-TCDD 2,3,7,8-Tetrachloro-1,4-dioxin C 12 H 4 Cl 4 0 2 Molecular mass: 322 ICSC # 1467 CAS # 1746-01-6 RTECS # HP3500000 UN # 2811 -

November 26, 2003 Peer reviewed

~FIRSTA ID/

~ 4 ,

O F~ A ACTE C HAZARD / -

~EXPOJRi SYPOSFREFGTN Gives off irritating or In case of fire in the toxic fumes (or gases) surroundings: powder, in a fire. water spray, foam, carbon dioxide.

AVOD LLCONTACT! [IN ALL CASES CONSULT A DOCTOR!

Chloracne. ymptoms Use appropriate Fres air, rest. Refer for may be delayed. lengineering controls. imedical attention.

MAY BE ABSORBED! Protective gloves. Remove contaminated (See Inhalation). Protective clothing. clothes. Rinse and then Redness. Pain. wash skin with water and soap. Refer for medical attention.

Redness. Pain. Face shield, or eye First rinse with plenty protection in of water for several combination with minutes (remove breathing protection, contact lenses if easily possible), then take to a doctor.

I(See Inhalation). IDo not eat, drink, or [Give a slurry of 38

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 smoke during work. activated charcoal in Wash hands before water to drink., Induce eating. vomiting (ONLY IN CONSCIOUS PERSONS!). Refer for medical attention.

Evacuate danger area! Separated from food and Consult an expert! Chemical feedstuffs. R:

protection suit including self- S:

contained breathing UN Hazard Class: 6.1 apparatus. UN Packing Group: I SEE 41RA,YT MFORMAfi?5t ONNBACK Prepared in the context of cooperation between the International Programme on Chemical Safety & the Commission of the European Communities (C) IPCS' CEC ICSC: 1467 1994. No modifications to the International version have been made except to add the OSHA PELs, NIOSH RELs and NIOSH IDLH values.

39

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 International Chemical Safety Cards ICSC: 1467 2,3,7,8-TETRACH LORODIBENZO-p-DIOXIN PHYSICAL STATE; ROUTES OF EXPOSURE:

APPEARANCE: The substance can be absorbed COLOURLESS TO WHITE NEEDLE- into the body by inhalation of LIKE CRYSTALS dust, through the skin and by ingestion.

PHYSICAL DANGERS:

INHALATION RISK:

Evaporation at 20 0 C is negligible; CHEMICAL DANGERS: a harmful concentration of The substance decomposes on airborne particles can, however, heating to 750-800 0 C and under be reached quickly when the influence of UV light dispersed.

producing chlorine EFFECTS OF SHORT-TERM OCCUPATIONAL EXPOSURE EXPOSURE:

LIMITS: The substance is irritating, to the TLV not established. eyes , the skin and the MAK: 10-8 mg/m 3 ; H; respiratory tract . The substance Peak limitation category: 11(8); may cause effects on the Carcinogen category: 4; cardiovascular system, Pregnancy risk group: C; gastrointestinal tract , liver (DFG 2003). nervous system and endocrine system . The effects may be delayed.

EFFECTS OF LONG-TERM OR REPEATED EXPOSURE:

Repeated or prolonged contact with skin may cause dermatitis.

The substance may have effects on the bone marrow, endocrine system , immune system , liver and nervous system . This substance is carcinogenic to humans. Animal tests show that this substance possibly causes toxicity to human- reproduction or development.

Melting point: 305-306 0 C Solubility in water: none Density: 1.8 Vapour pressure, Pa at 25 0 C:

g/cm3 negligible Octanol/water partition coefficient 40

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 F[ as log Pow: 6.8-7.02 The substance is very toxic to aquatic organisms. This substance may be hazardous in the environment; special attention should be given to soil contamination. Bioaccumulation of this chemical may occur in fish,in plants, in mammals and in milk. It is strongly advised that this substance does not enter the environment.

N..T Es' his chemical is only produced for research purposes, but could be generated as a by-product from chemical processes or fires.

Transport Emergency Card: TEC (R)-61GT2-I Neither NIOSH, the CEC or the IPCS nor any person acting on behalf of NIOSH, the CEC or the IPCS is responsible for the use which might be made of this information. This-card contains the collective views of the IPCS Peer Review Committee and may not reflect in all cases all the IMPORTANT detailed requirements included in national legislation on the subject.

LEGAL NOTICE:

The user should verify compliance of the cards with the relevant legislation in the country of use. The only modifications made to produce the U.S. version is inclusion of the OSHA PELs, NIOSH RELs and NIOSH IDLH values.

Neither NIOSH, the CEC or the IPCS nor any person acting on behalf of NIOSH, the CEC or the IPCS is responsible for the use which might be made of this information. This card contains the collective views of the IPCS Peer Review Committee and may not reflect in all cases all the IMPORTANT detailed requirements included in national legislation on the subject.

LEGAL NOTICE:

The user should verify compliance of the cards with the relevant legislation in the country of use. The only modifications made to produce the U.S. version are inclusion of the OSHA PELs, NIOSH R.ELs and NIOSH IDLH values.

41

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 International Chemical Safety Cards POLYCHLORINATED BIPHENYL ICSC: 0939 (AROCLOR 1254)

Chlorobiphenyl (54%

chlorine)

Chlorodiphenyl (54% chlorine)

PCB Molecular mass: 327 (average)

ICSC # 0939 CAS # 11097-69-1 RTECS # TQ1360000 UN # 2315 EC # 602-039-00-4 October 20, 1999 Peer reviewed Not combustible. Gives In case of fire in the off irritating or toxic surroundings: powder, fir~umes (or gases) in a carbon dioxide.

fire EDS 'PREVENT GENERATION R OF MISTS ! STRICT IoHYGIENE!

Ventilation. Fresh air, rest. Refer for l /AY BABOBD Protective glvs Dry skin. Redness. Protective clothing emove cnaiae Imedical attention.

Iclothes. Rinse and then o iwash skin with water land soap. Refer for fmedical attention.

Safety goggles, face First rinse with plenty shield. of water for several minutes (remove contact lenses if easily possible), then and theo andoa. Rer f 42

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 Headache. Numbness. Do not eat, drink, or smoke during work. attention.

Rest. Refer for medical

!L.P 'LLAC"F D Iq PR*4;A I Consult an expert! Collect Separated from food and Unbreakable packaging; put leaking liquid in sealable feedstuffs . Cool. Dry. Keep breakable packaging into containers. Absorb remaining in a well-ventilated room. closed unbreakable liquid in sand or inert container. Do not transport absorbent and remove to with food and feedstuffs.

safe place. Do NOT let this Severe chemical enter the marine pollutant.

environment. Personal Note: C protection: complete Xn symbol protective clothing including N symbol self-contained breathing R: 33-50/53 apparatus. S: 2-35-60-61 UN Hazard Class: 9 UN Packing Group: II IM R.RTAWTTFORIj NO4iAI Prepared in the context of cooperation between the International Programme on Chemical Safety & the Commission of the European Communities (C) IPCS CEC ICSC: 0939 1994. No modifications to the International version have been made except to add the OSHA PELs, NIOSH RELs and NIOSH IDLH values.

43

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 International Chemical Safety Cards POLYCHLORINATED BIPHENYL ICSC: 0939 (AROCLOR 1254)

PHYSICAL STATE; ROUTES OF EXPOSURE:

APPEARANCE: The substance can be absorbed LIGHT YELLOW VISCOUS LIQUID. into the body by inhalation of its aerosol, through the skin and by PHYSICAL DANGERS: ingestion.

INHALATION RISK:

CHEMICAL DANGERS: A harmful contamination of the The substance decomposes in a air will be reached rather slowly fire producing irritating and toxic on evaporation of this substance gases . at 201C.

OCCUPATIONAL EXPOSURE EFFECTS OF SHORT-TERM LIMITS: EXPOSURE:

TLV: 0.5 mg/m 3 as TWA; (skin);

A3; (ACGIH 2004).

MAK: 0.05 ppm, 0.70 mg/m 3 ; H; EFFECTS OF LONG-TERM OR Peak limitation category: 11(8); REPEATED EXPOSURE:

Carcinogen category: 3B; Repeated or prolonged contact Pregnancy risk group: B; with skin may cause dermatitis.

(DFG 2004). Chloracne is the most visible OSHA PEL: TWA 0.5 mg/m 3 skin effect. The substance may have NIOSH REL: Ca TWA 0.001 effects on the liver. Animal tests mg/m 3 See Appendix A *Note: show that this substance possibly The REL also applies to other causes toxic effects upon human PCBs. reproduction.

NIOSH IDLH: Potential 3 occupational carcinogen 5 mg/m Relative density (water = 1): 1.5 Vapour pressure, Pa at 25OC: 0.01 Solubility in water: Octanol/water partition coefficient none ' as log Pow: 6.30 (estimated)

SIn the food chain important to humans, bioaccumulation takes place, specifically in aquatic organisms. It is strongly advised not o let the chemical enter into the environment.

hanges into a resinous state'(pour point) at 10 0 C. Distillation range: 365 0 -390 0 C. Card has been partly updated in October 2004. See sections Occupational Exposure Limits, EU classification, Emergency Response.

Transport Emergency Card: TEC (R)-90GM2-II-L 44

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 Neither NIOSH, the CEC or the IPCS nor any person acting on behalf of NIOSH, the CEC or the IPCS is responsible for the use which might be made of this information. This card contains the collective views of the IPCS Peer Review Committee and may not reflect in all cases all the IMPORTANT detailed requirements included in national legislation on the subject.

LEGAL NOTICE:

The user should verify compliance of the cards with the relevant legislation in the country of use. The only modifications made to produce the U.S. version are inclusion of the OSHA PELs, NIOSH RELs and NIOSH IDLH values.

Neither NIOSH, the CEC or the IPCS nor any person acting on behalf of NIOSH, the CEC or the IPCS is responsible for the use which might be made of this information. This card contains the collective views of the IPCS Peer Review Committee and may not reflect in all cases all the IMPORTANT detailed requirements included in national legislation on the subject.

LEGAL NOTICE:

The user should verify compliance of the cards with the relevant legislation in the country of use. The only modifications made to produce the U.S. version are inclusion of the OSHA PELs, NIOSH RELs and NIOSH IDLH values.

45

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 International Chemical Safety Cards ICSC: 1052 BARIUM Ba Atomic mass: 137.3 ICSC # 1052 CAS # 7440-39-3 RTECS # CQ8370000 UN # 1400 October 20, 1999 Peer reviewed AUEHAZARDS!

SYMPTOMS FIS IEFGTN AID/

SEXPOSUREENI~N Flammable. Many NO open flames, NO Special powder, dry reactions may cause sparks, and NO sand, NO hydrous fire or explosion, smoking. NO contact agents, NO water.

with water>

Finely dispersed Prevent deposition of particles form explosive dust; closed system, mixtures in air. dust explosion-proof electrical equipment and lighting.

PREVENT DISPERSION EOF DUST! STRICT I FHYGIE NE!.

Cough. Sore throat. Local exhaust or Fresh air, rest. Refer for

[breathing protection. Imedical attention.,

Redness. Protective gloves. Remove contaminated clothes. Rinse skin with plenty of water or shower. Refer for mnedical attention.

Redness. Pain. Safety goggles. First rinse with plenty of water for several minutes (remove contact lenses if easily possible), then take to a doctor.

IDo not eat, drink, or Rinse mouth. Refer for 46

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 I

Ismoke during work. Imedical attention.

Sweep spilled substance into Separated from halogenated sealable containers. Carefully solvents, strong oxidants, R:

collect remainder, then acids. Dry. Keep under inert S:

remove to safe place. gas, oil or oxygen-free liquid. UN Hazard Class: 4.3 Chemical protection suit UN Packing Group: II including self-contained breathing apparatus. Do NOT wash away into sewer.

TMPflTANT

.~QF:Fi Th~lnjrMATjTfN'nFlIn PRAfJ( :ik- .

Prepared in the context of cooperation between the International Programme on Chemical Safety & the Commission of the European Communities (C) IPCS CEC ICSC: 1052 1994. No modifications to the International version have been made except to add the OSHA PELs, NIOSH RELs and NIOSH IDLH values.

International Chemical Safety Cards ICSC: 1052 BARIUM PHYSICAL STATE; ROUTES OF EXPOSURE:

APPEARANCE: The substance can be absorbed YELLOWISH TO WHITE into the body by ingestion.

LUSTROUS SOLID IN VARIOUS FORMS. INHALATION RISK:

PHYSICAL DANGERS:

Dust explosion possible if in EFFECTS OF SHORT-TERM powder or granular form, mixed EXPOSURE:

with air. The substance irritates the eyes, the skin and the respiratory tract.

CHEMICAL DANGERS:

The substance may EFFECTS OF LONG-TERM OR spontaneously ignite on contact REPEATED EXPOSURE:

with air (if in powder form). The substance is a stropg reducing agent and reacts violently with oxidants and acids. Reacts violently with halogenated solvents. Reacts with water, forming flammable/explosive gas (hydrogen - see ICSC0001),

causing fire and explosion hazard.

47

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 OCCUPATIONAL EXPOSURE LIMITS:

TLV: ppm; 0.5 mg/m 3 (as TWA)

(ACGIH 1999).

Boiling point: 1640 0 C Solubility in water: reaction Melting point: 725 0 C Density: 3.6 g/cm3 Reacts violently with tire extinguishing agents such as water, bicarbonate, powder, toam, and carbon dioxide. Rinse contaminated clothes (fire hazard) with plenty of water.

Transport Emergency Card: TEC (R)-43G12 Neither NIOSH, the CEC or the IPCS nor any person acting on behalf of NIOSH, the CEC or the IPCS is responsible for the use which might be made of this information. This card contains the collective views of the IPCS Peer Review Committee and may not reflect in all cases all the IMPALORTA  : detailed requirements included in national legislation on the subject.

LEGAL NOTICE:

The user should verify compliance of the cards with the relevant legislation in the country of use. The only modifications made to produce the U.S. version are inclusion of the OSHA PELs, NIOSH RELs and NIOSH IDLH values.

48

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 International Chemical Safety Cards 1,4- D IOXAN E ICSC:0041 1,4-Diethylene dioxide 1,4-Diethyleneoxide C4 H80 2 Molecular mass: 88.1 ICSC # 0041 CAS # 123-91-1 RTECS # JG8225000 UN # 1165 EC # 603-024-00-5 April 26, 1993 Peer reviewed HAZAiRD/ i-~' I RVNINFRTAD E~XPOSURE~

-~ 'SYMWPTOM'S' j ~PEETO ~ -

~~ FIRE FIGHTING ~~

Highly flammable. NO open flames, NO Powder, alcohol-sparks, and NO resistant foam, water smoking. NO contact spray, carbon dioxide.

with strong oxidants.

NO contact with hot surfaces.

Vapour/air mixtures are Closed system, In case of fire: keep explosive. Risk of fire ventilation, explosion- drums, etc., cool by and explosion on proof electrical spraying with water.

contact with equipment and lighting.

incompatible materials: Prevent build-up of see Chemical Dangers. electrostatic charges (e.g., by grounding).

Do NOT use compressed air for filling, discharging, or handling. Use non-sparking hand tools.

_______AVOID ALL CONTACT! _

Headache. Nausea. Ventilation, local Fresh air, rest. Refer for Cough. Sore throat. exhaust, or breathing medical attention.

-Abdominal pain. protection.

3Dizziness. Drowsiness.

Vomiting.

49

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 IUnconsciousness. I__

MAY BE ABSORBED! Protective gloves. Remove contaminated Redness. Protective clothing, clothes. Rinse skin with plenty of water or shower.

Redness. Pain. Watery Face shield, or eye First rinse with plenty eyes. protection in of water for several combination with minutes (remove breathing protection. contact lenses if easily possible), then take to a doctor.

(Further see rDo not eat, drink, or Rinse mouth. Refer for tInhalation). smoke during work. medical attention.

Collect leaking and spilled Fireproof. Separated from Airtight.

liquid in sealable containers strong oxidants, strong F symbol as far as possible. Wash acids. Cool. Dry. Keep in the Xn symbol away remainder with plenty dark. Store only if stabilized. R: 11-19-36/37-40 of water. (Extra personal S: 16-36/37 protection: complete UN Hazard Class: 3 protective clothing including UN Packing Group: II self-contained breathing apparatus).

MP RSE A N I NF 0RMKATAIN ON 'BACK Prepared in the context of cooperation between the International Programme on ICSC: 04 Chemical Safety & the Commission of the European Communities (C) IPCS CEC 1994. No modificationsto the International version have been made except to add the OSHA PELs, NIOSHRELs and NIOSH IDLH values.

50

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 International Chemical Safety Cards ICSC: 0041 1,4-DIOXANE PHYSICAL STATE; ROUTES OF EXPOSURE:

APPEARANCE: The substance can be absorbed COLOURLESS LIQUID , WITH into the body by inhalation of its CHARACTERISTIC ODOUR. vapour and through the skin.

PHYSICAL DANGERS: INHALATION RISK:

The vapour is heavier than air A harmful contamination of the and may travel along the ground; air can be reached rather quickly distant ignition possible. As a on evaporation of this substance result of flow, agitation, etc., at 20 0 C on spraying much faster.

electrostatic charges can be generated. EFFECTS OF SHORT-TERM EXPOSURE:

CHEMICAL DANGERS: The substance irritates the eyes The substance can form explosive and the respiratory tract. The peroxides. Reacts vigorously with substance may cause effects on strong oxidants and concentrated the central nervous system, liver strong acids. Reacts explosively and kidneys. Exposure to high with some catalysts (e.g., Raney- vapour concentrations may result nickel above 210 0 C). Attacks in unconsciousness.

many plastics.

EFFECTS OF LONG-TERM OR OCCUPATIONAL EXPOSURE REPEATED EXPOSURE:

LIMITS: The liquid defats the skin. This TLV: 25 ppm; 90 mg/m 3 (as substance is probably TWA) (skin) (ACGIH 1992-1993). carcinogenic to humans.

OSHA PEL: TWA 100 ppm (360 mg/m 3 ) skin NIOSH REL: Ca C 1 ppm (3.6 mg/m 3 ) 30-minute See Appendix A

NIOSH IDLH: Potential occupational carcinogen 500 ppm Boiling point: 101 0 C Relative density of the vapour/air-Melting point: 12 0 C mixture at 20 0 C (air = 1): 1.08 Relative density (water = 1): 1.03 Flash point: 12 0 C Solubility in water: miscible Auto-ignition temperature: 180 0 C Vapour pressure, kPa at 20OC: 4.1 Explosive limits, vol% in air: 2-Relative vapour density (air = 1): 22.5 3.0 Octanol/water partition coefficient as log Pow: -0.42 51

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 A T k;.'

N-0 T E S 7- 7 Jse of alcoholic beverages enhances the harmful effect. Depending on the degree of exposure, periodic medical examination is indicated. The odour warning when the exposure imit value is exceeded is insufficient. Check for peroxides prior to distillation; render harmless if positive.

Transport Emergency Card: TEC (R)-30Sl165 NFPA Code: H2; F3; R1; AflflTTTflNAI.

• TNFflRM~ATTflN-- - ~ ~

---

A-D--D- ITIONAL-Tf4f RMATION ICSC:

0041 1,4-DIOXANE (C) IPCS, CEC, 1994 Neither NIOSH, the CEC or the IPCS nor any person acting on behalf of NIOSH, the CEC or the IPCS is responsible for the use which might be made of this information. This card contains the collective views of the IMPORTANT IPCS Peer Review Committee and may not reflect in all cases all the LIMAPORTIT detailed requirements included in national legislation on the subject.

The user should verify compliance of the cards with the relevant legislation in the country of use. The only modifications made to produce the U.S. version are inclusion of the OSHA PELs, NIOSH RELs and NIOSH IDLH values.

52

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 International Chemical Safety Cards.

LEAD ICSC: 0052 Lead metal Plumbum Pb Atomic mass: 207.2 (powder)

ICSC # 0052 CAS # 7439-92-1 RTECS # OF7525000 October 08, 2002 Peer reviewed TYPS~ ACUTE HAZARDS/ ~ RVNTO~ FIRST AID/;j HAZARD/ PRVNTO FIEFGTN

__EXPOSURE <S PTM IR GTNG:

Not combustible. Gives In case of fire in the off irritating or toxic surroundings: use fumes (or gases) in a appropriate fire. extinguishing media.

Finely dispersed Prevent deposition of particles form explosive dust; closed system, mixtures in air. dust explosion-proof electrical equipment and lighting.

See EFFECTS OF LONG- PREVENT DISPERSION TERM OR REPEATED OF DUST! AVOID EXPOSURE. EXPOSURE OF (PREGNANT) WOMEN!

Local exhaust or Fresh air, rest.

breathing protection. _

Protective gloves. Remove contaminated clothes. Rinse and then wash skin with water and soap.

Safety spectacles. First rinse with plenty of water for several minutes (remove contact lenses if easily possible), then take to a doc~tor.

53

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 Abdominal pain. Do not eat, drink, or Rinse mouth. Give Nausea. Vomiting. smoke during work. plenty of water to Wash hands before drink. Refer for medical eating. attention.

Sweep spilled substance into Separated from food and containers; if appropriate, feedstuffs and incompatible moisten first to prevent materials . See Chemical dusting. Carefully collect Dangers.

remainder, then remove to safe place. Do NOT let this chemical enter the environment. (Extra personal protection: P3 filter respirator for toxic particles.)

SEE IMPORTfA-NT INFORM-Aff6NONBC Prepared in the context of cooperation between the International Programme on Chemical Safety &the Commission of the European Communities (C) IPCS CEC ICSC: 0052 1994. No modifications to the International version have been made except to add the OSHA PELs, NIOSH RELs and NIOSH IDLH values.

54

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction I April 2005 International Chemical Safety Cards ICSC: 0052 LEAD PHYSICAL STATE; ROUTES OF EXPOSURE:

APPEARANCE: The substance can be absorbed BLUISH-WHITE OR SILVERY- into the body by inhalation and GREY SOLID IN VARIOUS FORMS. by ingestion.

TURNS TARNISHED ON EXPOSURE TO AIR. INHALATION RISK:

A harmful concentration of PHYSICAL DANGERS: airborne particles can be reached Dust explosion possible if in quickly when dispersed, powder or granular form, mixed especially if powdered.

with air.

EFFECTS OF SHORT-TERM CHEMICAL DANGERS: EXPOSURE:

On heating, toxic fumes are formed. Reacts with oxidants.

Reacts with hot concentrated EFFECTS OF LONG-TERM OR nitric acid, boiling concentrated REPEATED EXPOSURE:

hydrochloric acid and sulfuric The substance may have effects acid. Attacked by pure water and on the blood , bone marrow, by weak organic acids in the central nervous system, presence of oxygen. peripheral nervous system and kidneys , resulting in anaemia, OCCUPATIONAL EXPOSURE encephalopathy (e.g.,

LIMITS: convulsions), peripheral nerve TLV: 0.05 mg/m 3 ; A3; (ACGIH disease, abdominal cramps and 2002). kidney impairment. Causes EU OEL: as TWA 0.15 mg/m 3 ; toxicity to human reproduction- or (EU 2002). development.

OSHA PEL*: 1910.1025 TWA 0.050 mg/m 3 See Appendix C

• Note: The PEL also applies to other lead 3 NIOSH REL*: TWA 0.050 mg/m See Appendix C *Note: The REL also applies to other lead NIOSH IDLH: 100 mg/m 3 (as Pb)

Boiling point: 1740 0 C Density: 11.34 g/cm3 Melting -point: 327.5 0 C Solubility in water: none 3ioaccumulation of this chemical may occur in plants and in nammals. It is strongly advised that this substance does not enter the environment.

55

Demolition Activities, Yankee Nuclear Power Station; Rowe MA Yankee Atomic Electric Health and Safety Plan Cianbro Construction April 2005 I

• - ~

-~

~ ~

~-----

I fDepending on clothes ake working the degree home. of exposure, periodic medical examination is suggested. Do NOT Transport Emergency Card: TEC (R)-51S1872 ADDITIONAL INFORMATI~ibk ICSC: LEAD 0052 (C) IPCS, CEC, 1994 Neither NIOSH, the CEC or the IPCS nor any person acting on behalf of NIOSH, the CEC or the IPCS is responsible for the use which might be made of this information. This card contains the collective views of the IMPORTANT IPCS Peer Review Committee and may not reflect in all cases all the LEGAL NOTICE: detailed requirements included in national legislation on the subject.

The user should verify compliance of the cards with the relevant legislation in the country of use. The only modifications made to produce the U.S. version are inclusion of the OSHA PELs, NIOSH RELs and NIOSH IDLH values.

56