ML071670012

Yankee Nuclear Power Station Phase II Comprehensive Site Assessment Report

ML071670012
Person / Time
Site:	Yankee Rowe
Issue date:	01/26/2005
From:	Kay J Yankee Atomic Electric Co
To:	Howland D NRC/FSME, State of MA, Dept of Environmental Protection
References
BYR 2005-007
Download: ML071670012 (169)

Text

YANKEE ATOMIC ELECTRIC COMPANY Telephone (413) 49 Yankee Road, Rowe, Massachusetts 01367

.',A,N K EE January 26,.2005 3BYR 2005-007 Massachusetts Department of Environmental Protection DEP Western Region 436 Dwight Street Suite 402 Springfield, MA 01103 Attention: Mr. David Howland

Subject:

Yankee Nuclear Power Station (YNPS) Phase Ii Comprehensive Site Assessment Report

Dear Mr. Howland:

The enclosed YNPS Phase 1IP Comprehensive Site Assessment Report was prepared at the request of the Massachusetts Department of Environmental Protection to summarize:

" Likely and known sources of release of radioactivity, oil, and/or hazardous materials (OHM) to the environment.

• Yankee's rationale for selection of radioactive/OHM constituents/chemicals of concern (COGs) and areas/media targeted for investigation and/or characterization. A complete list of COCs is included in Table 16 of the document for your consideration and reference.

• Results of investigation and testing to identify the nature and extent of contamination in potentially affected media (soil, groundwater, surface water, sediment, air, fish and food stocks such as syrup and milk).

SOngoing/scheduled characterization and/or remedial actions.

This Phase II Report is submitted in fulfillment of the requirements of the Massachusetts Contingency Plan (MCP), Code of Massachusetts Regulations (310 CMR 40.0000) for a Phase il-Comprehensive Site Assessment (Phase II) Report pursuant to 310 CMR 40.0883. A risk assessment (as required under 310 CMR 40.0995) 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.

MA Department of Environmental Protection Western Region Office BYR 2004-007, Page 2 of 3 As site decommissioning, assessment and remediation continues, it is Yankee's expectation that this Phase H1 Report will provide a comprehensive basis for the Department to provide YAEC appropriate guidance as applicable to complete ongoing and future assessment and remedial actions necessary for Yankee to achieve closure of the site in a safe, responsible, reliable and beneficial manner.

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

Sincerely, YANKEE ATOMIC ELECTRIC COMPANY Principal Licensing Engineer

Attachment:

YNPS Phase I1Comprehensive Site Assessment Report

MA Department of Environmental Protection Western Region Office BYR 2004-007, Page 3 of 3 cc: R. Walker, Director, Radiation Control Program, MA DPH M. Whalen, Radiation Control Program, MA DPH L. Hahsen, MA DEP (WRO)

T. Kurpaska, MA DEP (WRO)

N. Bettinger, MA DEP (Boston)

C. Rowen, MA DEP (Boston)

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

P. Newkirk, US EPA, Headquarters K. Tisa, US EPA, Region I, TSCA Coordinator J. Hickman, Senior Project Manager, NRC NMSS J. Kotton, Regional Inspector, NRC Region I M. Fischer, USGen New England, Inc.

D. Katz, Citizen's Awareness Network Public Repository at Greenfield Community College

Phase II-Comprehensive Site 0

• Assessment Report r

• Yankee Nuclear Power Station 49 Yankee Road Rowe, Massachusetts RTN 1-13411 ERM Reference 0015181 28 January 2005 www.erm.com Deliveririg sustainable solutions in a muoe competitive world ERM

Yankee Atomic Electric Company Phase 11-Comprehensive Site Assessment Report for the Yankee Nuclear Power Station 49 Yankee Road Rowe, Massachusetts 28 January 2005 RTN 1-13411 ERM Reference 0015181 Environmental Resources Management 399 Boylston Street, 6th Floor Boston, Massachusetts 02116 T: (617) 646-7800 F: (617) 267-6447

Yankee Atomic Electric Company Phase II-Comprehensive Site Assessment Report for the Yankee Nuclear Power Station 49 Yankee Road Rowe, Massachusetts 28 January 2005 RTN 1-13411 ERM Reference 0015181

~x~l Jeremy f Pird, P.G.

ProjectManager 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 iii LIST OF FIGURES v LIST OFAPPENDICES v ,ii LIST OFACRONYMNS vi

1.1 BACKGROUND

1.2 PURPOSE & SCOPE 2 2.0 IDENTIFICATION OF SOURCES, CONSTITUENTS OF CONCERN & STUDY AREAS 3 2.1 IDENTIFICATION OF SOURCES 3 2.1.1 Site Radiological Sources 3 2.1.2 Site Sources of Oil and/or HazardousMaterials Release 4 2.2 IDENTIFICATION OF CONSTITUENTS OF CONCERN 4 2.2.1 Radiological 4 2.2.2 Oil & HazardousMaterials (OHM) 9 2.3 STUDY AREAS 1'6 2.3.1 Overview 1.6 2.3.2 Radiological 1'8 2.3.3 Oil & HazardousMaterials (OHM) 1'8 3.0

SUMMARY

OF RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM (REMP) 2.0 3.1 OVERVIEW 2.0 3.2 INHALATION PATHWAY & AIRBORNE PARTICULATES 2.2 3.3 SOIL 2.3 3.4 GROUNDWATER 2.3 i YANKEE /0015181-1/28/05 ERM i YANKEE /0015181-1/28/05

3.5 SURFACE WATER 24 3.6 SEDIMENT 26 3.7 INGESTION PATHWAY 27 3.7.1 Fish 27 3.7.2 Food Crops & Maple Syrup 28 3.7.3 Milk 30 4.0

SUMMARY

OF THE NATURE & EXTENT OF CONTAMINATION 32 4.1 OVERVIEW 32 4.2 SOIL 32 4.2.1 Radiological 32 4.2.2 Oil and/or Hazardous Materials 33 4.3 GROUNDWATER 35 4.3.1 Site Conceptual Model 35 4.3.2 Radiological Impacts to Site Groundwater 37 4.3.3 Oil and/or HazardousMaterial Impacts to Groundwater 38 4.3.4 On-going Assessment & Remedial Considerations 39 4.4 SEDIMENT & SURFACE WATER 40 4.4.1 Radiological 40 4.4.2 Oil and/or Hazardous Materials 41 4.5 FISH 43 4.5.1 RadiologicalAssessment 43 4.5.2 OHM Assessment 43 5.0 SITE DECOMMISSIONING, INVESTIGATION SCHEDULE AND CLOSURE PATHWAY 45

6.0 REFERENCES

48 iiii YANKEE /0015181-1/28/05 ERM YANKEE /0015181-1/28/05

LIST OF TABLES Table I Sources of RadioactiveRelease, PlantOperations & Maintenance Table 2 RadiologicalSource References Table 3 Sources of RadioactiveRelease, UnplannedReleases Table 4 Summary of Materials/ChemicalUsage Table 5 Summary of Common Radionuclides in Fish Table 6 Summary of Common Activation Radionuclides Table 7 Summary of Long-Lived TransuranicRadionuclides Table 8 Summary of DCGLsfor Different Media Types Table 9 Summary Statistics of All Detected SoilAnalytical Data, Identification of Chemicals of Potential Concern (Non-Radiological)

Table 10 Summary Statistics of All Detected Sediment Analytical Data-ShermanReservoir,Identification of Chemicals of PotentialConcern (Non-Radiological)

Table 11 Summary Statistics of All Detected Sediment Analytical Data-DeerfieldRiver, Identification of Chemicals of PotentialConcern (Non-Radiological)

Table 12 Summary Statistics of All Detected Sediment Analytical Data-WheelerBrook, Identification of Chemicals of PotentialConcern (Non-Radiological)

Table 13 Summary Statistics of All Detected Sediment Analytical Data-Storm System, Identificationof Chemicals of PotentialConcern (Non-Radiological)

Table 14 Summary Statistics of Detected Surface Water Analytical Data, Identification of Chemicals of PotentialConcern (Non-Radiological)

ERM iii YANKEE /0015181-1/28/05

Table 15 Summary Statistics of All Detected GroundwaterAnalytical Data, Identification of Chemicals of PotentialConcern (Non-Radiological)

Table 16 Summary of Radiological& Non-RadiologicalCOCs Table 17 Summary of Floorand Total Area of Buildings & Features Table 18 Summary of Open Area Land Survey Areas Table 19 StatisticalData Summary for Soils (Radiological),Land Areas within the Radiologically ControlArea Table 20 StatisticalData Summary for Soils (Radiological),Land Area Within the IndustrialArea (Outside RCA)

Table 21 StatisticalData Summary for Soils (Radiological),Impacted Portionsof the YNPS Site Outside of the IndustrialArea Table 22 OHM in Soil (Non-Radiological)

Table 23 Summary of Validated GroundwaterAnalytical Data,2003 and 2004 Sampling (Non-Radiological)

Table 24 StatisticalData Summary for Sediments - Sherman Reservoir (Radiological)

Table 25 OHM in Sediment (Non-Radiological)

ERM iv YANKEE /0015181-1/28/05

LIST OF FIGURES Figure 1 Locus Map Figure 2 Site Layout Figure 3 PreliminaryLand and Structure Classifications Figure4 AST, UST and TransformerLocation Map Figure5 Annual Average Gross Beta Concentration-AirParticulateFilters (in Text Section 3.2)

Figure 6 Tritium in Water (in Text Section 3.4)

Figure 7 Gross Beta in River Water (in Text Section 3.5)

Figure8 Tritium in River Water (in Text Section 3.5)

Figure9 Cs-137 Concentrationin Sediment (in Text Section 3.6)

Figure10 Annual Average K-40 and Cs-137 Concentration-Fish(in Text Section 3.7.1)

Figure11 Annual Average K-40 and Cs-137 Concentration-MapleSyrup (in Text Section 3.7.2)

Figure12 Annual Average K-40 Concentration-FoodCrop (in Text Section 3.7.2)

Figure13 Annual Average Cs-137 Concentration- Milk (in Text Section 3.7.3)

Figure14 Annual Average Sr-90 Concentration- Milk (in Text Section 3.7.3)

Figure15 Soil Sample Locations (Non-IndustrialArea) and OHM Results Exceeding MCP Reportable Concentrations Figure16 Soil Sample Locations (Industrialand Non-IndustrialArea) and OHM Results Exceeding MCP Reportable Concentrations Figure17 Hydrogeologic Cross Section A-A' ERM V YANKEE /0015181-1/28/05

Figure 18 HydrogeologicCross Section C-C' Figure 19 Shallow Tritium Plume Map for May 2004 Figure20 Tritium Plume in Wells About 100 Feet Deep, May 2004 Figure21 Ground Water Elevation in Shallow Aquifer, May 14, 2004 Figure22 Ground Water Elevation in Sands About 100 Feet Deep, May 14, 2004 Figure23 Ground Water Elevations in the Bedrock Aquifer, May 14, 2004 Figure24 GroundwaterMonitoringWell Locations and OHM Exceeding MCP Reportable Concentrations Figure25 Sediment and Surface Water Sample Locations Figure26 ProposedPathway to IntegratedEnvironmental Site Closure vi YANKEE /0015181-1/28/05 ERM Vi YANKEE /0015181-1/28/05

LIST OF APPENDICES Appendix A Supporting Documentation Appendix B Summary of Radioactive Analysis Methods vii YANKEE /0015181-1/28/05 ERM Vii YANKEE / 0015181-1 /28/05

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 Viii ERM YANKEE /0015181-1/28/05

LSP Licensed Site Professional LIP 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 SCFA Southeast Construction Fill Area SCPP Site Closure Project Plan ix YANKEE /0015181-1/28/05 ERM ix YANKEE /0015181-1/28/05

SFP Spent Fuel Pool SI/DG Safety Injection/Diesel Generator 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 xx YANKEE /0015181-1/28/05 ERM ERM YANKEE /0015181-1/28/0,5

1.1 BACKGROUND

The Yankee Nuclear Power Station (YNPS) is located on an approximately 1,800-acre property at 49 Yankee Road in Rowe, Massachusetts (Figure 1).

Yankee Atomic Electric Company (YAEC), owner and operator of YNPS, ceased commercial power generation activities in 1992 and is decommissioning the plant. In October 2003, YAEC released a Site Closure Project Plan (SCPP) to the public and various regulatory and non-regulatory stakeholders. The SCPP outlines the process and permitting by which YAEC will complete the decommissioning, environmental investigation, environmental remediation, site closure, and post-closure property transfer of YNPS. The SCPP has been updated to incorporate stakeholder comments since it's initial issuance. As outlined in the SCPP, YAEC's goals are to:

" Complete the majority of decommissioning and physical site closure activities at the site by mid-2005.

" Achieve radiological and non-radiological site closure in a safe, responsible, reliable, and beneficial manner.

• Integrate stakeholder requirements and interests into the project planning and implementation process to optimize efficiency, avoid duplication of efforts, and facilitate acceptance by both regulatory and non-regulatory stakeholders.

" Where feasible, restore the site to environmental quality standards that will enable future unrestricted use of the site.

" Safely manage the spent nuclear fuel on-site until such time that the Department of Energy (DOE) satisfies it's legal obligation to remove the spent fuel and Greater Than Class C (GTCC) wastes to a permanent off-site storage facility.

On behalf of Yankee Atomic Electric Company (YAEC), Environmental Resources Management (ERM), in coordination with Gradient Corporation (Gradient), Radiation Safety Control Services (RSCS) and C.N. Associates, has prepared this Phase Il-Comprehensive Site Assessment (Phase II) Report for the YNPS site.

ERM 1 YANKEE /0015181-1/28/05

1.2 PURPOSE & SCOPE This Phase II Report was prepared at the request of the Massachusetts Department of Environmental Protection (MADEP/Department) to summarize:

• Likely/known sources of release of radioactivity, oil, and/or hazardous materials (OHM) to the environment.

" YAEC's rationale for selection of radioactive/OHM constituents/chemicals of concern (COCs) and areas/media targeted for investigation.

" Results of investigation and testing to identify the nature and extent of contamination in potentially affected media (soil, groundwater, surface water, sediment, air, fish and food stocks such as syrup and milk).

" Ongoing/scheduled investigations and/or remedial actions.

At the Department's request, this Phase II Report is intended to be a summary document and thereby relies on more detailed supporting characterization documentation referenced in Appendix A (available at Greenfield Community College Library and at www.yankee.com). This Phase II is applicable to the entire "YNPS site" defined as that location in the environment where plant-related radioactivity and/or OHM have come to be located in the environment (i.e., at levels exceeding those naturally occurring, or background, including anthropogenic influences).

This Phase II is submitted in partial fulfillment of the requirements of the Massachusetts Contingency Plan (MCP), Code of Massachusetts Regulations (310 CMR 40.0000) for a Phase lI-Comprehensive Site Assessment (Phase II) Report pursuant to 310 CMR 40.0883, but excludes characterization of the potential risk of harm to human health, safety, public welfare and the environment at this time (as required under 310 CMR 40.0995). A 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 meeting applicable risk management criteria for protection of human health, safety, public welfare and the environment.

As site decommissioning, assessment and remediation continues, it is YAEC's expectation that this Phase II will provide a basis for the Department to provide YAEC appropriate guidance as applicable to complete ongoing and future assessment and remedial actions necessary for YAEC to achieve closure of the site in a safe, responsible, reliable and beneficial manner.

ERM 2 YANKEE /0015181-1/28/05

2.0 IDENTIFICATION OF SOURCES, CONSTITUENTS OF CONCERN &

STUDY AREAS 2.1 IDENTIFICATION OF SOURCES 2.1.1 Site RadiologicalSources Normal plant operations were expected to result in contamination of certain areas of the site and these areas were designed to contain such material. However, during the history of plant operations, certain events and conditions resulted in radioactive material being deposited in other locations within the plant. As a result, the plant design and operational procedures evolved to accommodate or eliminate these circumstances.

These events were categorized as "Planned" release events, because they were associated with normal plant operations and were expected to result in impacts to plant structures.

The principal events and circumstances, listed in chronological order in Table 1, contributed to the residual contamination that needs to be addressed during decommissioning. It should be noted that these events relate to the plant operational history and affected general plant radiological conditions and not specific plant locations. These events and their consequences, as well as an understanding of radiological conditions for the plant as a whole were among the factors considered when classifying the plant areas for the Final Status Survey (FSS).

A comprehensive review of all recorded events documented as having occurred outside the normal operational condition of the plant was also performed to capture those events that contributed to radiological contamination of the site. These events are summarized in Table 2. These events were typically documented in the format suitable for reporting to regulatory authorities such as Abnormal Occurrence Reports (AOR's),

submitted during the early site history, and Plant Incident Reports (PIR's) or Licensee Event Reports (LER's), submitted through the remainder of plant operation. Where available, the information in these reports was supplemented by supporting documentation concerning the events in the form of plant memos and radiological survey data.

33 YANKEE /00151811/28/05 ERM YANKEE /0015181-1/28/05

2.1.1.1 Unplanned Gaseous Releases Over the lifetime of the plant, a number of unplanned gaseous release events occurred. Short descriptions of these gaseous events as described in AOR/PIR/LER's are documented in the HSA. A careful review of these unplanned discharges did not reveal any unmonitored particulate component that could have significantly contributed to the long-term contamination of the site or its environs.

2.1.1.2 Unplanned Liquid Releases Several AOR's and PIR's reviewed documented unplanned liquid releases that resulted in contamination of the site grounds, buildings, and subsurface locations. When subsurface investigations were not performed due to inaccessibility, or were not completed to the level suitable for license termination, these locations were targeted for continuing characterization during the FSS. Table 3 provides a listing of the events identified that have resulted in radioactive contamination of the site, including a brief summary of each event based on the documentation prepared at the time of the incidents and an assessment of which survey areas (to be investigated during decommissioning and FSS) were impacted by the events.

2.1.2 Site Sources of Oil and/orHazardousMaterialsRelease The YNPS plant used a variety of chemicals in the course of routine operations. A summary of the materials/chemicals used and stored is provided in Table 4.

2.2 IDENTIFICATION OF CONSTITUENTS OF CONCERN 2.2.1 Radiological 2.2.1.1 Fission Radionuclides The operation of a nuclear reactor results in the creation of two types of radionuclides; fission and activation products. Fission products are the direct result of U-235 absorbing a thermal neutron and splitting (fissioning) into two smaller nuclear fragments, each of which has an excess of neutrons. The resultant fragments initially have a significant amount of kinetic energy, but due to their mass do not travel outside the confines of the fuel pellet. When the fragments stop, they lose their kinetic energy by transferring it to the medium they are in (i.e., heating the reactor coolant). The fragments are still radioactive and can decay by ERM 4 YANKEE /0015181-1/28/05

either negatron or neutron emission in order to reach a stable nuclear configuration. The additional neutrons (referred to as delayed neutron emission) become available to induce more fission reaction events at some distance from the initial reaction site.

Most of the fission events occur within the nuclear fuel pins that comprise a nuclear fuel element, which in turn are a component of a nuclear reactor core. Each pin is designed to keep the fission products within their stainless steel-welded container once they are created. Occasionally during reactor operations, some of these fuel pins (much less than one percent) develop a defect. When this failure occurs, some of the fission fragments enter the circulating water of the reactor coolant system.

The fission fragments created during the fission process can be atoms with an atomic mass number that ranges from approximately 70 to 160 with predominant nuclides at approximately 95 and 139. Most of the radioactive fission products have short half-lives and decay by the emission of a beta particle. Most of the beta decays are accompanied by the near spontaneous emission of a gamma ray. A small fraction of fission radionuclides have half-lives greater than one year. A listing of some common fission products is provided in Table 5 sorted by half-life.

ERM 5 YANKEE /0015181-1/28/05

2.2.1.2 Activation Radionuclides Non-Transuranics A discussed above, each fission event causes the emission of "free neutrons" from each event. In fact, on average each fission event emits 2.5 neutrons. Some of these neutrons go on to cause other fission events while others interact with other materials in or around the reactor core.

The interaction of neutrons with other non-radioactive material often results in the "activation" of a stable atom. The neutron interaction can occur by direct bombardment of metal components near the core, or it can occur with corrosion products carried in the reactor coolant as they travel through the core. For instance, if a neutron is absorbed by Co-59, the creation of Co-60 results which is a radioactive form of cobalt that decays by beta emission with a half-life of 5.26 years. In this example, Co-59 is a normal constituent of the steel alloys contained within the material that make up and surround the reactor core.

Activation products can be created from stable atoms that are contained within the circulating reactor coolant since this coolant passes through the reactor core where a high population of neutrons are present during reactor operations. Some of these stable atoms result from corrosion and wear products from the operation of valves and pumps that are part of the reactor coolant system. A listing of some common non-transuranic activation radionuclides is provided in Table 6 sorted by half-life.

Two of the radionuclides listed in Table 6 are activation products that come from sources other than metallic components. Tritium (3 H) results from the neutron interaction with boric acid (added as a neutron moderator) and lithium (an added pH control agent). Carbon-14 is formed as a result of activation of 14N (from trace concentrations of dissolved nitrogen) and 170 (from the water molecules).

Transuranics One additional type of activation product results in the activation of U-238 and its resultant activation products. Of the total uranium contained in a typical reactor core, approximately three percent is U-235 (the fissionable form) and 97 percent is U-238. Some of the fission neutrons interact with the predominant U-238 resulting in U-239 and then Np-239 by beta decay and then Pu-239 by beta decay. These activation products may again absorb a neutron creating other radioactive elements with atomic numbers greater than uranium (92), commonly referred to as transuranic radionuclides. Most of the transuranic radionuclides have short half-lives and decay by alpha particle emission. These activation products are ERM 6 YANKEE /0015181-1/28/05

usually insoluble materials and generally remain within the reactor core except when the fuel undergoes some failures thereby allowing fission products to enter into the reactor coolant system. In the absence of fission products in areas outside of the reactor core, it is reasonable to conclude the absence of transuranic radionuclides. Table 7 lists the long-lived transuranic radionuclides that are important during reactor operations sorted by half-life.

2.2.1.3 Naturally Occurring Radionuclides Naturally occurring radionuclides are present in soil, groundwater, and surface water, sediment and food stocks. These radionuclides are categorized as terrestrial or cosmic. The terrestrial radionuclides are generally contained in the earth's crust including both bedrock and soils.

These terrestrial radionuclides include U-234, U-235, U-238, and Th-232.

Each of these radionuclides is the first isotope in a chain of successive radionuclides until the chain ends in a stable isotope of lead. These decay chains include radioisotopes of U, Th, Pa, Ac, Ra, Rn, Po, Pb, and Bi. The decay modes of each radioisotope in the series include the emissions of alpha particles, beta particles, and gamma rays depending on the specific isotope. Also, the relative abundance of each of these radioisotopes may differ due to the various chemical properties of each element and of the specific geochemistry of the area. Because of the ubiquitous presence of these radionuclides these can be found in plants and animals as well as soils, surface water and groundwater.

The cosmic radionuclides are produced from nuclear interactions within the atmosphere principally from solar charged-particle radiation. The radionuclides produced from these cosmic sources include K-40, C-14, H-3, and Rb-87. Like the terrestrial radionuclides, these cosmic radionuclides are generally taken up within specific systems in the biosphere and can be found in soils, vegetation, animals, surface and groundwater, and bedrock.

Above ground nuclear weapons testing during the 1970's has contributed to radioactive material found in the environment, and material from this source is considered part of the measurable "background." The principal radionuclides of concern from weapons testing are Cs-137 and Sr-90, which are analyzed for during FSS and detected in some environmental samples (REMP). Differentiating the contribution from fallout versus plant operations is done by evaluating the concentrations present in unaffected areas of the site, the location of the survey area, and presence of any other plant-related radionuclides.

YANKEE /0015181-1/28/05 ERM 77 YANKEE /0015181-1/28/05

2.2.1.4 LTP Radionuclide Selection in Support of Final Site Surveys In the development of Yankee's License Termination Plan (LTP), a defined set of radionuclides was needed in order to develop Derived Concentration Guideline Levels, or DCGLs. These levels are radionuclide specific and are calculated (modeled) by considering the future uses of the property and the available site-specific parameters including hydrogeologic, geologic and meteorological parameters. Once developed, these DCGLs are used during the final site surveys to determine the significance (or dose contribution) of radionuclides identified at the site.

Materials exhibiting levels of radioactivity above applicable DCGLs are contained for off-site transportation and disposal at a licensed facility during decommissioning. Materials exhibiting very low levels of radioactivity at or below DCGLs, but still above background, will be safely managed and reused on-site in restoration. As such, it is important that the LTP list of potential radionuclides be comprehensive, yet limited to those potentially present (based on a relatively longer half-life) once decommissioning is complete.

Table 8 presents a summary of the plant-related radionuclides that were initially considered for the LTP. This all-inclusive list was developed based on the available literature and on Yankee-specific waste stream analysis during reactor operation.

The criteria used to determine a radionuclides inclusion in the LTP included:

• The radionuclides half-life and decay factor.

• Its estimated abundance in the plant waste streams.

• Its relative dose potential.

For instance, a radionuclide with a long half-life may not be included for consideration if it was never identified in any of the plant's waste streams during operations, or in the comprehensive Radiological Environmental Monitoring Program (REMP).

Evidence of radionuclides present during plant operation is supported by routine sampling of plant contamination for personnel protection purposes, for waste classification and disposal and from the routine REMP sampling. For waste classification, samples were required to be analyzed for specific radionuclides that included the LTP radionuclides.

For the REMP samples, analysis of soils, vegetation, water, air, and milk was required. These analyses included gross alpha, gross beta, gamma ERM 8 YANKEE /0015181-1/28/05

spectroscopy, liquid scintillation, and alpha spectroscopy, depending on the specific media. As part of developing the LTP radionuclide list, a review of all of this historical data was performed.

Twenty radionuclides have been selected for inclusion in the LTP (Table 8). These radionuclides represent the only ones expected to be present in any area of the site due to plant operations, i.e., are plant-related as opposed to naturally occurring. This selection is based on half-life, fractional abundance, and exposure potential. In addition to routine monitoring for these radionuclides, gross alpha/beta and gamma spectroscopy will verify the absence of other nuclides.

2.2.2 Oil & HazardousMaterials(OHM) 2.2.2.1 Data Review and Usability Assessment Since the initiation of plant decommissioning activities in 1992, YAEC has conducted numerous environmental sampling programs to support the decommissioning effort. These investigations have included sampling of building surfaces and materials, soil, soil gas, groundwater, stormwater systems, surface water, sediments and fish. Samples have been analyzed for both radiological and non-radiological parameters.

The Yankee database contains sample data reported since 1997, but nonradiological data reported before 2002 were not formally validated.

However, Gradient performed a data usability assessment on a subset of the historical data identified by YAEC to be critical to characterizing the Site. The data usability assessment was performed based on Quality Control (QC) information provided by YAEC. Data collected from 2003 to present have been formally validated by ERM according to EPA Region I guidance. The assessed subset of the historical data, as well as all formally validated data included in the database as of December 2004, were used in identifying the COCs for groundwater, surface water, soil, and sediment.

It is important to note that validation of the November 2004 sediment and groundwater data is incomplete at this writing and the use of validated results may alter the summary statistics Gradient generated to select the COCs for sediment and groundwater. A re-evaluation of COCs will be performed using the validated data for use in the pending risk characterization and assessment and reported in future correspondence.

2.2.2.2 Reasonably Foreseeable Future Use of the Site Plant decommissioning and demolition is currently underway and all radiological systems have been removed from the plant. The spent ERM 9 YANKEE /0015181-1/28/05

nuclear fuel is being stored in the Independent Spent Fuel Storage Installation (ISFSI), an on-site dry cask storage facility. Although the plant decommissioning and environmental restoration is scheduled to be completed by 2005, the YNPS license with the NRC will not be officially "terminated" until such time that the Department of Energy removes the spent fuel to permanent storage at a federally licensed storage facility (no such facility currently exists). Thus, YAEC will retain control of that portion of the site consisting of the ISFSI and former industrial area until the spent fuel is removed, and this "YAEC Retained Area" will be inaccessible to the public and subject to surveillance 24-hours a day.

Although the future status of the Site is currently not fully defined, likely use may consist of open space with some potential for recreational/limited development activities. In situations where the end use of a property has not been defined, the Massachusetts Contingency Plan (MCP) requires the evaluation of risk under a residential scenario and this scenario will form the basis of the human health risk assessment.

This assumption will provide a conservative assessment, as the most likely future Site use (e.g., recreational/open space) would not involve the kind of frequent exposure that would be the case under a "residential" exposure scenario.

Although a future residential exposure scenario may be hypothetically plausible for the majority of the 1,800-acre property, a deed restriction and/or Activity Use Limitation (AUL) will be enforced over that portion of the site constituting the former industrial area. In addition, as a component of the final site restoration/grading plan, a 3-foot overburden will be in place in the former industrial area. The AUL will preclude excavation without a DEP-approved soil management plan and any excavation would occur only under the oversight of a Licensed Site Professional (LSP).

2.2.2.3 Classificationof Site Soils and Site Groundwater Soil and groundwater at the site were categorized in accordance with 310 CMR 40.0930 as required for a Method 3 Risk Characterization. MADEP has defined three soil (S-1, S-2, S-3) and three groundwater (GW-1, GW-2, GW-3) classifications based on the nature of exposure. Soil classifications are based on accessibility of site soil, frequency of exposure, and intensity of exposure. Soil classification S-1 is based on the assumption of highest potential for exposure, while classification S-3 assumes the lowest potential for exposure. Groundwater classifications are also based on the type of potential exposure. Classification GW-1 has been established to protect against risks under the assumption that site groundwater may be used directly as a potable water source. Classification GW-2 protects ERM in YANKEE /0015181-1/28/05

against risks associated with volatilization of compounds from shallow groundwater and infiltration into buildings through cracks and other imperfections in slabs and foundations. Finally, classification GW-3 protects against risks associated with the discharge of groundwater to surface water.

Under an assumed residential exposure scenario, the corresponding soil category would be S-1. However, as noted above, the AUL in the former industrial area will limit possible contact with soils for the industrial portion of the site. Consequently, soils within the area subject to the AUL are classified S-3. For the evaluation of recreational activities and potential exposures, contact with soil may occur, however the intensity and frequency of use is expected to be lower when compared to a residential exposure scenario. Thus, under recreational scenarios the appropriate soil category would likely be S-3 (301 CMR 40.0933).

Because the Site is located within 504 feet of an Interim Wellhead Protection Area, groundwater on the southeastern portion of the Site is characterized as GW-1 (310 CMR 40.0932). In addition, portions of the Site are characterized as GW-2 because groundwater is less than 15 feet below grade and within 30 feet of occupied structures. Finally, all groundwater beneath the Site is characterized as GW-3 because MCP considers all groundwater as a source of discharge to surface water. Therefore, groundwater at the Site is classified as GW-1, GW-2 and GW-3.

2.2.2.4 Background Chemical Concentrations Potential risks to human health and the environment will be evaluated for site-related chemicals above background exposures. MADEP (1995) defines background as "those levels of oil and hazardous material that would exist in the absence of the disposal site of concern that are:

(a) ubiquitous and consistently present in the environment at and in the vicinity of the disposal site of concern; and, (b) attributable to geologic or ecologic conditions, atmospheric deposition of industrial process or engine emissions, fill materials containing wood or coal ash, releases to groundwater from a public water supply system, and/or petroleum residues that are incidental to the normal operation of motor vehicles."

Given their ubiquitous presence in the environment, MADEP (2002a) has developed statewide background levels for metals and PAHs in both "natural" soil and soil containing fill material. For chemicals without MADEP-derived background levels, site-specific information was used to FRM 11 YANKEE /0015181-1/28/05

characterize local conditions and identify COCs, including other media such as surface water, groundwater, and sediment. Maximum detected concentrations of chemicals in specific media were compared to MADEP's background levels for soil or local conditions for chemicals lacking a MADEP-derived background level or other media (MADEP, 2002a).

Chemicals present at levels consistent with local/regional and published background levels were not retained as COCs for the risk assessment.

2.2.2.5 Constituents of Concern Based on the operations and materials used at the plant, samples from environmental media have been (in previous site investigations) analyzed for (but not necessarily limited to) the following COCs (Gradient, 2003):

• volatile organic compounds (VOCs);

• semivolatile organic compounds (SVOCs);

• petroleum hydrocarbonsi

" priority pollutant 13 metals, plus boron and lithium;

• hexavalent and trivalent chromium;

" total cyanide and cyanide amenable to chlorination;

" chlorinated herbicides;

" polychlorinated biphenyls (PCBs);

" dioxins and furans;

• hydrazine; and

" radionuclides (radionuclides of concern were identified through the DCGL determination process and as described in section 2.2.1.4).

Depending on the levels of total petroleum hydrocarbons found, additional extractable petroleum hydrocarbon/volatile petroleum hydrocarbon (EPH/VPH) analyses may be performed (MADEP, 2002b).

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As specified in the MCP, all chemicals detected in soil, sediment, and surface water were retained as COCs if both of the following conditions are met:

" oil or hazardous materials are detected in greater than 5% of environmental samples, and

" oil or hazardous material concentrations exceed background or local conditions.

The risk characterization will focus on COCs defined by the above criteria.

In identifying oil or hazardous material COCs in the various sampled media, all data collected and analyzed as of 3 December 2004 were used in the analysis except:

• samples that were removed during remediation activities (including soil piles);

• field QA/QC samples (i.e. equipment, field, trip and lab blank data);

• all catch-basin samples; and

• samples collected by YAEC in 2003 and 2004 that were used for purposes other than site characterization.

All data marked as rejected (R) are unusable for use in identifying COCs.

Data qualifiers including "U" (undetected) and "J"(estimated) are fully usable, as are detected data, which required no qualifier be applied.

Soil samples were collected and analyzed for TPH, VOCs, SVOCs, PCBs, pesticides, herbicides, hydrazine, inorganics, and dioxin/furans based on a historic assessment. Statistical summaries of detected oil or hazardous materials are presented in Table 9. In accordance with the MCP, detected concentrations of oil or hazardous materials were compared to the MADEP background concentrations for Polycyclic Aromatic Hydrocarbons (PAHs) and inorganics. Where available, site-specific background concentrations were used to compare against maximum detected concentrations for oil or hazardous materials of all other chemical groups. Oil or hazardous materials were identified as COCs if the detected frequency is greater than 5% and if detected concentrations exceed MADEP or local site-specific background concentrations. Oil or hazardous materials with no corresponding MADEP or site-specific background concentrations were selected as COCs based on detected frequencies only. Detected frequencies of greater than 5% were designated as COCs in the soils.

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Sediment samples were collected in four Areas of Concern (AOC): Storm Water System, Sherman Reservoir, Deerfield River, and Wheeler Brook.

Each AOC was sampled for TPH, VOCs, SVOCs, PCBs, and Inorganics.

Statistical summaries of detected oil or hazardous materials are presented in Table 10 through Table 13 for each AOC. As previously stated, oil or hazardous materials are identified as COCs if the frequency of detection is greater than five percent or if site concentrations exceed local background concentrations. Local background conditions were characterized by six sediment samples from the northern/upstream area of Sherman Reservoir. VOCs and PAHs were detected infrequently in background samples. As a result, detected VOCs and PAHs in the AOCs were included as COCs. Concentrations of TPH and metals detected at least once in sediment samples in each of the AOCs were compared to site-specific background concentrations.

Eleven surface water samples were collected in water bodies throughout and adjacent to the site. These samples were analyzed for VOCs, PCBs, and inorganics. No site-specific background surface water samples were collected. Therefore, oil or hazardous materials are identified as COCs if the frequency of detection is greater than five percent. Statistical summaries of surface water results are presented in Table 14.

Both filtered and non-filtered groundwater samples were collected from the site. One filtered groundwater sample was sampled and analyzed for VOCs and inorganics. Twenty-four filtered groundwater samples were analyzed for PCBs. Non-filtered groundwater samples were analyzed for VOCs, SVOCs, pesticides, PCBs, inorganics, herbicides, and alcohols. No site-specific background groundwater samples were collected. Therefore, oil or hazardous materials are identified as COCs if the frequency of detection is greater than 5%. Statistical summaries of detected OHM in groundwater are presented in Table 15.

The following table provides a list of chemicals of potential concern for each media sampled and evaluated based on the comparisons presented in Table 9 through Table 15."

SIn contrast to the approach recommended by MADEP, EPA generally recommends that Chemicals present below background levels be carried through the risk characterization, with risks associated with background being discussed in the risk characterization chapter (EPA, 2002). Given the comprehensive suite of chemicals included in the sampling analysis, the approach adopted here is considered protective of human health and the environment.

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Media Chemicals of Potential Concern TPH: TPH, TPH-DRO, EPH Cll-C22 aromatics and C19-C36 aliphatics, and total EPH; VOCs: 2-butanone, acetone, diethyl ether, methylene chloride, toluene; Soil SVOCs: all PAHs, bis(2-ethylhexyl)phthalate, carbazole; Dioxin: Total Equivalent Quantity (TEQ)

PCBs: Aroclor-1254, aroclor 1260; and lnorganics: Al, As, Ba, B, Cr, Cu, Pb, Li, Mn, Hg, Mo, Ni, and Se.

TPH: TPH VOCs: 1,1-dichloroethene, methylene chloride; Sediment- SVOCs: All PAHs; bis(2-ethylhexyl)phthalate, carbazole; Storm System dibenzofuran; PCBs: Aroclor-1254; aroclor 1260; and Inorganics: Sb, As, Ba, Be, Cd, Cr, Cu, Pb, Hg, Ni, Se, Ag, Th, and Zn.

VOCs: 1,1-dichloroethene, 1,2,4-trimethylbenzene, 2-butanone, 4-methyl-2-pentanone, acetone, carbon disulfide, toluene; Sediment- SVOCs: All PAHs, bis(2-ethylhexyl)phthalate, chrysene, Sherman fluoranthene, phenanthrene, pyrene; Reservoir PCBs: Aroclor-1254; and Inorganics: Sb, As, Ba, Be, Cd, Cr, Cu, Pb, Li, Hg, Ni, Se, and Zn.

VOCs: 2-butanone, 4-isopropyltoluene, acetone, chloromethane; Sediment- SVOCs: All detected PAHs; Deerfield PCBs: Aroclor-1254, and aroclor-1260; and River Inorganics: Cu and Pb.

Sediment-VOCs: 1,1-dichloroethene, 2-butanone, acetone; and Wheeler Inorganics: Ba, Pb, and Hg.

Brook VOCs: acetone, carbon disulfide, chloromethane, methylene chloride, Surface Water toluene; and Inorganics: Ba, Cu, Fe, Mn, Se, and Ag.

TPH: TPH, TPH-DRO, TPH-GRO VPH C5-C8 aliphatics and C9-CIO aromatics, EPH Cll-C22 aromatics and C19-C36 aliphatics; VOCs: 1,1-Dichloroethane, acetone, carbon disulfide, methyl-t-butyl ether, toluene; Groundwater- SVOCs: bis(2-ethylhexyl)phthalate; fluoranthene, naphthalene, Non-Filtered phenanthrene, pyrene; PCBs: Arochlor-1254; Inorganics: Ba, Bo, Cr, Cu, Fe, Pb, Mn, Ni, Zn; and Alcohols: iso-propyl alcohol.

FRM 15 YANKEE /0015181-1/28/05

Groundwater-PCBs: Arochlor-1254 Filtered Table Notes: TPH - Total Petroleum Hydrocarbons, VOCs - Volatile Organic Compounds, SVOCs

- Semi-Volatile Organic Compounds, PCBs - Polychlorinated Biphenyls, PAHs - Polycyclic Aromatic Hydrocarbons, Sb-Antimony, As-Arsenic, Ba-Barium, Be-Beryllium, B-Boron, Cd-Cadmium, Cr-Chromium, Co-Copper, Pb-Lead, Li-Lithium, Mn - Manganese, Hg-Mercury, Mo-Molybdenum Ni-Nickel, Se-Selenium, Ag-Silver, Th-Thallium, and Zn-Zinc.

A comprehensive list of radionuclides and OHM identified as COCs is included in Table 16. Future site characterization and risk assessments will be focused on these identified COCs.

2.2.2.6 Applicable or Suitably Analogous Standards Section 310 CMR 40.0993(2) of the MCP requires that Applicable or Suitably Analogous Standards be identified in a Method 3 risk characterization. In Massachusetts, standards are available for drinking water, surface water, and air quality. As required by the MCP, Massachusetts Drinking Water Quality Standards may be applicable to site groundwater if site groundwater is classified as GW-1 groundwater.

Massachusetts Surface Water Quality Standards would be applicable to surface water in Sherman Reservoir. Massachusetts Air Quality Standards (310 CMR 6.00) also known as the National Ambient Air Quality Standards (NAAQS), which are only available for six compounds, are also applicable.

2.3 STUDY AREAS 2.3.1 Overview The developed portion of the site, displayed in Figure 2, is divided into three 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.

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

ERM 16 YANKEE /0015181-1/28/05

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

Summary of YNPS Areas and Structures Area Description Structures Located Within Area Demineralized Water Tank Industrial RCA Firewater Storage Tank/Pump House Area 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)

Screenwell House (Circulating Water Intake Industrial Area Structure) outside of the RCA 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 Asphalt, brick and concrete (ABC) Rubble Non- Areas outside fenced Disposal Area*

Industrial operational area Active and Inactive Leach Fields Area Administrative Building and office trailers Circulating Water Discharge Structure East and West Storm Drain Outfalls East Construction Fill Area (ECFA)

Fire Fighter Training Area New Shooting Range Parking areas Sand/Salt Shed Septic System Pump House Southeast Construction Fill Area (SCFA)

Storage Yard*

Trash Compactor Visitor's Center*

• Location shown in Figure 1.

ERM 17 YANKEE /0015181-1/28/05

2.3.2 Radiological Identification of study areas for radiological characterization of the site are identified in the HSA and FSS as Survey Areas based on the physical configuration of the operating plant, historic operations involving the management of radioactive materials and the history of unplanned release events. Approximately 30 acres of the YAEC property was impacted by plant operation and are designated in the HSA and FSS as Survey Areas and are classified as Class 1, 2 or 3 based on the potential for radioactive impact (Figure 3). Radiological characterization of these areas is proceeding in accordance with the LTP. The remainder of the property is non-impacted and will not be surveyed as part of the FSS as no reasonable potential for impact from plant operations exists.

Survey area boundaries and classification of impacted areas defined as of 31 July 2003 are summarized on Figure 3 and Table 17 for structures, and Figure 3 and Table 18 for open lands (YAEC, 2004a). The majority of the impacted area of open land is characterized by no residual plant related radioactivity or at levels that are a small fraction of the DCGL and are classified as Class 3. Class 3 open land survey areas surround the site Industrial Area, with the exception of two isolated areas (OOL-16 and OOL-17) that received soil from impacted locations within the Industrial Area. Class 2 open land survey areas on-site may have detectable levels of radioactivity above background, but are not expected to yield levels in excess of the DCGL. Class I open land survey areas represent site locations where historical information indicates the potential presence of radioactivity at levels greater than the DCGL (pre-remediation). Class 1 structure survey areas, and the majority of Class I open land survey areas, are located within the boundary of the RCA.

2.3.3 Oil & Hazardous Materials(OHM)

Historic site characterization data for OHM in the environment were compared with available information regarding historical site operations involving OHM use, storage, waste generation and waste management to identify study areas; locations where media require further evaluation to assess the presence or absence of OHM impact in the environment associated with YNPS operations. Historic site characterization data for OHM in the environment were compared with available information regarding historical site operations involving OHM use, storage, waste generation and waste management to identify study areas; locations where media require further evaluation to assess the presence or absence of OHM impact in the environment associated with YNPS operations.

Study areas are listed below and are shown on Figures 2 and 4:

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" Operational areas - Turbine Building, Service Building, PAB, PCA, Former Diesel Generator Building, Fuel Storage Area

• Current and Former AST locations

• Former UST locations

• Former Transformer Locations

" Current and former hazardous waste storage areas

• Former incinerator locations

" Former railroad tracks

" Disposal Areas - SCFA, ECFA, Asphalt, Brick and Concrete (ABC)

Rubble Disposal Area

" Active and inactive leachfields

• Old and new shooting ranges

• Soil in Industrial Area to assess potential impact from PCB-containing paint chip release

• Groundwater beneath and down-gradient of the Industrial Area

• Surface water and sediment in Sherman Reservoir, Wheeler Brook, Tributary to Wheeler Brook, Wheeler Brook Divertment, and West Storm Drain 19 YANKEE /0015181-1/28/05 ERM 19 YANKEE /0015181-1/28/05

3.0

SUMMARY

OF RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM (REMP) 3.1 OVERVIEW Radiological environmental monitoring was initiated in 1958, approximately two years before the Rowe plant began commercial power production, and has been in operation continuously since that time. In accordance with the requirements of 10CFR50, Appendix I (CFR, Title 10),

the principle objective of the REMP is to provide data on measurable levels of radiation and radioactive materials in the environment as a confirmation that the primary method of determining plant regulatory compliance, plant effluent release measurements and dose computations, are not likely to be significantly underestimated. As such, the radionuclides that are commonly assessed in off-site environmental samples are those that have been previously observed or could be expected to be present in treated liquid and gaseous effluent waste streams to the environment. The nuclides expected include both gamma and non-gamma emitting radionuclides that exhibit mobility through plant process systems.

Gamma isotopic analyses of REMP samples typically report the measured Minimum Detectable Concentration (MDC) or positively detected concentrations, for 23 nuclides. These are the most likely radionuclides, including both activation and fission products, expected to be part of either liquid or gaseous effluent waste streams. The list of nuclides is based on the operating experience at both Yankee Rowe and other operating nuclear power plants, and includes the following nuclides: Ag-108m, Ag-l10m, Ba/La-140, Ce-141, Ce-144, Co-57, Co-58, Co-60, Cr-51, Cs-134, Cs-137, Fe-59, 1-131, Mn-54, Nb-95, Ru-103, Ru-106, Sb-124, Sb-125, Se-75, Zn-65 and Zr-95.

The NRC guidance on REMP in NUREG-0472 (NUREG, 1982) stipulates a list of 12 radionuclides with specific detection and reporting requirements (MDC and Reporting Levels) that would lead to the highest potential exposure of members of the public resulting from plant operation. This list includes: Mn-54, Fe-59, Co-58, Co-60, Zn-65, Zr-95, Nb-95, 1-131, Cs-134, Cs-137, and Ba/La-140. However, if other spectrographic peaks are identified during sample analysis, or if unidentified peaks are noted in the analysis, the reporting laboratory is required to evaluate the additional radionuclides and report their presence in the sample. Consequently, the 23 radionuclides typically listed on the REMP sample gamma isotopic ERM 20 YANKEE /0015181-1/28/05

analysis report do not reflect the only radionuclides that could be reported. In addition to gamma isotopic analysis, gross beta and H-3 analyses are also routinely performed in evaluating environmental media as part of the REMP.

The REMP is also designed to allow a comparison of levels of radioactivity in samples from the area potentially influenced by the plant to levels found in areas not influenced by the plant. The monitoring locations in the first area are designated as "indicators" and the second area monitoring locations are designated as "controls." The distinction between the two areas, for a particular pathway, is based on relative direction and distance from the plant. Analysis of survey data from the two areas is used to differentiate between radiation due to plant activities and that due to other sources such as atmospheric nuclear weapons test fallout or seasonal variations in the natural background.

The REMP monitors four pathway categories that include the sampling of particulates and gaseous 1-131 in air; soil, sediment and water; and milk, fish and vegetables. In evaluating analysis results of environmental samples, it is necessary to consider the variability of natural and man-made sources of radioactivity, their distribution in the environment, and their uptake in environmental media. This variability is dependent on many factors including station release rates, past spatial variability of radioactive fallout from nuclear weapons tests, on-going redistribution of fallout, contribution from cosmogenic radioactivity, groundwater dynamics, soil characteristics, farming practices, and feed type. Any one of these factors could cause significant variations in measured levels of radioactivity. Therefore, these factors need to be considered in order to properly explain any variations in radiation detected and to distinguish between natural and station related radioactivity.

Environmental sampling results, as part of the REMP program, were reviewed for a twenty-year period from 1983 to 2003, for this report. This period encompasses ten years of plant operational history and ten years of post operational history. Previously, a review of the airborne pathway data in the REMP program from 1961 through 1997 was conducted, and the results are documented in Reference (Cummings, 1998).

The graphs of the annual average REMP results in the figures below represent only positive concentrations (greater than instrument background) for the nuclides of interest. Additionally, the graphs represent those nuclides for which sufficient results exist to provide a trend plot. Error bars are presented for those data that listed the mean and the uncertainty in the mean in the Annual Radiological Environmental Operating Report (AREOR). All other positive nuclide ERM 21 YANKEE / 0015181-1 /28/05

results are discussed in the Summary of Results for each media category.

Any gaps in the graphed data reflect results that were not positive rather than that no sample was collected. Only in one instance, in 1991, a maple syrup control sample was not available.

3.2 INHALATION PATHWAY & AIRBORNE PARTICULATES Air sampling was conducted at 7 locations (5 indicator and 2 control) throughout the twenty-year period evaluated. Each sampling station was equipped with an apparatus containing a glass fiber filter for collection of airborne particulates and a charcoal cartridge for collection of gaseous iodine. The air samplers operated continuously and the filters were changed and analyzed weekly. The particulate filters were analyzed for gross beta radioactivity and the cartridges were analyzed for 1-131 activity. A trigger level was set for the gross beta activity, above which, an individual filter would be analyzed by gamma spectrometry. Samples from each week in a given quarter were combined to form a composite sample for each location. The composite samples were analyzed by gamma spectrometry.

Positive gross beta activity (above instrument background) was routinely detected at all indicator and control stations. This radioactivity is attributable to naturally occurring radionuclides, as evidenced by the close correlation between the indicator and control stations shown in Figure 5. The gross beta results represent annual averages of 260 gross beta filter analyses from the indicator stations and 104 filters from the control locations. The evident spike in 1986 is the result of fallout from the Chernobyl incident. Gross beta results were elevated at both indicator and control stations in May and June of 1986. These filters, when analyzed by gamma spectrometry, revealed the presence of Cs-137, Cs-134, Ru-103, and Ru-106 (YAEC, 1986).

The only gamma emitting nuclide detected in the air filter quarterly composites, besides those resulting from the Chernobyl incident, was naturally occurring Be-7. No Yankee plant-related radioactivity was detected on either the particulate filters or the charcoal cartridges in the last twenty years.

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Figure 5 - Annual Average Gross Beta Concentration - Air Particulate Filters 0.06 0.05 E 0.04 0.03 0.02 0.01 0

1982 1987 1992 1997 2002 Year

- --g. beta indiator --- g. beta control 3.3 SOIL Soil analysis was performed in situ using a portable gamma spectrometry analysis system, every three years. The in situ soil was analyzed at the air sampling locations in 1978, 1981, 1984, and 1987. In addition, core samples of the soil were collected for a laboratory confirmatory analysis.

These results have been evaluated and reported as part of a review of the airborne pathway data to determine non-impacted area classification (Cummings, 1998). This review indicates naturally occurring K-40 and Th-232 and Cs-137 from weapons testing fallout.

3.4 GROUNDWATER Two fresh water sites were monitored for groundwater as indicator stations. The first was the on-site well (potable), and the second was Sherman Spring (0.2 kin). There were no control locations.

Samples were taken monthly and analyzed for gross beta, gamma spectrometry, and H-3. Samples from each month in a given quarter were also combined to form a composite sample. The composite samples were analyzed for H-3.

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No gamma emitting radionuclides have been detected in groundwater from either location. H-3 has been detected in Sherman Spring throughout the period evaluated. Figure 6 shows the decrease in the concentration over time, relative to the concentration measured in the river water at Harriman Reservoir. This figure presents the results of all the samples analyzed.

Figure 6 - Tritium in Water 2500 2000 1500 0

0 5

-500 iN £O N N Date

[- Harriman Station - Sherman Spring]

3.5 SURFACE WATER River or surface water was sampled from 2 indicator locations, one in the vicinity of the discharge point in Sherman Reservoir, one at Bear Swamp, 6.3 km downriver, and 1 control station, upriver at Harriman Reservoir (10 km). Samples were collected monthly and analyzed for gross beta and gamma spectrometry. Samples from each month in a given quarter were combined to form a composite sample for each location. The composite samples were analyzed for H-3.

No gamma emitters have been detected in the river water. Figure 7 below shows the gross beta concentrations from Bear Swamp and Harriman ERM 24 YANKEE /0015181-1/28/05

Reservoir. This figure presents the results of all the samples analyzed.

Figure 8 shows the annual average tritium concentration from Bear Swamp and Harriman Reservoir. The concentrations can be put into perspective by comparison to the NRC Reporting Level for tritium in non-drinking water paths, 30,000 pCi/L and to the EPA Maximum Contaminant Level (MCL) for tritium in drinking water. 20,000 pCi/L.

The required MDC for the analysis is 2,000 pCi/L.

Figure 7 - Gross Beta in River Water 6

S C

0 3

82 0

-1 Date I- WR-11 (No. 4 Station) - WR-21 (Harriman Reservoir)]

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Figure 8 - Tritium in River Water 2000 1800 1600 1400 0

1200 1000 0

800

• 600 400 200 0 . .. . . . . . . . . . . . . . . . .. . .

1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 Year E-uWR-11 Bear Swamp -U-WR-2lHanman Reservoi 3.6 SEDIMENT Sediment samples were collected semi-annually at 3 locations: 2 shoreline cores and an additional bottom sediment core at Sherman Reservoir. The two indicator locations were: Sherman Reservoir (discharge, 1989-present) and Deerfield River No. 4 station (36.1 km down river). The control station was upriver at Harriman Reservoir (10 km). The sediment samples were sectioned into 2-inch cores prior to analysis by gamma spectrometry.

Figure 9 shows the semi-annual sediment results for the Deerfield River and Harriman Reservoir. The data represents the average of the first three core sections.

Natural K-40 was detected in all sediment samples, and Cs-137 was detected in most. In addition, Co-60 was measured in some Sherman Reservoir sediments as discussed in Section 4.4. No other plant-related radionuclides were detected. The Cs-137 concentration at Harriman Reservoir, the control location, was considerably elevated in 1984. The AREOR for that year indicated that several core samples were taken a short distance from the traditional sampling location at the reservoir. The higher levels of Cs-137 are attributed to the very high organic content of these sediments that were collected near the high water mark. The technical explanation for this is given in Bellini, 2000. This data illustrates ERM 26 YANKEE /0015181-1/28/05

the variability with which radionuclides may distribute in the environment, and the caution that must be used in interpreting environmental results.

Figure 9 - Cs-1 37 Concentration In Sediment 2450

- 1950-0 C 1450 0

C 950 450

-50 Date I----SE-11 (No. 4 Station) -,-SE-21 (Harmiman Reservoir)!

3.7 INGESTION PATHWAY 3.7.1 Fish Fish samples were initially analyzed from 2 locations, one in the vicinity of the discharge point in Sherman Reservoir, and one upstream at Harriman Reservoir (10 km), in an area not influenced by the plant. The samples were analyzed by gamma spectrometry.

The only radionuclides detected in fish were fallout related Cs-137 and naturally occurring K-40 (see Figure 10).

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Figure 10 -Annual Average K-40 and Cs-137 Concentration - Fish 100000 181000 a 10 Yea 0.1 1983 1988 1993 1998 2003 Year

-.-- K-40 indicator --o-K-40 control -- Cs-137 indicator -a-Cs-137coDntrol - Required Cs-137 MDC 3.7.2 Food Crops & Maple Syrup Farm crops were collected at the time of harvest from 1 to 4 indicator stations depending on the results of a land use census, and one control location in Williamstown, MA, at 21 km.

Food crops have consisted of fruit and broad leafy vegetation. The sampling locations for this media vary based on the results of the annual land use census indicating the location of gardens and meteorological dispersion information for the year. The edible portions of the crops are analyzed by gamma spectrometry.

Due to the importance of maple syrup, as a commercial product in New England, samples have been collected annually since the early seventies, even though they are not required by the radiological environmental technical specifications (RETS). Sampling locations varied based on the land use survey results, and are documented each year in the annual environmental operating reports. The samples were analyzed by gamma spectrometry (see Figures 11 and 12).

K-40 has been detected consistently in all food crops and in maple syrup.

Cs-137 has been detected in food crops in two out of the twenty years 28 YANKEE /0015181-1/28/05 ERM 28 YANKEE /0015181-1/28/05

from indicator locations. In addition, Cs-137 has been detected in maple syrup from indicator and control locations. Because the syrup is collected from the manufacturer as a finished product that has been boiled down as part of the production process, the concentrations of nuclides do not represent environmental levels. It is estimated that the resulting syrup has been concentrated by a factor ranging from 15 to 120 times the original sap depending on the time of season and sugar content of the sap collected (YAEC, 1983-2003). No plant-related radionuclides have been detected.

Figure 11 - Annual Average K-40 and Cs-1 37 Concentration - Maple Syrup 10000 1000 0

0~

0 100 (a

A 10 1 '. I I . ,

ý , ,

. , , , i 1982 1987 1992 Year 1997 2002

--6-K-40 indicator -K-40 control -.-- Cs-137 indicator -ACs-137 control ERM 29 YANKEE /0015181-1/28/05

Figure 12 - Annual Average K-40 Concentration - Food Crop 10000 9000 8000 0) 7000 0

6000 C

4000 C

300 42000 1000 0

1982 1987 1992 1997 2002 Year

-. -0indicator -- K-4 conftrl 3.7.3 Milk

,Milk sampling was conducted monthly and twice per month during the "grazing season" that runs from June to November. During that time, milk samples were obtained from two indicator stations (if available) and at least one control station. The indicator stations are chosen based on the annual Land Use Census and current meteorological deposition information and typically are located within five miles of the Yankee Rowe site. Beginning in 1999, no indicator station was available for milk sampling. All samples were analyzed by gamma spectrometry and by nuclide specific analysis for Sr-89, Sr-90 and 1-131.

The review of the results for the period between 1983 and 2003 indicate similar K-40 concentrations at the indicator and control stations. Cs-137 and Sr-90 in both control and indicator stations were detected in amounts that were typical throughout the New England environment as a result of nuclear weapons testing fallout and have decreased since the cessation of above ground weapons testing in the 1980s. Figures 13 and 14 show the annual average concentrations for Cs-137 and Sr-90 in raw milk, respectively. In addition to the indicator and control stations for the YNPS, annual average concentrations in pasteurized milk for New England were obtained from the EPA Environmental Radiation Ambient Monitoring System (ERAMS) web site, and from two additional New England sampling locations. Data is included for 1982 to illustrate the extreme variability (as evidenced by the error bars) that was present in ERM ERM 30 30 YANKEE /0015181-1/28/05 YANKEE /0015181-1/28/05

fallout related radionuclide concentrations in New England milk at that time. These large variations are due to differences in the feeding practices at the various farms. In particular, the amount of pasture vegetation vs.

stored feed and the amount and type of vegetation in the animals' diet when on pasture (YAEC, 1983-2003).

Figure 13 - Annual Average Cs-137 Concentration - Milk 30, 25 [

20

./Required MDC = 18 pCi/L

-l 115 1986: Change in the number of indicator stations due to sale of cow herd 5' 10 1993: Goat farm replaces cow farm 10 5

iU 0- T I  ! l * . . . . . . . . . . . . . . . .

1981 1986 1991 1996 2001 Year

- Cs-137 indicator W-- --- Cs-137 control --Avg. EPA VT/NH pastuized

--Required MDC -CNew England - A -- o- New England - B Figure 14 -Annual Average Sr-90 Concentration - Milk 30.0 25.0 0) 20.0 0

C 15.0 o

0 0(D 10.0 5.0 0.0 -

1980 1985 1990 Year 1995 2000

-U-Sr-90

-- indicator Sr Location NE - A -,-+- Sr-90 controlNE-B Sr Location Avg. EPA VT/NH, pastunzed - Required MDC ERM 31 YANKEE /0015181-1/28/05

4.0

SUMMARY

OF THE NATURE & EXTENT OF CONTAMINATION 4.1 OVERVIEW This section provides a summary of the nature and extent of impact identified from radionuclides and OHM in the environment by media, i.e.,

soil, groundwater, surface water, sediment, and fish. This summary is based on the results of past and ongoing investigations incorporating results available through December 2004. Additional investigation and remediation will continue concurrent with site decommissioning efforts requiring update of the findings presented. Once decommissioning, remedial and restoration actions are complete, an assessment of the level of risk to human health and the environment posed by residual impacts will be completed to support closure and restrictions on future use of the site.

4.2 SOIL 4.2.1 Radiological The soil data are presented in three groups; 1) land areas outside of the industrial area; 2) within the industrial area; and 3) within the RCA. The number of samples collected for which a result was reported are listed; the number of samples with detectable radioactivity, the range of concentrations detected as well as the mean and standard deviation are reported. Tables 19 through 21 summarize data from soil samples collected for radiological analysis. The samples were counted by gamma spectroscopy and a broad range of radionuclides was analyzed for as noted in the table footnote, however, only those nuclides for which results were reported appear in the tables. A summary of analysis methods is included in Appendix B.

The area encompassed by the RCA would be expected to be the most impacted by radioactivity from plant operations and that table does show the highest concentration of radioactive measurements. It would be expected that land areas outside and inside the industrial area would either be the same or the land areas outside the industrial area would be slightly lower. Precise comparisons of the data for these different areas of the site are difficult given the targeted nature of the sampling in the Industrial Area.

ERM 32 YANKEE /0015181-1/28/05

It is important to note that these data are interim characterization data and are used to support initial classification of areas for the FSS. Soil samples along with other survey data will be collected during the FSS in accordance with the FSS QAPP and approved procedures. The results from these samples will comprise the final record of radioactivity in soils at the site and will be used to demonstrate compliance with applicable DCGLs for NRC license termination and risk assessment.

4.2.2 Oil and/orHazardousMaterials 4.2.2.1 Background Areas A total of 23 soil samples, which included three duplicate samples, were collected from ten background soil sample locations during the soil sampling event. Background soil sample locations are shown on Figures 15 and 16. Validated background soil analytical results are summarized in Table 22. None of the background samples exhibited OHM at levels exceeding Reportable Concentrations (RCs). None of the background soil samples were analyzed for Volatile Organic Compounds (VOCs) because Flame Ionization Detector (FID) field screening results were not greater than or equal to 5 ppm.

4.2.2.2 Industrial Area A total of 250 soil samples, which included nine duplicate samples, were collected from 36 locations within the Industrial Area of the YNPS.

Industrial Area soil sample locations are shown in Figure 16. Industrial Area soil analytical results are summarized on Table 22. Results exceeding applicable RCs are highlighted.

RCS-1 criteria were exceeded for beryllium at SB-001. A total of 11 confirmatory soil samples were collected and analyzed for beryllium at and in proximity to SB-001. All analytical sample results were below method detection limits (0.5 milligram per kilogram (mg/kg)). Therefore, the beryllium RC exceedance was not confirmed and is not plant related.

RCS-1 criteria were exceeded for EPH (C11 - C22 Aromatics) at SB-005.

The detection of EPH at SB-005 may be associated with the overlying pavement at the sample location. Additional investigation is on-going.

RCS-1 criteria were exceeded for dioxin at SB-020, SB023, and SB-074. A total of 11 confirmatory soil samples were collected and analyzed for dioxin at and in proximity to SB-020. Sample location SB-020 and the samples collected on a 10-foot grid around SB-020 were all below the RC for dioxin total equivalent quantity (TEQ). However, two sample ERM 33 YANKEE /0015181-1/28/05

locations along a 150-foot grid contained dioxin TEQs greater than the applicable RC. The detection of dioxin at SB-020, SB023, and SB-074 could be associated with operation of former incinerators at the YNPS.

Additional investigation is proceeding.

The Department has proposed to increase the RCS-1 standard for dioxin TEQ from four picograms per gram (pg/g) to 20 pg/g. None of the samples for SB-020 or SB-023 exceed the proposed RCS-1 standard for dioxin TEQ. SB-074 does exceed the proposed RCS-1 standard for dioxin TEQ.

RCS-2 criteria were exceeded for PCBs at SB-032, SB-042, SB-078, and SB-092. The detection of PCBs at SB-032, located in an area targeted for soil excavation, is consistent with the findings of the Phase II - Comprehensive Site Assessment (CSA) (ERM, 2003) that addressed a release of PCB-containing paint chips. The detection of PCBs at SB-042, SB-078, and SB-092, located beyond the area targeted for soil excavation, will be addressed under future remedial actions for soil planned for 2005.

RCS-2 criteria were exceeded three PAHs (benzo(a)anthracene, benzo(a)pyrene and benzo(b)fluoranthene) at SB-056. The detection of PAHs at SB-056, located along a site access roadway, may be associated with incidental releases of petroleum from on-site vehicle use. Additional investigation is ongoing.

RCS-2 criteria were exceeded for two PAHs (benzo(a)anthracene and benzo(a)pyrene) at SB-071. The detection of PAHs at SB-071 may be associated with a former fuel oil AST. Additional investigation is ongoing.

4.2.2.3 Non-IndustrialArea A total of 192 soil samples, which included ten duplicate samples, were collected from 56 locations within the Non-Industrial Areas of the YNPS.

Non-Industrial Area soil sample locations are shown in Figures 15 and 16.

Non-Industrial Area soil analytical results are summarized on Table 22.

Results exceeding RCs are highlighted.

RCS-1 criteria were exceeded for TPH at locations SB-157 and SB-158, which are located within the Visitor Center Parking Lot, and may be associated with incidental releases of petroleum from on-site vehicle use.

Further soil sampling is planned to evaluate the extent of TPH impacted soils near the Visitor's Center.

ERM 34 34 YANKEE /0015181-1/28/05 YANKEE /0015181-1/28/05

RCS-2 criteria were exceeded for three PAHs (i.e., benzo(a)anthracene, benzo(a)pyrene, and benzo(b)fluoranthene) at SB-105. A total of 29 confirmatory soil samples were collected and analyzed for PAHs at and in proximity to SB-105. In addition to the three PAHs that had previously exceeded RCs, four additional PAHs (benzo(k)fluoranthene, chrysene, dibenz(a,h)anthracene, ideno(1,2,3-cd)pyrene) were detected above RCs.

Total PAH concentrations ranged from non-detect to greater than 300 mg/kg. The concentrations of PAHs increased with depth. Elevated levels of PAHs correlated with field observations of railroad ties and petroleum odors. Further soil sampling is planned to evaluate the extent of PAH impacted soils near SB-105.

RCS-2 criteria were exceeded for beryllium at SB-111. A total of 11 confirmatory soil samples were collected and analyzed for beryllium at and in proximity to SB-111. All analytical sample results were below method detection limits (0.5 milligram per kilogram (mg/kg)). Therefore, the beryllium RC exceedance was not confirmed and is not plant related.

RCS-2 criteria were exceeded for lead at SB-135. A total of 29 confirmatory soil samples were collected and analyzed for lead at and in proximity to SB-135. The analytical results ranged from 18 to 2,900 mg/kg and nine out of 13 samples exceeded the applicable RC of 600 mg/kg, thereby confirming the original results. At each sampling location the concentration of lead decreased with depth and did not exceed the RC for any 1-2 or 2-3 foot intervals. The detection of lead at SB-135 is attributed to former use of this portion of the site as the Old Shooting Range.

Further soil sampling is necessary to evaluate the extent of lead-impacted soil near SB-135 and conduct abatement as necessary.

4.3 GROUNDWATER 4.3.1 Site Conceptual Model Groundwater investigations began at YNPS in 1977, with drilling of the first monitoring well. Since then, a total of 65 additional monitoring wells have been drilled. Sampling of the wells has identified tritium in shallow ground water within a stratified drift aquifer beneath the site. The concentration of tritium in the shallow ground water is generally low, with a maximum of about 5,000 picocuries per liter (pCi/L).

The most recent round of drilling occurred during the summer of 2004, when ten wells were drilled to further refine the definition of hydrogeologic features that control the fate and transport of tritium that has been identified in groundwater beneath the site. This recently ERM 35 YANKEE /0015181-1/28/05

completed investigation followed a comprehensive episode of drilling completed the previous year, which discovered an aspect of the tritium plume that was unrecognized earlier. The work completed in 2003 is reported in Hydrogeologic Report of 2003 Supplemental Investigation (Hydrogeologic Report) (YAEC, 2004b). Earlier groundwater investigations are summarized in Site Ground Water Data Collection for YNPS Decommissioning, Rev 1 (YAEC, 2003).

Before 2003, virtually all of the wells drilled were shallow and did not penetrate a lodgement till layer presumed not to contain groundwater, which is beneath the surficial stratified drift aquifer that underlies the site.

During the summer 2003 drilling program, for the first time, several wells were drilled through the entire sequence of sediments overlying bedrock.

These sediments were deposited by continental glaciers that occupied the region during the Pleistocene geologic epoch. The results of the 2003 investigation suggested that the lodgement till beneath the stratified drift was about thirty feet thick and was underlain by a thick sequence of glaciolacustrine sediments that had been deposited within a glacial lake.

Several thin, discrete sand aquifers containing tritium at concentrations greater than those measured in the stratified drift were encountered and thought to be interlayered within the glaciolacustrine sequence.

The 2004 drilling included wells at two locations (MW-106 and 108) near the middle of the Deerfield River Valley. These were some of the deepest wells that have been drilled at YNPS and penetrated the stratified drift, lodgement till, and glaciolacustrine sediments that had been encountered elsewhere on site. Correlation of the sediments exposed by the 2003 and 2004 drilling campaigns reveals that the lodgement till is thicker and the top of the underlying glaciolacustrine sequence is deeper than originally thought. This interpretation implies that many of the thin, discrete sand aquifers are interlayered within the lodgement till rather than the glaciolacustrine sequence. Figures 17 and 18 show the stratigraphy along two cross sections A-A' and C-C', oriented northwest-southeast and north northwest-south southeast across the site, respectively. These cross sections are revised from those presented in the Hydrogeologic Report, and include the new wells MW-106 and MW-108.

The depositional process that produced this arrangement of sediments within the till can be described as follows. Short-term fluctuations in climate, causing warming that may have spanned a period of a few years to a few decades, resulted in a temporary stagnation or retreat in movement of the ice sheet and a net increase in melt water. This melt water deposited the relatively clean, well-sorted sand aquifers into crevasses and ice channels within or on the margins of the glacier. As the climate reverted to colder temperatures that were more normal ERIM 36 YANKEE /0015181-1/28/05

throughout the Pleistocene, there occurred a net increase in snow accumulation and decrease in melt water. Under these conditions, the ice front advanced, once again depositing lodgement till beneath its base and overriding the crevasse and ice-channel filling.

This sequence of fluctuating climate repeated during several episodes, resulted in a series of thin, discrete sand aquifers that were found interlayered within the lodgement till at YNPS. The process by which the sand aquifers apparently were deposited suggests that they are isolated, discontinuous, poorly connected and of limited extent. This stratigraphy has obvious implications for the transport of contaminants in groundwater and suggests that the thin, discrete sand aquifers do not provide a mechanism for flow of tritium over large distances.

4.3.2 RadiologicalImpacts to Site Groundwater The preliminary results of the 2004 drilling campaign, conducted on the margins of the presumed perimeter of the tritium contamination, confirm that monitoring well clusters MW-106, MW-108 and MW-109 outline the extent of tritium contamination to the north, west and southwest of both the shallow and deeper tritium plumes. Only minor concentrations of tritium (less than 1,000 pCi/L compared to the EPA MCL of 20,000 pCi/L) were detected in the shallow aquifer at MW-106 and in two of the deeper thin, discrete sands at MW-109.

Figures 17 and 18 show the distribution of tritium in May 2004 in cross section, while Figures 19 and 20 show the tritium plume in May in plan view, at two depths. Figures 21, 22 and 23 show the groundwater elevations and direction of flow in May 2004 in the shallow aquifer, in sands about 100 feet deep and in the bedrock, respectively. Each of these three maps shows a predominant component of flow to the northwest, toward the Deerfield River below Sherman Reservoir.

Groundwater has been sampled quarterly since July 2003 in all accessible monitoring wells. Each sample is collected using the low-flow sampling technique and is analyzed for tritium, gamma-emitting radionuclides, gross alpha and gross beta activity. Most samples are also analyzed for a list of ten transuranic and hard-to-detect radionuclides. Procedure AP-8601 details the sampling schedule and list of analytes for each monitoring well. Tritium continues to be the only plant-related radionuclide detected in groundwater at YNPS. Gross beta activity is detected in all wells and gross alpha in some, but this is naturally-occurring activity associated with transformations within the uranium and thorium series, which occur within the local metamorphic bedrock.

ERM 37 YANKEE /0015181-1/28/05

4.3.3 Oil and/orHazardousMaterialImpacts to Groundwater 4.3.3.1 OHM Parameters The monitoring well locations, corresponding to each reporting category, and analytical results exceeding RCs are presented on Figure 24.

Groundwater analytical results for 2003 and 2004 are summarized on Table 23. Results exceeding RCs are highlighted.

4.3.3.2 Shallow MonitoringWells Each of the 36 shallow interval monitoring wells were sampled during either the 2003 or 2004 groundwater sampling events.

RCGW-2 criteria were exceeded for PCBs in shallow monitoring well MW-5. Analytical data from the most recent sampling event (August 2004) indicates a detection of PCBs in unfiltered samples (as particulates),

but no significant dissolved phase impact. Additional monitoring for dissolved phase PCBs will be conducted at MW-5 during future groundwater sampling events.

4.3.3.3 IntermediateMonitoring Wells Each of the 11 intermediate monitoring wells were sampled during either the 2003 or 2004 groundwater sampling events.

RCGW-2 criteria were exceeded for 1,1-dichloroethene (DCE) at MW-105C. Chlorinated VOCs were used/stored in the nearby Turbine Building (Figure 24). Therefore, the source, nature, and extent of DCE in groundwater will require further evaluation. Additional sampling for DCE will be conducted at MW-105C during future groundwater sampling events.

RCGW-2 criteria were exceeded for VPH (i.e., C5-C8 Aliphatics) at MW-101C. Review of the analytical data and resulting chromatographs indicate that the exceedance of VPH at MW-101C is likely attributable to interference by either acetone or isopropyl alcohol and is not attributable to petroleum hydrocarbons. Therefore, the VPH exceedance of the RC does not require notification to Department. Acetone and isopropyl alcohol sample results at MW-101C are below applicable RC criteria.

RCGW-2 criteria were exceeded for PCBs at MW-107D. The exceedance of RCGW-2 for PCBs at MW-107D is attributable to PCB-containing paint chips. Analytical data from the most recent sampling events (i.e., May and August 2004) indicate that PCBs were not detected in the dissolved ERM 38 YANKEE /0015181-1/28/05

phase. Additional sampling for dissolved phase PCBs will be conducted at MW-107D during future groundwater sampling events.

4.3.3.4 Bedrock MonitoringWells Each of the 11 bedrock monitoring wells were sampled during either the 2003 or 2004 groundwater sampling events.

RCGW-2 criteria were exceeded for PCBs at MW-107B. The exceedance of PCBs at MW-107B is attributable to PCB paint chips. Analytical data from the most recent sampling event (August 2004) indicate that PCBs were not detected in the dissolved phase. Additional sampling for dissolved phase PCBs will be conducted at MW-107B during future groundwater sampling events.

RCGW-2 criteria were exceeded for bis(2-ethylhexyl)phthalate (DEHP) at MW-108B. Additional sampling will be conducted to confirm the RC exceedance.

4.3.3.5 Water Supply Wells The two water supply wells were sampled during the 2003 and 2004 groundwater sampling events. No compounds were detected above applicable RCs for either the Facility Water Supply Well (Figure 2) or the Visitor Center Water Supply Well (Figure 1).

4.3.3.6 Sherman Spring Sherman Spring was sampled during the 2003 and 2004 groundwater sampling events. No compounds were detected above the method detection limits at Sherman Spring.

4.3.4 On-going Assessment & Remedial Considerations The data gathered during the summer 2004 drilling program are currently being evaluated, interpreted and compiled into a comprehensive hydrogeologic report that will be released in early Spring 2005. That report will include updated plume maps, groundwater flow maps and cross sections that reflect the information learned from the drilling program and the groundwater analytical data resulting from four quarters of sampling during 2004. The report will compare tritium concentrations to groundwater levels in each well, to determine if a seasonal trend can be identified. The report will also draw conclusions regarding completeness of the body of information describing the nature and extent of tritium impacts to the groundwater at YNPS.

ERM 39 YANKEE /0015181-1/28/05

Ongoing demolition of structures at YNPS has restricted access to suspected source areas of tritium in the groundwater. These suspected source areas include the spent fuel pool, the ion exchange pit, the vicinity of a breach in the chemical laboratory radioactive waste sump pipeline, and the vicinity of a failed drain pipe in the PCA storage facility.

Access to these areas should become available later in 2005. YAEC may wish to investigate these and other areas by drilling additional monitoring wells to determine the areal and vertical distribution of tritium or other radionuclides in their vicinity. The resulting information would be useful in further defining the extent of impacts to the groundwater in suspect areas not yet fully investigated, the relation between any new impacts identified and those already known, and in demonstrating the breadth of the area where the concentration of tritium may exceed a regulatory guideline.

4.4 SEDIMENT & SURFACE WATER 4.4.1 Radiological The Sherman Reservoir has been used as a source of cooling water and discharge (including stormwater discharge) for YNPS. These uses resulted in the introduction of small amounts of plant-related radioactivity into the reservoir and subsequently into the sediments.

Sediment samples from the Sherman Reservoir and other parts of the Deerfield River have been collected routinely and analyzed for radionuclide content, beginning before the start of plant operations as a part of the Radiological Environmental Monitoring Program (REMP).

REMP sediment samples were collected two to three times per year in a varying number of locations in support of plant operation and analyzed using gamma spectroscopy to identify the presence of plant-related radioactivity. The REMP included analyses Ac-228, Ac/Th-228, Ag-108m, Ag-110m, Am-241, Ba-140, Be-7, Bi-212, Bi-214, Ce-141, Ce-144, Co-57, Co-58, Co-60, Cr-51, Cs-134, Cs-137, Eu-152, Fe-59, 1-131, 1-133, K-40, Mn-54, Mo-99, Nb-95, Np-239, Pb-212, Pb-214, Ra-226, Ru-103, Ru-106, Sb-124, Sb-125, Se-75, Sr-90, Te/1-132, TI-208, Zn-65, and Zr-95. Special REMP sampling for specific investigations, mostly in Sherman Reservoir, has also been conducted over the years. Additionally, a study of river and reservoir sediment (Bellini, 2000) was undertaken as a part of site characterization studies in support of license termination, using approved plant procedures and preferred sampling techniques. These samples were analyzed using gamma spectroscopy.

ERM 40 YANKEE /0015181-1/28/05

As expected, due to licensed liquid releases, Co-60 and Cs-137 were the only plant-related radionuclides consistently identified as being present and were found in low-levels in bottom sediment samples taken from the south end of Sherman Reservoir near the Circulating Water outfall.

Slightly higher levels were found in the south end of the reservoir, most likely due to the increased amount of organic material in the sediments of that area. In general the amounts of Cs-137 and Co-60 decrease with distance downstream from the reservoir, and thus the impacts are localized to the south end of the reservoir and the areas in the immediate proximity of the storm drain outlets. Samples from other areas of the Sherman Reservoir and the Deerfield River contained no detectable amounts of plant-related radioactivity.

A follow-up sediment study (Bellini, 2001) implemented the recommendations for additional sediment sampling in the original study and reviewed more recent REMP data. In addition to performing gamma spectroscopy, sediment samples in the follow-up study were also analyzed for Sr-90. Although detected, the results for Sr-90 were consistent with background from fallout associated with nuclear weapons testing. The follow-up sediment sampling resulted in the identification of no significant presence of plant-related radioactivity in Wheeler Brook stream-bed upstream and the Deerfield River canals downstream of YNPS. The study did recommend follow-up sediment sampling as a part of the final status survey, which has been incorporated in the LTP.

A compilation of Sherman Reservoir sediment data from the HSA for Survey Area OOL-01 is included in Table 24.

4.4.2 Oil and/or HazardousMaterials 4.4.2.1 Comparison to Background Sediment sampling results for Sherman Reservoir, West Storm Drain, Deerfield River, and Wheeler Brook were compared to background sediment results. Sampling results were compared to the maximum concentrations detected in background sediment samples for total VOCs, total SVOCs, DRO, and individual metals. Total PCBs were not detected in background sediment samples. Therefore, PCB results were compared to the average method detection limit for total PCBs in background sediment samples.

4.4.2.2 Sherman Reservoir In August 2003, a total of 44 sediment samples, which included one duplicate, were collected from 36 sample locations in Sherman Reservoir ERM 41 YANKEE /0015181-1/28/05

(SD-002 to SD-041). Sample results are detailed in Table 25 and presented in Figure 23. Within Sherman Reservoir, copper (SD-008 and SD-009) and lead (SD-011) were detected at concentrations greater than five times background. Lead (SD-012) was detected at concentrations greater than three times background. Metals detected at concentrations above background are near the circulating water discharge structure (SD-008 and SD-009) and the cooling water intake pipe (SD-011 and SD-012).

TPH-DRO was detected at concentrations greater than three times background at SD-041. This detection does not appear to be related to known site activities due to its distance from the site (approximately 700 feet from the shoreline), and its upstream location in relation to the site.

4.4.2.3 Deerfield River In August 2003, a total of seven surficial sediment samples, which included one duplicate, were collected and analyzed from the Deerfield River (SD-201 to SD-206). Sample results are detailed in Table 25 and are presented in Figure 25.

Within the Deerfield River, copper (SD-204) was detected at concentrations greater than three times background. SD-204 is located in proximity to the confluence of the Deerfield River and the West Storm Drain Ditch.

In July 2004, 12 additional sediment samples, including 2 duplicates, were collected from the Deerfield River in proximity to SD-205, which is located near the confluence of the Deerfield River and the West Storm Drain Ditch. All 12 samples were submitted for analysis of PCBs. Sample results ranged from non-detect to 300 ug/kg.

4.2.2.4 West Storm Drain Ditch In August 2003, a total of six shallow sediment samples, which included one duplicate, were collected from the West Storm Drain Ditch (SD-301 to SD-305), which discharges to the Deerfield River. Sample results are detailed in Table 25 and are presented in Figure 25. Within the West Storm Drain Ditch, total SVOCs (SD-303) and lead (SD-301) were detected at concentrations greater than five times background. Total SVOCs (SD-302) and lead (SD-304) were detected at concentrations greater than three times background and may be associated with runoff from parking areas at YNPS.

In June 2004, seven sediment samples, which included one duplicate, were collected from the West Storm Ditch to confirm the results of SD-302 and ERMI 42 YANKEE /0015181-1/28/05

SD-303. Sample locations SD-302 and SD-303 were resampled and additional samples were collected in proximity to these locations. The analytical results for total SVOCs ranged from non-detect to 4,893 ug/Kg.

These sample results were substantially lower than the previous results, indicating that the previously detected levels of total SVOCs were not reproducible.

4.2.2.5 Wheeler Brook In August 2003, a total of six surficial sediment samples were collected and analyzed from Wheeler Brook (SD-101 to SD-106). Sample results are detailed in Table 25 and are presented in Figure 25. All compounds and compound groups detected in Wheeler Brook were below site-specific background concentrations.

A total of 11 surface water samples, including one duplicate, were collected from five locations along Wheeler Brook (SW-1 to SW-5). Metals and VOCs were detected in surface water analytical results.

4.5 FISH 4.5.1 RadiologicalAssessment Radiological assessment of fish in both Sherman Reservoir and at a control location, Harriman Reservoir, is provided in YNPS Annual REMP Reports. Samples are collected semi-annually. As expected in biological matter, naturally occurring K-40 was detected in all samples. No other gamma emitting radionuclides other than Cs-137 were detected in fish samples. The average Cs-137 concentrations are considered to be consistent with fallout from above ground nuclear weapons testing.

4.5.2 OHM Assessment Fish samples were collected at the site to evaluate whether the release of PCBs related to the paint chip release were present in fish in Sherman Reservoir. Fish were collected during the Phase II Comprehensive Site Assessment from the East Storm Drain Area, the northern end of Sherman Reservoir and from Harriman Reservoir. PCBs were detected in the fish tissue samples collected in the East Storm Drain Area. The Phase I1 risk characterization determined that the levels of PCBs in fish detected near the East Storm Drain Outfall do not pose a risk to consumers of recreationally-caught fish. Both the carcinogenic and non-carcinogenic risks are below the Department's risk management criteria. Subsequently, ERM 43 YANKEE /0015181-1/28/05

the fish tissues were analyzed for PCB congeners. The congener results were consistent with the PCB aroclor results.

ERM 44 YANKEE /0015181-1/28/05

5.0 SITE DECOMMISSIONING, INVESTIGATION SCHEDULE AND CLOSURE PATHWAY Decommissioning activities are being completed in three phases:

" Phase 1: Mechanically/electrically isolate the Spent Fuel Pool, remove SSCs not supporting fuel storage, and remove fuel and GTCC waste from the SFP.

" Phase 2: Dismantlement and disposition of remaining systems, structures, and components (SSCs).

" Phase 3: Termination of the Part 50 license.

As discussed herein, Phase I has been completed. Phase 2 activities are ongoing. Site investigation and remedial actions are being conducted concurrent with Phase 2 decommissioning. Phase 3 is intended to occur following completion of all radiological decommissioning activities.

The following are general decontamination and dismantlement considerations that are being incorporated, as appropriate, into the activities for decommissioning the systems, components, and structures at YNPS.

• Radiological characterization survey data has been used to identify the systems, structures, and components to be decontaminated and dismantled. Characterization data have also been collected for soils and sediments in the vicinity of the plant.

" Detailed decommissioning work documents are being developed, reviewed, and approved in accordance with project and plant programs and procedures. These documents include plans for sampling for radioactivity in soils as demolition progresses. These data add to the characterization data and may be used to direct further excavation and decontamination as appropriate.

" Plant tag-out procedures are being used to de-energize electrical and control equipment, isolate and drain fluid systems, and isolate and depressurize pneumatic systems. Radiation Protection procedures will be used to ensure compliance with radiological requirements for contamination control and worker protection and ALARA programs.

Occupation safety standards will be observed.

" Components are being identified prior to removal. The components are then removed using the techniques and methods as specified in the ERM 45 YANKEE /0015181-1/28/05

decommissioning work packages. Components are either decontaminated or shipped to a low-level radioactive waste disposal facility or, if appropriate, shipped to an approved landfill.

" Contaminated structural steel components, on which a volume reduction process is being applied, may be moved to a processing area and packaged into containers for shipment to an off-site waste processing facility.

" Remaining portions of basements and slabs will be perforated to allow for groundwater and/or surface water infiltration.

• Remaining buried contaminated components (e.g., piping, drains, and conduit) are being excavated. After excavation, the components will be examined to ensure that they are physically sound prior to cutting and removal. Most buried contaminated piping is located in steel conduits (i.e., pipes enclosed in pipes).

" After completion of decommissioning and/or remediation activities and prior to final status survey, isolation and controls will be implemented.

" A final status survey will be performed to verify removal of contamination to below release levels.

Coatings will be removed, as required by local, state, and federal regulations. PCB paints will be removed from exposed concrete surfaces as required by the Alternate Method of Disposal Authorization (AMDA) requirements prior to demolition of the structure, as authorized by the EPA on 8 October 2002 and subsequent changes thereto.

In addition to dismantlement and decontamination activities, YAEC's proposed pathway and general schedule for completing the integrated assessment of radiological and OHM impacts to the environment at the site is summarized in Figure 26. Ongoing activities to support site closure are highlighted in the green blocks (ongoing through December 2005), key reporting components are highlighted in the yellow blocks (including this Phase II Report and the Site Closure Risk Assessment scheduled from October 2005 through March 2006) and the end-point to the closure process is described in the red block (targeted for the period from January to July 2006). Key components of the proposed closure pathway include:

Ongoing coordination with MADEP (as the lead agency), other regulatory and public stakeholders on the results of site investigation and remedial actions. January 2005 through July 2006.

ERM 46 YANKEE /0015181-1/28/05

• Iterative site investigation (development of Field Sampling Plans, data collection and analysis), risk screening to determine the likelihood and/or need for remedial response actions by comparison of results to DCGLs and/or conservative risk-based thresholds (MCP Method 1 Standards), interim remedial measures as Release Abatement Measures (RAMs) for OHM or in accordance with NRC/DPH requirements for the management of radioactive materials and verification sampling and analysis to confirm compliance with target site closure requirements. January2005 through December 2005.

" Completion of a site closure risk assessment integrating results of final radiological and OHM testing post-remediation, site restoration activities (re-grading and planting) and consideration of institutional controls (deed restrictions) to demonstrate that site conditions ensure long-term protection of human health, safety, public welfare and the environment. October 2005 through March 2006.

" Preparation of a final site closure documentation consistent with the MCP (targeting a Permanent Solution as a Class A-3 RAO), public meetings, DEP written approval of site closure and execution of ongoing monitoring and maintenance plans necessary to ensure compliance with site closure requirements and approvals. January 2006 through June 2006 and on.

YAEC's proposed environmental site closure pathway is intended to provide a general framework for coordination with the Department (as the lead regulatory agency) in an effort to establish agreement on specific deliverables and a schedule that will meet both YAEC's, the Department's and other regulatory and public stakeholders needs. YAEC encourages the Department and other regulatory and public stakeholders to provide constructive comment and input regarding this proposed pathway so that YAEC can achieve site closure on schedule in a safe responsible and reliable manner.

ERIM 47 YANKEE /0015181-1/28/05

6.0 REFERENCES

Bellini, F.X. Deerfield River Sediment Screening Study. Environment Services Group-Duke Engineering and Services, October 2000.

Bellini, F.X. Deerfield River Sediment Screening Study: Follow-Up Assessment. Environment Services Group-Duke Engineering and Services, March 2001.

Cummings, Edward, "Review of YNPS REMP Reports for FSS Non-Impacted Area Classification, RP-98-62, June, 1998.

Code of Federal Regulations, Title 10, Part 50, Appendix I, "Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion 'As Low as is Reasonably Achievable' for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents."

EPA, 2002. Role of Background in the CERCLA Clean up Program. Office of Solid Waste and Emergency Response. Office of Emergency and Remedial Response. OSWER 9285.6-07P.

ERM. 2003. Phase II Comprehensive Site Assessment, Yankee Nuclear Power Station. 28 April 2003.

Gradient. 2003. Quality Assurance Project Plan Site Closure, Yankee Nuclear Power Station. Rowe, Massachusetts.

MADEP. 1995. "Guidance for Disposal Site Risk Characterization - In Support of the Massachusetts Contingency Plan (Interim final policy)." Bureau of Waste Site Cleanup and Office of Research and Standards (Boston, MA). BWSC/ORS-95-141. July.

MADEP, 2002a. Background Levels of Polycyclic Aromatic Hydrocarbons and Metals in Soil. Technical Update for MADEP 1995 Guidance of Disposal Site Risk Characterization - In Support of the Massachusetts Contingency Plan. Boston MA.

MADEP. 2002b. "Characterizing Risks Posed by Petroleum Contaminated Sites: Implementation of MADEP VPH/EPH Approach." Final Policy WSC-02-411. October 2002.

ERM 48 YANKEE /0015181-1/28/05

NUREG 0472, "Draft Radiological Effluent Technical Specifications for a PWR," Revision 3, September 1982.

YAEC. 1986. Yankee Nuclear Power Station, Annual Radiological Environmental Operating Reports, January - December 1986.

YAEC. 1983 - 2003. Yankee Nuclear Power Station, Annual Radiological Environmental Operating Reports, January - December 1983 - 2003.

YAEC. 2003. Hydrogeologic Report of 2003 Supplemental Investigation.

15 March 2004.

YAEC. 2004a January 2004. Yankee Nuclear Plant Site Historic Site Assessment, Revision 0.

YAEC. 2004b. Site Ground Water Data Collection for YNPS Decommissioning, Rev 1. Framatome ANP DE&S. February 2003 ERM 49 YANKEE /0015181-1/28/05

Tables Table 1 Sources of Radioactive Release Plant Operations & Maintenance Yankee Nuclear Power Station Rowe, MA Date Mechanism or Structure Radionuclides of Concern Release Impact Survey Area Circa 1960's Due to mechanical wear and corrosion Radioactive silver and nickel - Ag- Into the reactor coolant Resulted in distribution of radioactive silver from the initial set of control rods 108m and Ni-63 in plant systems and on equipment used during the first refueling Storage of the refueling equipment and Radioactive silver Within the Radiologically Controlled Area MARRSIM Class I survey areas prepared radioactive waste outdoors (RCA) yard area Snow removal activities performed in Area outside the RCA where snow was MARSSIM Class 2 and 3 survey areas the RCA caused a redistribution of relocated. The areas affected were inside the accumulated surface contamination industrial area fence on property governed by the YNPS NRC license, areas outside the fenced industrial area, along the rail road bed outside the east gate, and along existing roadways Rain falling on the surface of yard areas Small amounts of radioactive Redistribution of radiological contamination Portions of the drains as well as any in the RCA material have been observed in into low areas of the RCA and into the storm sediment or soil found above detectable the catch basins over the years drain system radioactive concentrations will be disposed of as radioactive waste.

A defect in the construction of the IX Pit Believed to be the source of the Leaks in the radioactive systems in the Ion Allowed contaminated water to leak, concrete tritium contamination observed in Exchange (IX) Pit resulted in contamination resulting in contamination of the subsurface the ground water at the site of the water in the IX Pit soils, asphalt and concrete around the IX Pit and adjoining structures.

These leaks as well as possible leaks Groundwater contamination continues to from the Spent Fuel Pool (SFP) that be investigated by YNPS and more will be abuts the IX Pit learned as the decommissioning progresses and these buildings are demolished Wear on internal valve components These particles were activated to Although not a frequent occurrence, Co-60 The particles associated with fuel fragments made of steUite resulted in the gamma emitting Co-60 during particles have been identified and removed have not been identified in the RCA, but introduction of wearparticles into the plant power operations. Some during surveys of the RCA. The were confined to controlled contamination reactor primary system particles associated with fuel environmental impact of these particles has areas.

K fragments were also generated been observed to be very minor as they are during plant operations microscopic in size and are insoluble as they are essentially metal chips Out of doors decontamination facilities Resulted in contamination of the soils MARRSIM Class 1 survey areas (North and South decontamination around the pads. These areas have been pads) assigned the FSSsurvey area designation of NSY-.1_

The repair of a damaged reactor cooling Resulted in contamination of the turbine MARRSIM Class 3survey areas however pump motor on the normally clean building generally and on the turbine deck this area may be reclassified due to some turbine deck and control room specifically. All decon activities performed during radioactive contamination was contained demolition within the turbine building strocture.

Mid 1970s 'YNPSconverted from stainless steel to Detectable quantities of fission Resulted in a release of fuel'pellets directly Contributed to changes in the radionuclide zirconium clad fuel pins. Some of the products such as Cs-137 and Cs- into the reactor coolant system. profile at the plant zirconium fuel pins failed in the reactor 134 were dispersed throughout clarify as 'fuel pellet fragment" and delete due to vibrational stress from water the primary side plant systems the word "directly" jetting. The pin failure resulted in a and the fuel handling facility for release of fuel pellets directly into the the first time in the plant reactor coolant system.. operating history 1981 Relocating the reactor head to its The impact dislodged particulate This resulted in contamination of the RCA MARRSIM Class I survey areas outside storage location, the reactor radioactivity adhered to the yard area under and around the equipment head made contact with the wall above underside of the reactor head. hatch.

the equipment hatch in the Vapor Container.

1984 PVC drainpipe that connected the PCA This event occurred in survey area WST-02 MARRSIM Class I survey areas storage building to the Waste Disposal (Figure 3). The line ran diagonally from Building. The PVC pipe joints failed survey area WST-01 (old PCA) to survey allowing liquid to flow from the area WST-03 through the NE quadrant of the drainpipe into the surrounding soil. warehouse (Figure 3). The line was excavated and repaired and the affected soil disposed off-site as radioactive waste Circa 1994 Use of an underwater plasma torch to This changed the radionuclide mis This cutting debris was contained within the Contributed to a change in the radionuclide section of the reactor internals resulted of the residual contamination in plant system and was essentially insoluble profile at the plant in the release of highly radioactive the shield tank cavity and, to a due to its metallic nature. No environmental cutting debris into the shield tank certain extent, in the Spent Fuel release was observed.

cavity shield water. Pool.

All events listed in chronological order 1 of 1

Table 2 Radiological Source References Yankee Nuclear Power Station Rowe, MA Category Types of Documents Reviewed License and Technical Specifications. 9 Technical Specification and Changes

• License amendments Original Plant Design . Function and purpose of systems and structures

• Plant operating parameters

• Plant operating procedures Original Plant Construction Drawings

• Specifications for systems and structures and Photographs

• Field Changes/As-Built drawings 0 Site Conditions Plant Operating History 0 Abnormal Operating Reports (AOR) 0 Licensee Event Reports (LER)

• Plant Information Reports (PIR)

• Radiological Occurrence Reports (ROR)

• Radiological Incident Reports (RIR)

• Condition Reports (CR)

• Plant Operating Procedures Regarding Spills and Unplanned Releases

• Plant Operations Logbooks

• Radiological Environmental Monitoring Program and Radiological Environmental Technical Specification Reports (REMP & RETS)

• Monthly Plant Operations Reports

• Semi-Annual Plant Operations Reports Work Control Documents and Site

• Job Orders Modifications 0 Plant Alterations

• Engineering Design Change Requests (EDCR)

• Plant Modifications

• Maintenance Requests Radiological Surveys and Assessments

• Radiological surveys performed in support of normal plant operations and maintenance

• Radiologicaf surveys performed in support of special plant operations and maintenance

• Radiological assessments performed in response to radioactive spills or events

• Scoping and characterization surveys performed as part of Decommissioning Plan development

'Remediation support surveys conducted during decommissioning activities

• Surveys conducted under the guidance of NUREG/CR-5849 (Reference 2-4)

The YAEC Decommissioning Plan

• Decommissioning Work Plans

. Secondary Side Work Plans 0 Engineering Change Notifications

• Field Change Notifications

• Temporary Change Requests Data from personal exit interviews regarding,Plant operational history _____________________________

The historical evaluations performed for the previously submitted LTP Documentation of remediation area stabilization and restoration activities-1 of 1

Table 3 Sources of Radioactive Release Unplanned Releases Yankee Nuclear Power Station Rowe, MA ie.sampie contamea it nair-uter contamer or reactor cooiant water was aroppea on approximately 35 mCi. the asphalt in the Potentially Contaminated Area between the (specific radionuclide data not Primary Auxiliary Building and the Waste Disposal Building.

available)ý The spill was absorbed using absorbent paper and the area decontaminated by mopping. The fixed contamination remaining was approximately 0.05 mr/hr at 1 inch from the pavement.

9/18/1963 Shield-Tank Cavity Contamination levels were 106 A one-half inch sampling valve located over the IX Pit was 63-12 NOL-1/NOL-2 NSY-2 Fill Water Spill to 107 dpm (Specific inadvertently left open while filling the shield tank cavity.

radionuclide data not This resulted in aspill of approximately 10 gallons of water

- available) over areas of several from the Safety Injection Tank. A portion of the spill ran off square inches. the deck of the pit and onto a section of the blacktop surface to the west of the pit. The radiation level in the inimmediate area was70-100 mr/hr measured at one inch. Run off water 2

resulted in contamination levels of 20-60,000 dpm/ft (Sic).

10/8/196 De-watering Pump At the time the leak was A water leak from the fuel chute de-watering pump was 63-17 OOL-5/OOL-6/NOL-01 East Storm Drain System Packing Leakage identified` 6 to 8 inches of routed, via a small utility hose, to a 30-gallon collection drum water had accumulated in the placed in a stormdrain catch basin (ECB-005) located between barrel with activity of 6 x 10"' the railroad tacks and the NE comer of the spent fuel pit. It mCi/ml (specific radionuclide was determined that the bottom rim of the barrel was data not available), corroded, and water was leaking from the bottom of the barrel.

It was believed only a small amount of water was leaked to the storm system.

9/3/1964 Seal Water Tank An estimated 35 gallons of Shutdown cooling pump seals leaked reactor coolant water 64-08 AUX-1 West Storm Drain System spill water containing a total and back-flowed into the seal water tank.- This caused the tank activity of 270 mCi (specific to overflow through the vent connection, into the common radionuclide data not relief valve discharge line and onto the Primary Auxiliary available) was released. Building roof. The Roof Drain System drained into the Storm Drain System via a subsurface piping connection. A sample of the storm drain (WCB-009) was determined to contain 1 x 10-6 mCi/ml. The predominant isotopes were Co-58, Co-60, and Mn-54 (distribution of the radionuclides in the sample not available). Service Water was diverted to the storm drain to flush the system.

Page 1 of 5

Table 3 Sources of Radioactive Release Unplanned Releases Yankee Nuclear Power Station Rowe, MA IX Pit High Level -. I he radionuclides and After tuling me ion txcnange nt to its normal operating level, Leakage Coming Up concentrations identified the operator failed to close the fill Valve. Water continued to 5/OOL-6 internal and external to piping through Pavement were: Ag-r10m at 5 x 1067 flow into the pit from the Primary.Water Storage Tank by (backfill) / SFP-02 sub-floor /

gravity feed. Later, the operator noticed water seeping NSY-09 / AUX-01 North mCi/mi and Co-60 at 1 x 1e through the blacktop on the west side of the pit, diagnosed the external perimeter (backfill)/

ma/mi/.

cause, and dosed the valve. The water on the blacktop was. SFP-01 West external perimeter sampled and was found to contain radioactivity. The blacktop (backfill) / BRT-01 Eastern was rinsed down with Service Water to the storm drain (ECB- external perimeter I

005)

A two-inch priming valve for the Spent Fuel Pit (SFP) cooling 06-07 SFP-01 North external wall East Storm Drain System 9/27/1966 Spent Fuel Pit Watei This occurrence resulted in a Spill total release of 4mCi gross b-g and purification pump was left open; however an upstream /NOL-01/OOL-01 internal and external to piping and 670 mCi of tritium (more valve isolating make up water to the Low Pressure Surge Tank (backfill between SFP-01 and specific radionuclide data not (LPST) was correctly closed. The LPST make up pump was ECB005) available). started to provide make up water to a hose connection located between the two valves to wash down a shipping cask as it was removed from the pit. Water flowed through the open priming valve to the SFP in sufficient quantity to result in actuation of the high level alarm. The reason for the high level alarm was not immediately determined and by the time the reason was identified water had overflowed from the SFP.

Approximately 33 gallons of water flowed down the SFP exterior wall, over a small section of asphalt paving and into an immediately adjacent storm drain, ECB-005. A continuous service water flush of the east side culvert system (ECB-005) was initiated and continued for a 24-hour period.

9/27/1966 Abnormal Activity This occurrence resulted in a Water from the west storm drain culvert was sampled (the SFP 66-08 OOL-5/OOL-6 West Storm Drain system in Storm Drain total release of 0.8 mCi gross b- water released discussed above discharged to the east side g and 3.32 mCi tritium. only). An average of two samples from the west side showed gross activity of 6.7 x 1iy7 mCi/mi (specific radionuclide data not available). Investigation found a relief valve on the safety injection tank heating system to be slowly leaking into a floor drain in the PAB. The floor drains in that section of the building were traced to discharge to a storm drain located on the outside of the building (WCB-009). Further investigation indicated that the relief valve leak could not have existed for more than one day and that the maximum volume did not exceed eight gallons during that period. A sample of culvert water collected 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the occurrence indicated a gross activity of 1.2 x 10* mCi/ml and tritium activity of 5.1 x 10"s mCi/ml.

Page 2 of 5

- -- m - - m - - l---- ------ D Table 3 Sources of Radioactive Release Unplanned Releases Yankee Nuclear Power Station Rowe, MA Approximately ll gallons of Tne nose usea tor a routine araming otte ruei cnute pump discharge line burst. Less than 10 gallons of contaminated water with an activity of 3.0 x 10"3 mCi/ml (for a total of 113 water flowed into a storm drain served by the east culvert mCi) was released. (ECB-005). The spill area was flushed with service water. The east culvert was sampled after the spill.

1/16/1968 Waste Hold-up A total of 520 mCi b-g and 698 The suction line from the waste hold-up tank was found to be 68-01 NSY-7 Tank Moat Spill mCi tritium were spilled into frozen. Approximately 200 gallons of water spilled froma the moat. valve bonnet failure caused by the freezing of the suction line.

The spill was contained within the moat structure.

7/16/1975 Yard Area An area of land near the Ion Over the next few days, the entire restricted area was 75-07 NOL-01 through NOL-06 SVC-03 beneath slab in old Contamination Exchange Pit was identified surveyed. Fourteen areas, ten of which were in areas and SVC-03 RCA access alley with a contamination level of previously identified as a "clean area," were found to be 2

approximately 500,000 dpm. contaminated at levels greater than 1000 dpm/100 cm . Most of the contamination was removed, and the remaining contamination was sealed in place using asphalt sealer and covered with clean soil.

12/21/1977 Service Building A boring bit inadvertently punctured the 2.5-inch stainless 77-16 NOL-2 Soils surrounding perforation Radioactive Sump steel line leading from the Service Building Sump Tanks to the and transfer line backfill/Soils Transfer Line PAB while conducting core borings inside the Radiation to a depth of 61.5 feet and Puncture Control Area. The sump line ran at a depth of 15 feet below along the bore hole.

underground, where the damage occurred, and the boring depth was 61.5 feet. The damage was not detected until the next day when the sump pump started and water issued from the borehole. The sump pump ran through two cycles resulting in 20 gallons of water discharged from the rupture.

The water contained the following:

Radionuclide Total Activity, Concentration, Fraction of 0mCi mCi/ml MPC 1-131 16.5 2.18 x 104 3.63 1-133 2.76 3.65 x 10' 0.15 Cs-134 0.34 4.46 x 106 0.01 Cs-137 0.5 6.67 x 10-6 0.02 Co-60 0.58 7.69 x 10-6 0.01 No measurable levels of activity were released off-site or to the storm drain. The line was repaired, and a sand and concrete casing was poured around it.

Page 3 of 5

Table 3 Sources of Radioactive Release Unplanned Releases Yankee Nuclear Power Station Rowe, MA Radiation readings on contact A hose developed a pinhole leak, while pumping resin to a 5outh and tast exterior walls or with the resin were 1 mnrad/hi cask. The failure of the hose allowed the release of several NSY-02. The sub-slab area of and the spilled liquid reading gallons of water and one quart of resin. A 15- by 20-foot area NSY-02 (IX-pit) was also were up to several hundred Df the RCA yard was contaminated. Decontamination impacted due to transfer of thousand dpm/100 cM2 (sic) included removal and disposal of some of the blacktop. contamination by surface water (specific radionuclide data not (Le., water used in available). decontamination and rainwater) into cracks between asphalt and IX Pit walls 5/15/1981 Contamination of Removable radioactivity While positioning the reactor vessel head over the equipment 81-09 NOL-1/NOL-6/OOL- BRT-01/in cracks and crevices Yard Area During immediately below the hatch in preparation to lower the head through the equipment 12/OOL-13 and 00L-1 under VC Equipment Hatch Rx Head Removal equipment hatch was 200 hatch, the reactor head made contact with the shield wall. This and along rails/ties in OOL-12 mrad/hr beta. The total resulted in the spread of removable radioactivity outside of the and OOL-13 and the East Storm activity released to the ground Vapor Container (VC). The area was cleaned, but due to Drain System due to surface was approximately 250 mCi, rainfall trace radioactive material levels were detected in the water run-off.

with approximately 10mCi east storm drains.

(specific radionuclide data not available) discharged to Sherman Pond.

9/10/1984 Drain Pipe Failure Soil samples from around the An excavated drainpipe from the Potentially Contaminated 84-16 WST-1/WST-2 and WST-3 WST-02 at a depth in excess of 9 pipe identified the presence of Area (PCA) storage building to the Waste Disposal building feet below grade, activity Co-60 and Cs-137 and the was found to be leaking. The pipe from the edge of the old remains potentially in excess of excavation of the pipe PCA building to the edge of the waste disposal building and the soil DCGL. WST-03 at ash 3

continued. The area of approximately 420 ft of dirt and rock were removed as dewatering sump in drumming maximum contamination was radioactive waste. The soil remaining at the bottom of the pit. Decommissioning measured at 25-35 mR/hr excavation contained Co-60 at an average concentration of 30 standards had not yet been (specific radionuclide data not pCi/gm. developed at the time this available), with a hot spot of partial remediation was 29,300 pCi/gm Co-60 in this performed. Radiological decay same area. since 1984 may have reduced the radionuclide concentration below the soil DCGL. Further scoping data will be collected below the 9 foot clean backfill to confirm this evaluated rnnditinn Page 4 of 5

Table 3 Sources of Radioactive Release Unplanned Releases Yankee Nuclear Power Station Rowe, MA Leakage trom a..,-uter sampie trom me Ln reDruary 1/ ana vs, iY, a mueicnute aewatermg une ana Frozen Fuel Chute Fuel chute line indicated 1,000 a neutron shield tank telltale drain line ruptured due to Dewatering Line net cpm, and a sample from freezing. The ground below the rupture, as well as the area the NST telltale line indicated adjacent to the railroad tracks and pumpback house, showed the presence of Co-60 and Cs- no contamination. However, the snow pile along the south 137. side of the rails by the new fuel vault indicated the presence of Co-60, Cs-137, and Mn-54. All snow piles with positive radiation measurements were sent to the rad drains and the I A 2/23/1994 NST Tell-Tales/Fuel A 3.5-liter sample from the On February 17 and 18,1994, a fuel chute dewatering line and 94-09 NOL-1 Chute Dewatering fuel chute line indicated 1,000 a neutron shield tank telltale drain line ruptured due to Line net cpm, and a sample from freezing. The ground below the rupture, as well as the area the NST telltale line indicated adjacent to the railroad tracks and pumpback house, showed the presence of Co-60 and Cs- no contamination. However, the snow pile along the south 137. side of the rails by the new fuel vault indicated the presence of Co-60, Cs-137, and Mn-54. All snow piles with positive radiation measurements were sent to the rad drains and the areas de-posted.

Page 5 of 5

- - - - - - - - - - - - - - m- - -l - m -m Table 4 Summary of Materials/Chemical Usage Yankee Nuclear Power Station Rowe, MA ateri, iystem., 7 701116--  :, ý N, als/Che* i6lljsýge Water treatment room Service Building Clay Separan (coagulant)

Soda Ash (caustic hypochloride)

Drain/trench discharged to circulating water system Alum (Aluminum Sulfide)

Resin Sulfuric Acid Sodium Bicarbonate Sodium Sulfate Trisodium Phosphate Bisodium Phosphate Monosodium Phosphate Ammonia Hydrazine Morpholine Lithium Hydroxide Potassium Dichromate fchromium)

Reactor Rod Refueling Shield tank inside VC Cyanide (early 1960s) Equipment wash-down south decon pad west wall of Turbine (Silver cyanide waste removed from rods)

Building drained to primary drain tank Secondary steam system Condensers - pump room to Hydrazine Feedwater Secondary steam generators - VC Morpholine Condensate Trisodium Phosphate Circulating water system condensers Sherman Pond screen well house to condensers outflow weir AF 501 (thought to be antifoulant)

Water treatment drain/trench and neutralization tank discharged calgon into circulating water system Electrical systems and transformers Plant wide Oil Main transformers located at west end of Turbine Building and PCB Turbine Bldg Cable Tray room Ion exchange Ion Exchange pit. Boron Potassium Dichromate (chromium)

Oil storage Lube room - by water treatment Virgin oils and grease Garage (lubricants)

North wall lower level PAB Waste oil drums next to old SI Tank Page I of 3

Table 4 Summary of Materials/Chemical Usage Yankee Nuclear Power Station Rowe, MA Component cooling All primary systems Potassium chromate (chromium)

Neutron shield tank Drains under component cooling coolers discharged to storm drain Sodium hydroxide (WCB-009) prior to 1966 Septic system North of parking lot (PG&E) Hand cleaning chemicals Middle parking Auxiliary Boilers and building heating Boiler room and all heated (steam) buildings Hydrazine system Trisodium Phosphate Sodium Sulfate Main coolant system Vapor container (VC) Boron Safety injection PAB IX pit Hydrazine Emergency core cooling Designed leakage to waste disposal Lithium Hydroxide Low pressure surge tank Boric acid mix tank Shut down cooling Diesel motors Security diesel generator Lubricating oil (outside of gate house) Diesel fuel oil Emergency diesels-SIDG Building Anti freeze Fire system Diesel-Fire water tank Batteries - lead, sulfuric acid FTE - SDG by TK-39 Ethylene glycol Pumps, motors, motor operated valves All areas Lubricating oil Fuel oil Hydraulic oils Grease Hazardous waste storage areas Old PCA Building PCB East end of Stores warehouse Oil West end of Stores warehouse Lead Turbine Bldg/Lube Oil Room Mercury (instruments)

Paint Lght bulbs Rad-waste drain system Floor drain from VC, PAB, SFP, waste disposal, old PCA storage Chemlab waste SIDG building, North & South Decon Room (N+SDR) drains, Personnel decon water control point, Primary and Secondary chemistry labs.

Rad-waste. tanks and pumps outside (south) of control point Reactor component decon water Waste disposal evaporator Waste disposal building Inflows of rad-waste drain system Page 2 of 3

Table 4 Summary of MaterialsiChemical Usage Yankee Nuclear Power Station Rowe, MA Rid-waste evaporator skid Evaporator trailer and 20,000 gal tank Antifoam Primary drain effluent (FTE, Chemlab, Control point, Decon sink)

Freon (in chiller)

Ethylene glycol Propylene glycol Turbine/generator Turbine Hall - Turbine building Hydrogen gas (coolant)

Seal oil Lube oil 1,1,1-Trichloroethane (TCA) used to clean centrifuge Kerosene used to clean centrifuge CCl4 - carbon tetra-chloride used to clean centrifuge (early period)

Buildings/Structures Surfaces, Paint & Insulation Asbestos PCB and Lead paint Plant Trash and Waste Incinerators North of SS Bldg Discontinued -1%7 - 1969 Waste Disposal Building Discontinued circa early 1970s Weed Control Power line right of way Herbicides Above Ground Storage Tanks (ASTs) Beside Spent Fuel Building 30,000 Fuel Oil - Closed 2001 Turbine Bldg /Lube Oil Room 6,700 Lube Oil - Closed 1999 Turbine Building 4,500 Lube Oil - Closed 1999 Portable Tank 500 Diesel - Active Visitor Center 330 Fuel Oil - Active Safe Shut-Down Building (2) 275 Fuel Oil - Closed 2004 Security Building (2) 275 Diesel - Active Fire Pump Building 275 Diesel - Closed 2004 Fire Training/Middle Parking Lot 275 Diesel - Closed Safety Injection/Diesel Generator (SI/DG) Building 275 Diesel - Closed 2001 Underground Storage Tanks (USTs) Safe Shut Down Building area 4,000 Diesel - Closed 1994 East of Turbine Building 2,000 Waste Oil - Closed 1994 East side of Garage 1,000 Gasoline - Closed 1990 Visitor Center 550 Fuel Oil - Closed 2003

_East side Security Building 500 Diesel - Closed 1994 NOTE - Table reprinted from Quality Assurance Project Plan, Site Closure, Yankee Nuclear Power Station, Rowe, MA Gradient Corporation 2003 Page 3 of 3

Table 5 Summary of Common Fission Radionuclides Yankee Nuclear Power Station Rowe, MA Radionuclide Half Life, YEARS 1-133 2.37E-03 La-140 4.60E-03 Y-90 7.31E-03 1-131 2.20E-02 Ba-140 3.49E-02 Cs-136 3.59E-02 Ce-141 8.90E-02 Te-129m 9.21E-02 Nb-95 9.63E-02 Ru-103 1.08E-01 Sr-89 1.38E-01 Sb-124 1.65E-01 Zr-95 1.75E-01 Ce-144 7.79E-01 Cs-134 2.06E+00 Sb-125 2.77E+00 Eu-155 4.96E+00 Eu-154 8.81E+00 Ba-133 1.07E+01 Nb-93m 1.36E+O1 Pm-145 1.77E+01 Sr-90 1.91E+01 Cs-137 3.OOE+01 Sn-121m 5.50E+01 Sm-151 9.01E+01 Tb-158 1.50E+02 Mo-93 3.50E+03 Nb-94 2.03E+04 Tc-99 2.13E+05 Zr-93 1.53E+06 Cs-135 2.30E+06 1-129 1.57E+07 Sm146 1.03E+08 1 of 1

Table 6 Summary of Common Activation Radionuclides Yankee Nuclear Power Station Rowe, MA Radionuclide Half Life, YEARS Cr-51 7.59E-02 Fe-59 1.22E-01 Co-58 1.94E-01 Zn-65 6.68E-01 Ag-110m 6.85E-01 Co-57 7.42E-01 Mn-54 8.56E-01 Na-22 2.60E+00 Fe-55 2.70E+00 Co-60 5.27E+00 H-3 1.24E+01 Eu-152 1.33E+01 Ni-63 9.61E+01 Ag-108m 1.27E+02 C-14 5.73E+03 Ni-59 7.51E+04 CI-36 3.01E+05 Mn-53 3.70E+06 1 of 1

Table 7 Summary of Long-Lived Transuranic Radionuclides Yankee Nuclear Power Station Rowe, MA Radionuclide Half Life, YEARS Pu-241 1.44E-01 Cm-243/244 2.85E+01 Pu-238 8.78E+01 Am-241 4.32E+02 Pu-239/240 2.41E+04 1 of 1

Table 8 Summary of DCGLs for Different Media Types Yankee Nuclear Power Station Rowe, MA Subsurface Partial Soil Building Surface Structures Radionuclide (R9491U1 (dpm/100 cm2)[2] (pCi/g)f3l Analysis H-3 3.50E+02 3.40E+08 1.35E+02 LSC C-14 5.20E+00 1.OOE+07 2.34E+03 LSC Fe-55 2.80E+04 4.OOE+07 LSC Co-60 3.80E+00 1.80E+04 3.45E+03 Gamma Spec.

Ni-63 7.70E+02 3.70E+07 6.16E+04 LSC Sr-90 1.60E+00 1.40E+05 1.39E+01 LSC Nb-94 6.80E+00 2.60E+04 - Gamma Spec.

Tc-99 1.30E+01 1.40E+07 - Gamma Spec.

Ag-108m 6.90E+00 2.50E+04 - Gamma Spec.

Sb-125 3.OOE+01 1.OOE+05 - Gamma Spec.

Cs-134 4.70E+00 2.90E+04 - Gamma Spec.

Cs-137 8.20E-00 6.30E+04 1..45E+03 Gamma Spec.

Eu-152 9.50E+00 3.70E+04 Gamma Spec.

Eu-154 9.OOE+00 3.40E+04 Gamma Spec.

Eu-155 3.80E+02 6:50E+05 Gamma Spec.

Pu-238 3.10E+01 5.70E+03 - Alpha Spec.

Pu-239 2.80E+01 5.10E+03 - Alpha Spec.

Pu-241 .9.30E+02 2.50E+05 - Alpha Spec.

Am-241 2.80E01i 5.OOE+03 - Alpha Spec.

Cm-243 3.OOE+01 7.20E+03 - Alpha Spec.

Notes:

Fi[Represents a dose of 23.73 mrem/yr

[21 -Represents a dose of 25 mrem/yr

[31Represents a dose of 0.5 mrem/yr 1 of 1

Table 9 Summary Statistics of All Detected Soil Analytical Data Identification of Chemicals of Potential Concern (Non-Radiological)

Yankee Nuclear Power Station Rowe, MA 29 1. 81% 2.3. 682.59 11000 Yes 2.2 26.88 680 Yes TPH-DRO 143 186 77% 4.4 4.4 4.4 TPH-GRO 2 62 3%. 4.6 3.79 150 No Less than 5% detected VPH 1 C5-C8 Aliphatics 2 49 4% 5.54 4.22 19.3 No Less than 5% detected EPH Cll-C22 Aromatics 54 179 30% 7.17 24.02 788 Yes C19-C36 Aliphatics 61 179 34% 7.84 29.30 1010 Yes C9-C18 Aliphatics 7 179 4% 9.38 6.20 202 No Less than 5% detected 3 A 50% 22.7 26.32 70.5 Yes Total EPH (ug/c DW)

Volatile Organic Compounds (ug/Kg) 1,1,1,2-Tetrachloroethane 1 178 1% 2.7 13.62 2.7 No Less than 5% detected 1,1,1-Trichloroethane 2 178 1% 6.5 15.40 88 No Less than 5% detected 1,2-Dichloroethane 178 1% 9.3 13.60 9.3 No Less than 5% detected 2-Butanone 40 178 22% 1.4 60.05 1400 Yes 4-isopropyltoluene 3 178 2% 3.1 14.07 73 No Less than 5% detected.

4-Methyl-2-pentanone 1 178 1% 4.1 25.77 4.1 No Less than 5% detected Acetone 52 178 29% 3.7 145.64 980 Yes Benzene 1 178 1% 4.9 13.58 4.9 No Less than 5% detected Carbon disulfide 7 178 4% 2.7 13.76 9 No Less than 5%.detected Carbon tetrachloride 1 178 1% 6.5 15.04 6.5 No Less than 5% detected Chloroform 178 1% 6.3 16.49 6.3 No Less than 5% detected Diethyl Ether 1 174 9% 3.2 30.71 79 Yes Ethylbenzene 1 178 1% 4.4 13.58 4.4 No Less than 5% detected lsopropylbenzene 178 1% 2.4 13.62 2.4 No Less than 5% detected m+p-Xylenes 3 178 2% 1.8 13.56 2.8 No Less than 5% detected Methylene chloride 26 178 15% 4.2 33.10 420 Yes Methyl-t-butyl ether 1 178 1% 12 16.64 12 No Less than 5% detected n-Butylbenzene 1 178 1% 35 13.80 35 No Less than 5% detected o-Xylene 1 178 1% 1.8 13.56 1.8 No Less than 5% detected Tetrachloroethene 2 178 1% 4.3 14.73 230 No Less than 5% detected Toluene 59 178 33% 1.5 14.94 27 Yes Trichlorofluoromethane 8 178 4% 2 49.88 5.6 No Less than 5% detected Page 1 of 3

Table 9 Summary Statistics of All Detected' Soil Analytical Data.

Identification of Chemicals of Potential' Concern (Non-Radiological)ý Yankee Nuclear Power Station Rowe, MA Semi-Volatile OrganicCompc 2,4-Dimethylphenol 1 180. 1% 160 215.28 160 ND NIJý ND No Less than 5% detected 2-Methylnaphthalene 4 180 2% 100 301.53 12000 500 ND ND ND Yes Less than 5% detected, 3+4-Methylphenol 3 180 2% 81. 209.63 340 below MADEP Bkgd ND ND ND No Acenaphthene 10 180 6% 80 371.27 13000 500 ND ND ND Yes Acenaphthylene 13 180 7% 110 273.81 5100 500 ND ND ND Yes Anthracene 26 180 14% 74- ND 591.74 25000 1000 ND ND Yes Benzo(a)anthracene 42 182 23% 76 854.41 2()000 2000 ND ND ND Yes Benzo(a)pyrene 39 182 21% 74 584.38 16000 2000 ND ND ND 410%' 100 30.5 1200ND ND D8es Yes Benzo(b)fluoranthene 37 180 21% 80 854.38 34000 2000 ND ND ND Yes Benzo(g,h,i)perylene 31 180 17% 94 410.11 13000 1000. ND ND ND Yes Benzo(k)fluoranthene 34 180 19% 81 665.79 19000 1000 ND ND ND Yes Benzoic acid 2 180 1% 240W 1058.06 3500 3500 1457.14 3500 No Less than 5% detected bis(2-Ethylhexyl)phthalate 12 180 7% 74 224.63 780 ND ND ND Yes Butyl benzyl phthalate 1 180 1% 500 211.67 500 ND ND ND No Less than 5% detected Carbazole 10 154 6% 87 263.97 5100 ND ND ND Yes Chrvsene 20100 41 180 23% 85 106824 360010 NDI ND NDl Yes.

Dibenzo(a,h)anthracene 17 180 9% 73' 272.86 3800 500 ND ND ND Yes Dibenzofuran 8 180 4% 85 369.47 11000 ND ND ND No Less than 5% detected Di-n-butyl phthalate 3 180 2% 74 208.23 84 ND ND ND No Less than 5% detected Fluoranthene 59 180 33% 72 2595.58 110000 4000 ND ND ND Yes Fluorene 13 180 7% 83 449.63 16000 1000 ND ND ND Yes lndeno(1,2,3-cd)pyrene 27 180 15% 100 488.08 16000 1000 ND ND ND Yes Naphthalene 4 180 2% 220 381.64 27000 500 ND ND ND Yes Phenanthrene 33 180 18% 80 1241.46 75000 3000 ND ND ND Yes Pyrene 52 180 29% 70 1844.31 86000 4000 ND ND ND Yes PolychlorinatedBiplhenyls (ug/Kg)

Aroclor-1254 237 468 1 51% 5.7 5117.34 480000 ' Yes Aroclor-1260 37 468 8% 15. 158.23 4400 Yes Page 2 of 3

Table 9 Summary Statistics of All Detected Soil, Analytical Data Identification of Chemicals of Potential Concern (Non-Radiological)

Yankee Nuclear, Power Station Rowe, MA 1 1 100% 24000 24000 24000 10OO0 Yes:

Antimony 5 113 4% 2.38 24 1 No Less than 5% detected 9556 Arsenic 347 491 71% 0.66 2.16 27 20 0.7 Yes 1%

0.79 3.2 Barium 191 191 100% 14 67.55 670 50 Yes Beryllium 3. 323 1% 0.5 0.38 2 0.4 No ND ND ND Less than 5% detected Boron 5 9 56% 18 106.33 520 Yes 18 18.50 19 Cadmium 5 485 1% 0.3 0.77 7.2 2 No ND 0.54 Less than 5% detected-Chromium 491 491 100% 1 13.95 490. 30 Yes 6.3 16.01 34 Copper 281 308 91% 1.8 15.50 350 40 2.3 Yes 5.07 19 Iron 8 8 100% 1100 13725 19300 20000 No Below MADEP Bkgd Concentration Lead 551 555 99% 0.43 129.67 18200 100 Yes 0.97 8.84 57 Lithium 8 8 100% 12 17 26 23 24.50 26 Yes Magnesium 1 1 100% 830 830 830 5000 No Below MADEP Bkgd Concentration Manganese 8 8 100%/ 107 458.50 2300 300 Yes Mercury 68 483 14% 0.006 0,20 2.6 0.3 Yes ND ND ND Molybdenum 1 1 100% 8.6 8.60 8.6 Yes Nickel 267 301 89% 3.5 13.54 230 20 3.8 11.67 29 Yes Selenium 52 484 11%. 4.2 3.43 16 0.5 ND ND Yes ND Silver 7 481 1% 0.81 0.29 3 0.6 ND No ND ND Less than 5% detected Thallium 3 301 1% 0.6 1.01 0.82 0.6 0.73 *0.43 0.73 No Less than 5% detected Vanadium 1 1 100% 1.8 1.80 1.8 30 No Below MADEP Bkgd Concentration Zinc 214 308 69% 20 72.71 1200 100 36 56.78 77 Yes 301 308 I 69%

1%

100% 0.6 1.8 20 72.71 1.01 1.80 1200 0.82 1.8 100 0.6 30 Yes No Dioxin/Furan(pg/g) 1,2,3,4,5,6,7,8-OCDD 22 25 88% 0.62 43.88 320 21 11.68 . 21 Yes 1,2,3,4,5,6,7,8-OCDF 20 25 80% 0.36 39.99 820 1.7 0.93 1.7 Yes 1,2,3,4,6,7,8-HpCDD 18 25 72% 0.55 6.44 43 3.8 2.38 3.8 Yes.

1,2,3,4,6,7,8-HpCDF 22 25 88% 0.09 6.91 95 0.3 0.7 1.1 Yes 1,2,3,4,7,8,9-HpCDF 15 25 60% 0.16 3.39 71 ND ND ND Yes 1,2,3,4,7,8-HxCDD 10 25 40% 0.21 0.19 0.56 0.23 0.16 0.23 Yes 1,2,3,4,7,8-HxCDF 20 25 80% 0.07 4.97 100 0.29 0.43 0.57 Yes 1,2,3,6,7,8-HxCDD 11 25 44% 0.3 0.37 2.2 0.3 0.20 0.3 Yes 1,2,3,6,7,8-HxCDF 17 25 68% 0.13 0.64 6.3 0.21 0.12 0.21 Yes 1,2,3,7,8,9-HxCDD 11 25 44% 0.26 0.37 1.7 0.35 0.22 0.35 Yes 1,2,3,7,8,9-HxCDF 4 25 16% 0.14 0.08 0.26 ND ND ND Yes 1,2,3,7,8-PeCDD 4 25 16% 0.18 0.14 0.74 ND ND ND Yes 1,2,3,7,8-PeCDF 11 25 44% 0.2 0.39 3.1 0.22 0.15 0.22 Yes 2,3,4,6,7,8-HxCDF 15 25 60% 0.12 0.42 2.4 0.28 0.16 0.28 Yes 2,3,4,7,8-PeCDF 16 25 64% 0.12 0.83 12 0.14 0.26 0.38 Yes 2,3,7,8-TCDD 5 25 20% 0.32 0.39 4.2 ND ND ND Yes 2,3,7,8-TCDF 10 25 40% 0.27 0.60 3.1 ND ND ND Yes Notes Averages represent the mean of those detected and 1/2 the detection limit of those not detected Summary Statistics only include detections Blanks - Not Analyzed MADEP Bkgd = Massachusetts Department of Environmental Protection Background Concentrations (MADEP, 2002)

Page 3 of 3

m - - m m- - - n-- m - m-- -

Table 10 Summary Statistics of All Detected Sediment Analytical Data - Sherman Reservoir Identification of Chemicals of Potential Concern (Non-Radiological)

Yankee Nuclear Power Station Rowe, MA I Maximum detect located at least TPH-DRO (Diesel Range) 38 49  % 2. 39 5 19 S 801751 No 17W fee:fo sho~reline and l l I I l l "r ... . .... ...

Volatile Orranic Com ounds(ug/Kr) 1,1-Dichloroethene 14 22 64% 3.5 12.89 40 15 17.58 T 24 Yes 12,4-Trimethylbanzene 1 22 5% 4.2 3.15 4.2 ND ND ND Yes 2-Butanone 16 22 73% 26 27.70 140 11 28.75 67 Yes 4.Methyl-2-Pestanone 2 22 9% 2.8 3.11 3.2 ND ND ND Yes Acetone 17 22 77% 3 96.5S 280 42 117.92 280 Yes Carbon Disulfide 3 22 14% 5.2 3.54 8.8 ND ND ND Yes Toluene 13 22 59% 11 16.74 52 12 20.83 31 Yes Semi. Volatile OrganicCopntutds (toglKg)___

2-Methylphenol 1 22 4.5% 150 287.5 150 150 330.83 150 No Less than 5% detected 3.4-Methylphenol 1 22 4.5% 230 285.23 230 230 322.5 230 No Less than 5% detected Acesaphthene 1 22 4.5% 160 293.18 160 ND ND ND Yes Anthracene 1 22 5% 240 296.82 240 ND ND ND Yes Benzo(a)anthracene 4 22 18% 130 271.14 320 180 267.5 200 Yes Benzo(a)pyrene 2 22 9% 230 286.82 270 230 31&.67 230 Yes Benzo(b)fluoranthene 1 22 5% 220 283.18 220 220 315 220 Yes Benzo(glh,i)perylese 1 22 5% 120 291.36 120 ND ND ND Yes Benzo(k)fluoranthene 1 22 5% 220 283.18 220 220 315 220 Yes Bis(2-ethylhexyl)phthalate 2 22 9% 140 288.86 140 ND ND ND Yes Chrysene 5 22 23% 120 262-05 290 170 240.83 230 Yes Dibenzofuran 1 22 5% 120 291.36 120 ND ND ND No Less than 5% detected Di-n-octyl phthalate 1 22 5% 320 299.77 320 ND ND ND No Less than 5% detected Fluoranthese 11 22 50% 120 277.5 7W0 170 321.67 430 Yes Fluorene 1 22 5% 180 294.09 180 ND ND ND Yes lndesso(1,2,3-cd)pyrene 1 22 5% 110 290.91 110 ND ND ND Yes Phenanthrene 2 22 9% 140 316.14 740 140 345.83 140 Yes Pyrene 9 22 41% 120 266.14 520 130 290 380 Yes SPolyrltlorinoledBiphenyls (ag/K)

A iroclor1254 107 195 [55% 1 18 4257.76 550000 1 ND ND ND Yes lnorganics(mg/g __ ____

Antimony 2 16 13% 1.7 " 0.59 3.9 ND ND ND Yes Arsenic 35 51 69% 0.7 1.33 4.8 1.6 1.6 2.8 Yes Barium 5 5 100% 35 93.2 180 ND ND ND *Yes Beryllium 3 48 6% 0.2 0.73 0.3 ND ND ND Yes Cadmium 3 50 6% 0.5 0.85 6.7 ND ND ND Yes Chronium 55 55 100% 2.6 14.93 34 4.5 14.55 .21 Yes Copper 52 53 98% 6.4 47.28 570 6.4 31.1 45 Yes Lead 64 67 96% 0.51 12.84 75 0.65 2.8 5.2 Yes Lithium 3 3 100% 12 16.33 23 ND ND ND Yes Mercury 4 50 8% 0.1 0.29 2.1 ND ND ND Yes Nickel 53 53 100% 5 17.97 55 11 19.8. 28 Yes Selenium 7 49 14% 2.9 2.45 6.4 3.9 3.02 4.9 Yes Less than 5% detected, does not Silver 2 s0 4% 0.3 0.24 0.4 0.4 0.3 0.4 No exceed local conditions Thallium 1 48 2% 1.7 0.45 1.7 ND ND ND No Less than 5% detected Zinc 52 53 98% 30 131.82 790 49 178.2 270 Yes Notes Averages represent the mean of those detected and 1/2 the detection limit of those not detected Summary Statistics only include detections Summary Statistics subject to change with the inclusion of newly validated data Pagel of I

Table 11 Summary Statistics of All Detected Sediment Analytical Data - Deerfield River Identification of Chemicals of Potential Concern (Non-Radiological)

Yankee Nuclear Power Station Rowe, MA Volatile Organic Compounds (ug/Kg) 2-Butanone . 1 1 14% 12 6.29 12 11 28.75 67 Yes 4-Isopropyltoluene. 1 7 14% 2 2.5 2 ND ND ND Yes Acetone 1 7 14% 76 22 76 .42 117.92 280 Yes Chloromethane 1 7 14% 1.2 2.11 1.2 ND ND ND Yes Semi-Volatile OrganicCompounds (ug/Kg)

Benzo(a)anthracene 1 7 14% 330 226.43 330 180 267.5 200 Yes Benzo(a)pyrene 3 7 43% 83 185.43 320 230 316.67 230 Yes Benzo(b)fluoranthene 3 7 43% 79 184.86 310 220 315 220 Yes Benzo(g,~i)perylene 1 7 14% 210 209.29 210 ND ND ND Yes Benzo(k)fluoranthene 2 7 29% 78 209 330 220 315 220 Yes Bis(2-ethylhexyl)phthalate 1 7 14% 120 196.43 120 ND ND ND Yes Chrysene 3 7 43% 90 195 380 170 240.83 230 Yes Fluoranthene 3 7 43% 150 256A3 670 170 321.67 430 Yes lndeno(1,2,3-cd)pyrene 1 7 14% 200 207.86 200 ND ND ND Yes Phenanthrene 2 7 29% 80 210.71 340 140 345.83 140 Yes Pyrene. . I 3 7 43% 120 229.29 540 130 290 380 Yes PolychlorinatedBiphenyls (ug/Kg)

Aroclor-1254 116 125 64%l 15113-2.5-61820 [.ND rNDl NDT Yes T Aroclor-1260 3 25 12% 180 41.25 200 ND ND ND Yes Inorganics (m*g/K)

Arsenic 5 7 71% 0.52 1.03 2.5 1.6 1.63 2.8 No Below local conditions Chromium 7 7 100% 6.6 10.11 17 4.5 14.55 21 No Below local conditions Copper 7 7. 100% 7.6 37.19 150 6.4 31.07 45 Yes Lead 7 7 100% 1 5.64 13 0.65 2.81 5.2 Yes Nickel . 7 7 100% 8.8. 11.64 17 11 19.83 28 No Below local conditions Selenium 2 7 29% 2.8 1.85 3.5 3.9 3.02 4.9 No Below local conditions Zinc 7 7 100%. 29 71.29 210 49 178.17 270 No Below local conditions Notes Averages represent the mean of those detected and 1/2 the detection limit of those not detected Summary Statistics only include detections Summary Statistics subject to change with the inclusion of newly validated data Page I of 1

Table 12 Summary Statistics of All Detected Sediment Analytical Data - Wheeler Brook Identification of Chemicals of Potential Concern (Non-Radiological)

Yankee Nuclear Power Station Rowe, MA i orai o'erroleum -iyarocarvon(mg/rmg)

TPH-DRO 1 4 1 6 1 "67% 1 2.9 1 10.33 1 45 1 19 1 31.75 1 80 No Below local conditions Volatile Organic Compounds (ug/Kg) 1,1-Dichloroethene 1 5 120% 1 3.3 12.66 3.3 1 15 1 17.8 2 Yes 2-Butanone 2 5 40% 2.4 6.28 14 11 28.75 67 Yes Acetone 2 6 33% 18 42 90 42 117.92 280 Yes Inorganics (mg/Kg)

Barium 6 6 100% 24 44.67 76 ND ND ND Yes Chromium 12 12 100% 5 7.52 10 4.5 14.55 21 No Below local conditions Lead 8 11 73% 0.44 2.58 5.9 0.65 2.8 5.2 Yes Mercury 1 11 9% 0.046 0.10 0.046 ND ND ND Yes Nickel .5 6 83% 5.6 6.66 12 11 19.8 28 No Below local conditions Notes Averages represent the mean of those detected and 1/2 the detection limit of those not detected Summary Statistics only include detections Summary Statistics subject to change with the inclusion of newly validated data Page 1 of 1

Table 13 Summary Statistics of All Detected Sediment Analytical Data - Storm System Identification of Chemicals of Potential Concern (Non-Radiological)

Yankee Nuclear Power Station Rowe, MA ND Yes 17.17 3 500 1901 .75N 80 No F TPH-DRO 16 33% 165000 21667.33 6500 1 I ND Volatile OrganicCompounds (ug/Kg)

Methylene chloride 1,1-Dichloroethene 1 8 13%

25% 1.1 11 23.58 14.63 1.1 21 ND 15 ND 17.58 ND 24 Ye Yes Semi-Volatile OrganicCompounds (ug/Kg) 2-Methylnaphthalene 1 14 7% 280 195.01 280 ND ND ND Yes Acenaphthene 3 14 21% 98 . 291.65 1800 ND ND ND Yes Anthracene 4 14 29% 120 322.15 2200 ND ND ND Yes Benzo(a)anthracene 8 14 57% 130 681.80 6600 180 267.5 200 Yes Benzo(a)pyrene 8 14 57% 100 624.65 5800 230 316.67 230 Yes Benzo(b)fluoranthene. 6 14 43% 130 601.08 5600 220 315 220 Yes Benzo(g,h,i)perylene 6 14 43% 100 386.80 2900 ND ND ND Yes Benzo(k)fluoranthene 6 14 43% 130 525.37 4600 220 315 220 Yes Benzoic acid 1 14 7% 130 855.77 130 ND ND ND Yes bis(2-Ethylhexyl)phthalate 6 14 43% 86 169.37 200 ND ND ND Yes Carbazole 1 13 8% 2200 357.69 2200 ND ND ND Yes Chrysene 8 14 57% 140 660.37 6200 170 240.83 230 Yes Dibenzo(a,h)anthracene 1 14 7% 770 230.01 770 ND ND ND Yes Dibenzofuran 1 14 7% 1300 267.87 1300 ND ND ND Yes Fluoranthene 10 14 71% 100 1384.65 14000 170 321.67 430 Yes Fluorene 2 14 14% 100 303.58 1900 ND ND ND Yes Indeno(1,Z3-cd)pyrene 6 14 43% 93 377.01 2900 ND ND ND Yes Naphthalene 1 14 7% 470 208.58 470 ND ND ND Yes Phenanthrene 8 14 57% 210 1211.80 13000 140 345.83 140 Yes Pyrene 8.8 14 57% 240 1028.23 9900 130 290 380 Yes PolychlorinatedBiphenyls (ug/Kg)

Aroclor-1254 57 80 71% 14 905.33 9200 ND ND ND Yes Aroclor-1260 2 80 3% 1200 131.58 4800 ND ND ND No E Page 1 of 2

Table 13 Summary Statistics of All Detected Sediment Analytical Data - Storm System Identification of Chemicals of Potential Concern (Non-Radiological)

Yankee Nuclear Power Station Rowe, MA Antimony 10 17 59% .1 1.84 4.7 ND ND ND Yes Arsenic 19 22 86% 1.4 5.97 17.4 1.6 1.6 2.8 Yes Barium 16 16 100% 18 1575.44 3800 ND ND ND Yes Beryllium 1 17ý 6% 0.3 2-28 0.3 ND ND ND Yes Cadmium 15 22 68% 1.2 38.90 130 ND ND ND Yes Chromium 15 22 68% 4.2 16.35 94 4.5 14.55 21 Yes Copper 17 17 100% 16 457.22 2040 6.4 31.1 45 Yes Lead 34 34 100% 0.58 43.69 190 0.65 28 5.2 Yes Mercury 14 22 64% 0.12 0.78 4.7 ND ND ND Yes Nickel 17 17 100% 5.3 202.35 539 11 19.8 28 Yes Selenium 3 22 14% 44 12.25 140 3.9 3.02 4.9 Yes Silver 4 22 18% 1.4 7.03 36 0.4 0.3 0.4 Yes Thallium 8 17 47% 3.6 3.91 12-8 ND ND ND Yes Zinc 17 17 100% 59 2488.82 7270 49 178.2 270 Yes Notes Averages represent the mean of those detected and 1/2 the detection limit of those not detected Summary Statistics only include detections Summary Statistics subject to change with the inclusion of newly validated data Page 2 of 2

Table 14 Summary Statistics of Detected Surface Water Analytical Data Identification of Chemicals of Potential Concern (Non-Radiological)

Yankee Nuclear Power Station Rowe, MA V ULULLL IC . . ,U:T*U.,,UfL*L U3 .

Acetone 5 11 45% 3.4 6.15 14 Yes 0.83 2.35 0.83 Yes Carbon disulfide 1 11 9%

36% 0.43 2.09 3.7 Yes Chloromethane 4 11 0.84 0.962 0.95 Yes Methylene chloride 5 11 45%

9% 0.41 2.31 0.41 Yes Toluene 1 11 Inorganics (mg/L)

Barium 16 16 100% 0.015 0.019 0.039 Yes Copper 11 11 100% 0.014 0.021 0.03 Yes Iron 11 11 100% 0.072 2.136 16 Yes Manganese 10 11 91% 0.017 0.164 0.82 Yes Selenium 1 12 8% 0.006 0.023 0.006 Yes Silver 1 11 9% 0.005 0.003 .0.005 Yes Notes Only includes all detected surface water samples Averages represent the mean of those detected and 1/2 the detection limit of those not detected Blanks - No Criterion Page 1 of I

Table 15 Summary Statistics of All Detected Groundwater Analytical Data Identification of Chemicals of Potential Concern (Non*Radiological)

Yankee Nuclear Power Station Rowe, MA i otal Petroleum tiyaroc TPH 1 2 50% 270 135.3 270 Yes TPH-DRO 31 55 56% 32 83:8 720 Yes TPH-GRO 3 52 6% 15 6.1 43 Yes VPH C5-C8 Aliphatics 17 74 23% 32.19 255.52 3470 Yes C9-CIO Aromatics 29 84 35% 23.9 48.10 117 Yes C9-C12 Aliphatics 2 49 4% 45.8 51.06 76.3 No Less than 5% detected EPH C1l-C22 Aromatics 27 73 37% 36 62.46 408 Yes C19-C36 Aliphatics 14 67 21% 73 76.03 555 Yes C9-C18 Aliphatics 2 65 3% 61 45.77 63 No Less than 5% detected m J .5. . a. -. & - I . .5.

Volatile Organic Compoinds (ug/L) 1,1-Dichloroethane 14 226 6% 0.49 2.79 4.9 Yes 1,1-Dichloroethene 5 226 2% 0.86 2.08 1.7 No Less than 5% detected 1,2,4-Trimethylbenzene 3 226 1% 1.8 3.89 8.8 No Less than 5% detected 1,3,5-Trimethylbenzene 3 226 1% 0.71 3.85 2.9 No Less than 5% detected 2-Butanone 1 226 0.4% 26 7.90 26 No Less than 5% detected 4-Isopropyltoluene 3 204 1% 0.33 2.47 1.1 No Less than 5% detected 4-Methyl-2-pentanone 2 226 1% 0.82 5.63 5 No Less than 5% detected Acetone 37 225 16% 3 297.43 14000 Yes Benzene 1 226 0.4% 1.5 1.87 1.5 No Less than 5% detected Carbon disulfide 17 226 8% 0.28 6.70 78 Yes Chloroform 9 226 4% 0.49 2.05 2 No Less than 5% detected Clhloromethane 11 226 5% 0.36 3.91 2.3 No Less than 5% detected Dichlorodifluoromethane 4 226 2% 0.62 5.42 3 No Less than 5% detected Ethylbenzene 3 226 1% 0.5 2.59 2.4 No Less than 5% detected lodomethane 1 216 0.5% 1.2 4.89 1.2 No Less than 5% detected Isopropylbenzene 1 226 0.4% 0.74 2.68 0.74 No Less than 5% detected m+p-Xylenes 5 226 2% 2.6 2.82 25 No Less than 5% detected Methylene chloride 3 226 1% 0.57 4.84 15 No Less than 5% detected Methyl-t-butyl ether 46 226 20% 0.68 8.68 140 Yes n-Butylbenzene 1 226 0% 0.71 2.68 0.71 No Less than 5% detected n-Propylbenzene 2 226 1% 0.58 2.67 1.4 No Less than 5% detected Page 1 of 3

Table 15 Summary Statistics of All Detected Groundwater Analytical Data Identification of Chemicals of Potential Concern (Non-Radiological)

Yankee Nuclear Power Station Rowe, MA U-Aylelte Less a 5% etuetu Tetrachloroethene Tetrahydrofuran 14 1

1 226 204

.0.4%

0.5%

1-I 0.21 69 1.87 11.31 0.21 69

• No No Less than 5% detected Less than 5% detected Toluene 226 6% 0.2 2.78 8.7 Yes Semi-Volatile OrganicCompounds (ug/L) 3+4-Methylphenol 1 109 1% .43 4.99 43 No Less than 5% detected Acenaphthene 4 123 3% 0.06 2.08 0.16 No Less than 5% detected Acenaphthylene 3 123, 2% 0.1 2.07 0.38 No Less than 5% detected Anthracene 5 123 4% 0.1 2.07 0.27 No Less than 5% detected Benzidine 3 120 3% 2.1 9.46 3.7 No Less than 5% detected Benzo(a)anthracene 2 123 2% 0.15 2.06 0.23 No Less than 5% detected Benzo(a)pyrene 1 123 1% 0.13 2.06 0.13 No Less than 5% detected Benzo(b)fluoranthene 2 123 2% 0.16 2.06 0.16 No Less than 5% detected Benzo(bfui)perytene 2 123 2% 0.13 2.07 0.2 No Less than 5% detected Benzo(k)fluoranthene 1 123 1% 0.26 2.06 0.26 No Less than 5% detected bs(2-Ethynhexyl)phenate 15 120 13% 26 5.81 86 Yes Chrysene 2 123 2% 0.15 207 0.32 No Less than 5%detected Dibenzo(ah)antheacene 2 123 2% 0.11 2.06 0.27 No Less than 5% detected Diethyn phthalate 3 120 3% 3.5 4.76 16 No Less than 5% detected Fluoranthene 8 123 7% 0.1 20.6 0.22 Yes Fluorene 4 123 3% 0.06 2.09 1 No Less than 5%detected lndeno(1,e3-cd)pyrene 2 123 2% 0.12 2.06 0.24 No Less than 5% detected Naphthalene 15 123 12% 0.06 2.08 0.51 Yes Pentachiorophenol 5 122 4% 2.1 10.31 14 No Less than 5%detected Phenanthrene 9 123 7% 0.1 2.07 0.18 Yes Phenol 2 109 2% 2.2 4.61 5.7 No Less than 5% detected Prene 8 123 7% 0.1 42.08 50.3 1 Yes Lssthan_%detcte PolychorinatedBiphenyls (ug/L)

Aroclor-1254 59 267 22% 0.25 1.00 69 Yes Aroclor-1260 12 266 5% 0.25 0.16 0.25 No Less than 5% detected Page 2 of 3

Table 15 Summary Statistics of All Detected Groundwater Analytical Data Identification of Chemicals of Potential Concern (Non-Radiological)

Yankee Nuclear Power Station Rowe, MA Non-Filtered Antimony 1 74 1% 0.0063 0.003 0.0063 No Less than 5% detected Arsenic 4 139 3% 0.019 0.005 0.068 No Less than 5% detected Barium 69 84 82% 0.011 0.089 0.93 Yes Boron 57 164 35% 0.067 0.12 1.9 Yes Cadmium 5 138 4% 0.003 0.002 0.0085 No Less than 5% detected Chromium 17 161 11% 0.0054 0.007 0.088 Yes Copper 22 96 23% 0.0034 0.007 0.036 Yes Iron 19 19 100% 0.084 68.5 300 Yes Lead 41 165 25% 0.0034 0.005 0.11 Yes Manganese 19 19 100% 0.047 5.9 11 Yes Mercury 1 161 1% 0.0003 0.0001 0.0003 No Less than 5% detected Nickel 20 96 21% 0.0031 0.007 0.053 Yes Selenium 3 138 2% 0.0052 0.018 0.05 No Less than 5% detected Silver 1 144- 1% 0.009 0.002 0.009 No Less than 5% detected Zinc 4 74 5% 0.12 0.039 0.83 Yes Alcohols (mg/L) iso-Propyl Alcohol 1 2 1 7 1 29% 1 140 1 40.7 1 140 1 Yes I Filtered 1 25% i 0.38 1 0.48 I 2.9 I Yes Notes Averages represent the mean of those detected and 1/2 the detection limit of those not detected Summary Statistics only include detections Summary Statistics subject to change with the inclusion of newly validated data Page 3 of 3

Table 16 Summary of Radiological & Non-Radiological COCs Yankee Nuclear Power Station Rowe, MA H-13 Total Petroleum Hydrocarbons Semi-Volatile OrganicCompounds [norganics Dioxin/Furan, TPH 2-Methylnaphthalene Aluminum 1,2.3;4,5,6,7,18-OCDD, C-14 TIPH-DRO Acenaphthene Arsenic 1,Z3,4,5,6,7,8-OCDF Fe-55 VPH Acenaphthylene Antimony 1,,3A,6,7,81-HpCDD Co-60 CS-C8 Aliphatics Anthracene Barium 1,2,3,4,6,7,8-H-pCDF Ni-63.

C9-C1O Aromatics Benzo(a)anthracene Beryllium 1,2,3A,478,9-HpCDF Sr-90 EPH Benzo(a)pyrene.., Boron 1,2,3,4,7,8-HxCDD Nb-94 C1-C22 Aromatics Benzo(b)fluoranthene Zadmium 1,2,3,4,7,8-HxCDF TC-99 Ag-108rm C19-C36 Aliphatics Benzo(g&h,i)perylene Calcium 1,.2,3,6,7,&-HxCDD Benzo(k)fluoranthene -hromium 1,2,3,6,7,8-1-xCDF Sb-125 Cs-134 Volatile Organic Compounds bis(2-Ethylhexyl)phthalate Zopper 2,Z3,7,8,9-HxCDD 2-Butanone Carbazole [ron 1,23,7,8,9-HxCDF Cs-137 Acetone Chrysene Lead 1,Z3,7,8-PeCDD Eu-152 Carbon Disulfide. Dibenzo(a,h)anthracene Lithium 1,Z3,7,8-PeCDF Eu-154 Chloromethane Fluoranthene Manganese Z3,4.6,7,8-HxCDF Eu-155 Diethyl Ether Fluorene Mercury Z3,4,7,B-PeCDF Pu-238 1,1-Dichloroethene [ndeno(1,2,3-cd)pyrene Molybdenum Z3,7,8-TCDD Pu-239 4-Isopropyltoluene lsodrin Nickel 2,3,7,8-TCDF Pu-241 Am-241 11,2,4-Trirnethylbenzene Isophorone Potassium Polychlorinated Biphenyls Methylene chloride Methyl Methanesulfonate 3elenium Aroclor-1254 Cm-243 Methyl-t-butyl ether Naphthalene 'hallium Aroclor-1260 4-Methyl-2-Pentanone Phenanthrene zinc Toluene Pyrene 1 of 1

Table 17 Summary of Floor and Total Area of Buildings and Features Yankee Nuclear Power Station Rowe, MA SURVEY AREA DESCRIPTION MARSSIM FLOOR AREA TOTAL AREA RATIO (total 2

CLASS (mW) (W ) floor)

SVC-01 NORTH PART OF SERVICE BLDG (CLEAN SIDE) 3 921 921 1 SVC-02 RAD PORTIONS OFSERVICE BLDG AND ANNEX 1 444 444 1 SVC-03 CLEAN SIDE OF SERVICE BLDG ANNEX 3 366 366 1 TBN-01 TURBINE BLDG AND OFFICE PADS 3 1517 1517 1 SPF-O SPENT FUEL POOL AND TRANSFER CHUTE 1 60 302 5.03 SPF-02 NEW FUEL VAULT 1 95 141 1.48 BRT-01 CONCRETE PEDESTALS 1 NSY-OI NORTH AND SOUTH DECON PADS AND FTE 1 224 224 1 NSY-02 IX-PIT 1 NSY-03 SI DIESEUACCUMULATOR TANK/BATTERY ROOM 1 380 482 1.12 NSY-04 SAFE SHUTDOWN 1 103 120 1.16 NSY-05 FIRE WATER TANK AND PUMP HOUSE 1 184 184 1 NSY-06 PCA#2 (NEW) 1 219 219 1 NSY-07 WHT / ADT / WASTE GAS PADS 1 390 390 1 NSY-08 NEW SI TANK . 1 880 0 1 NSY-09 ELEVATOR SHAFT 1 6 21 4.5 NSY-10 ISFSI 3 985 1078 1.09 NSY-11 CHEM WASTEPIT 1 17 78 4.5 NSY-12 TANK #1 BASE 1 31 31 1 NSY-13 TANK #39 BASE 1 70 70- 1 WST-01 PCA #1 (OLD) 1 109 109 1 WST-02 PCA WAREHOUSE 1 604 604 WST-03 WASTE DISPOSAL BLDG 1 230 WST-04 COMPCTOR BLDG 1 AUX-01 P AB/EAST END 1 AUX-02 P AB / WEST END 1 130 189 1.45 OMB-01 PUMPHOUSE AND SCREENWELL 3 230 541 2.35 OMB-02 SECURITY GATEHOUSE AND DIESEL GENERATOR 3 270 868 3.2 OMB-03 ADMINISTRATION BUILDING 3 297 798 2.6 OMB-04 WAREHOUSE AND LOADING DOCK PAD 3 625 625 1 OMB-05 FURLON HOUSE 3 432 OMB-06 SEAL PIT 3 120 1 of 1

m - m-m m - - --- - m-m - m - - m -

Table 18 Summary of Open Area Land Survey Areas Yankee Nuclear Power Station Rowe, MA SURVEY DESCRIPTION MARSSIM AREA AREA CLASS (-2)

OOL-01 SHERMAN POND SEDIMENTS 3' 73971 OOL_02 YANKEE NON-RAD YARD AREAS 3 7134 OOL-03 SHERMAN RESERVOIR DAM AND SOUTH SHORELINE 3 16177 OOL-04. US GENERATION / SHERMAN STATION OVERLYING GROUNDWATER PLUME 3 17870 OOL-05 US GENERATION / DEERFIELD RIVER FRONTAGE 3 28574 OOL-06 YANKEE WESTERN ACCESS 3 37281

• OOL-07 SOILS DEPOSIT AREA 2 2108 01,-08 YANKEE SITE EXCLUSIONZONE 3 133368 OOL-09 SOUTHEAST CONSTRUCTION FILL AREA 3 2387 OOL-10 ISFSI/ACCESS, EXCLUSION ZONE, BUFFER ZONE 2 8408 OOL-11 EAST RCA BUFFER ZONE 2 1220 OOL-12 WAREHOUSE RAIL SPUR 1 876 OOL-13 US GENERATION/RAIL SPUR TERMINUS 1 1148 OOL-14 US GENERATION/WHEELER BROOK FRONTAGE 3 2354 OOL-15 US GENERATION/SHERMAN RESERVOIR.EAST SHORELINE 3 4662 OOL-16 FURLON HOUSE PARKING LOT 3 2481 OOL-17 ASPHALT BRICK AND CONCRETE STORAGE YARD 3 3247 NOL-O1 EASTERN LOWER RCA YARD 1 1364 NOL-02 NORTHEASTERN UPPER RCA YARD 1 1990 NOL-03 SOUTHEASTERN UPPER RCA YARD 1 1575 NOL-04 SOUTHWESTERN UPPER RCA YARD 1 1753 NOL.05 NORTHWESTERN UPPER RCA YARD 1 1586 NOL-06 WESTERN LOWER RCA YARD 1 1329 NOL-07 ISFSI RCA YARD 3 1717 1 of 1

Table 19 Statistical Data Summary for Soils (Radiological)

Land Areas within the Radiologically Controlled Area Yankee Nuclear Power Station Rowe, MA

1. of Sample # of Mean Min Max Median Nuclide Results Detects (pCi/g) Std. Dev (pCi/g) (pCi/g) (pCi/g)

Ag-108m 329 54 7.361 21.245 0.031 99.714 0.241 Am-241 190 0 N/A N/A N/A N/A N/A Co-60 346 151 8.928 82.495 0.029 1008.8 0272 Cs-134 346 9 0.160 0.227 0.027 0.756 0.087 Cs-137 346 161 1.606 6.489 0.033 61.209 0.207 Eu-152 9 2 0.217 0.018 0.205 0.230 0.217 Nb-94 2 0 N/A N/A N/A N/A N/A Sb-125 22 0 N/A N/A N/A N/A N/A

• Table provides forresults of radionuclides determined to be potentially of concern at YNPS. Analyses were performed for the following radionuclides: Ac-228, Ag-108m, Ag-ll0m, Am-241, Ba-133, Ba-140, Bi-212, Bi-214, Ce-139, Ce-141, Ce-144, Co-57, Co-58, Co-60, Cr-51, Cs-134, Cs-136, Cs-137, Eu-152, Fe-59, 1-131, 1-132,1-133, K-40, Kr-85, La-140, Mn-54, Mo-99, Nb-94, Nb-95, Np-239, Pb-212, Pb-214, Ra-226, Ru-103, Ru-106, Sb-124, Sb-125, Se-75, TI-202, TI-208, U-235, Zn-65, and Zr-95.

1 of 1

Table 20 Statistical Data Summary for Soils (Radiological)

Land Area Within the Industrial Area (Outside RCA)

Yankee Nuclear Power Station Rowe, MA

1. of Sample # of Mean Min Max Median Nuclide Results Detects (pCi/g) Std. Dev (pCi/g) (pCi/g) (pCi/g)

Ag-108m 70 2 0.029 0.004 0.026 0.031 0.029 Am-241 69 0 N/A N/A N/A N/A N/A Co-60 90 8 0.394 0.599 0.033 1.726 0.253 Cs-134 87 4 0.139 0.050 0.096 0.209 0.126 Cs-137 90 34 0.121 0.112 0.035 0.457 0.082 Eu-152 6 0 N/A N/A N/A N/A N/A Nb-94 1 0 N/A N/A N/A N/A N/A Sb-125 5 0 N/A N/A N/A N/A N/A

• Table provides for results of radionuclides determined to be potentially of concern at YNPS. Analyses were performed for the following radionuclides: Ac-228, Ag-108m, Ag-110m, Am-241, Ba-133, Ba-140, Bi-212, Bi-214, Ce-144, Co-58, Co-60, Cs-134, Cs-136, Cs-137, Eu-152, Fe-59, 1-131, K-40, Kr-85, La-140, Mn-54, Nb-94, Nb-95, Np-239, Pb-212, Pb-214, Ra-226, Ru-103, Ru-106, Sb-124, Sb-125, Se-75, Te-132, TI-208, Zn-65, and Zr-95.

1 of 1

Table 21 Statistical Data Summary for Soils (Radiological)

Impacted Portions of the YNPS Site Outside of the Industrial Area Yankee Nuclear Power Station Rowe, MA

1. of Sample # of Mean Min Max Median Nuclide* Results Detects (pCi/g) Std. Dev (pCi/g) (pCVg) (pCi/g)

Aj-l"08m 422 5 0.032 0.008 0.023 0.044 0.034 Am-241 355 0 N/A N/A N/A N/A N/A Co-60 446 16 0.24;6 0.354 0.039 1.384 0.119 Cs-134 446 9 0.063 0.031 0.033 6.124 0.058 Cs-137 446 103 0.504 0.573 0.040 4.225 0.311 Igu-152 22 4 0.788 0.701 0.208 1.755 0.595 Nb-94 1 0 N/A N/A N/A N/A N/A Sb-125 39 1 0.215 N/A 0.215 0.215 0.215

• Table provides for results of radionuclides determined to be potentially of concern at YNPS. Analyses were performed for the following radionuclides: Ac-228, Ag-108m, Ag-110m, Am-241, Ba-133, Ba-140, Bi-212, Bi-214, Ce-141, Ce-144, Co-58, Co-60, Cr-51, Cs-134, Cs-136, Cs-137, Eu-152, Fe-59, 1-131,1-132, 1-133, K-40, Kr-85, La-140, Mn-54, Nb-94, Nb-95, Np-239, Pb-212, Pb-214, Ra-226, Ru-103, Ru-106, Sb-124, Sb-125, Se-75, Sn-113, TI-202, T1-208, U-235, Y-88, Zn-65, and Zr-95 1 of 1

Table 24 Statistical Data Summary for Sediments - Sherman Reservoir (Radiological)

Yankee Nuclear Power Station Rowe, MA

1. of Sample # of Mean Minimum Maximum Median Nuclide Results Detects (pCi/g) Std. Dev (pCi/g) (pCi/g) (pCi/g)

Ag-108m 6 1 0.029 N/A 0.029 0.029 0.029 Am-241 6 0 N/A N/A N/A N/A N/A Co-60 19 10 0.173 0.213 0.042 0.764 0.092 Cs-134 17 1 0.044 N/A 0.044 0.044 0.044 Cs-137 48 48 0.928 0.673 0.052 3.030 0.884 Eu-152 1 0 N/A N/A N/A N/A N/A Sb-125 2 0 N/A N/A N/A N/A N/A Sr-90 10 10 0.188 0.079 0.070 0.330 0.190

• Table provides for results of radionuclides determined to be potentially of concern at YNPS. Analyses were performed for the following radionuclides: Ac-228, Ac/Th-228, Ag-108m, Ag-110m, Am-241, Ba-140, Be-7, Bi-212, Bi-214, Ce-141, Ce-144, Co-57, Co-58, Co-60, Cr-51, Cs-134, Cs-137, Eu-152, Fe-59, 1-131, 1-133, K-40, Mn-54, Mo-99, Nb-95, Np-239, Pb-212, Pb-214, Ra-226, Ru-103, Ru-106, Sb-124, Sb-125, Se-75, Sr-90, Te/I-132, TI-208, Zn-65, and Zr-95.

Analysis for Nb-94 was not conducted.

1 of 1

Table 25 OHM in Sediment (Non-Radiological)

Wheeler Brook (100 Series)

Yankee Nuclear Power Station Rowe, MA Stalion Site SD-101 SD-102 SD-103 SD-104 SD-10 SD-106 Sample Designation Background Background Background SD-10l-00-14-l 04-00-04-- SD-103-00-04-1 SD-104-00-04-I SD-105-00 l Date Sampled Maximum 3X 83 8X 2/13/0203 8/13/2003 8/13/2003 8A3/2DD3 8/1312003 Total Petroleum Hydruorbons (mg/Kg)

TPH-DRO 80 240 400 2.8 U 2.6 U 41 2.9 8.2 3.2 Volatile Organic Compounds (ug/Kg) 1,1-Dichloroethene 24 5U 5U R 5UJ 5 U 3.3 J 1,2,4-Trimethylbenoene ND 5U 5 U R 5 US 5 U 5U 2-Butanone 67 0 U 10 U R 2.4 J 14 l0 U 4-Isopropyltoluene ND 5U 5U R 5 U 5 U 5U 4-Methyl-2-pentanone ND 5U 5 U R 5 U; I U 5U Acetone 280 39 UJ 29 U' 190 1 18 0 to UJ 10 US Carbon disulfde ND 5U 5 U R 5 UJ 5 U 5U Chioromethane ND 5U 5 U R 5 UJ 5 U 5U Methylenechloride ND 15 UJ 15 UJ R 15 UJ 15 UJ 15 US Naphthalene ND 5U 5U R 5 UJ 5 U 5U Toluene 31 U 5U R 7.7 UJ 5 U 5U TOTAL VOCs 402 1,206 2,010 190 20.4 14 3.3 Semi-VolatileOrganic Compounds (ug/Kg) 2-Methylnaphthalene ND 460 U 430 U R 400 U 460 U 500 U 2-Methylphen01 10 460 U 430 U R 400 U 460 U S00U 3+4-Methylphreol 230 460 U 430 U R 400 U 460 U 500 U Acenaphthene ND 460 U 430 U R 400 U 460 U 500 U Anthracente ND 460 U 430 U R 400 U 460 U 500 U Benzo(a)anthracefie 200 460 U 430 U R 400 U 460 U 00 U Be-zo(a)pyrene 230 460 U 430 U R 400 U 460 U 500 U Benzo(b)fluorantheoe 220 460 U 430 U R 400 U 460 U 500 U Beano(g,h,i)perylene ND 460 U 430 U R 400 U 460 U 500 U Benao(k)fluoranthene 220 460 U 430 U R 400 U 460 U 500 U bis(2-Ethylhexyl)phthalate ND 460 UJ 430 UJ R 400 UJ 460 UJ 500 UJ Carbazole ND 460 U 430 U R 400 U 460 U 500 U Chrysene 230 460 U 430 U R 400 U 460 U 500 U Diberao(a,h)anthracene ND 460 U 430 U R 400 U 460 U 500 U Dibenoofuran ND 460 U 430 U R 400 U 460 U 500 U Di-n-octyl phthalate ND 460 US 430 UJ R 400 UJ 460 UJ 500 UJ Fluoranthene 430- 460 U 430 U R 400 U

• 460 U 500 U Fluorene ND 460 U 430 U R 400 U 460 U 500 U Indeno(1,2,3-cd)pyrene ND 460 U 430 U R 400 U 460 U 500 U Naphthalene ND 460 U 430 U R 400 U 460 U 500 U Phenonthrene 140 460 U 430 U R 400 U 460 U 500 U Pyrene 380 460 U 430 U R 400 U 460 U 500 U TOTALSVOCa 2430 7,290 12,150 - - R PolychdloinatedBiphenyls (ug/Kg)

Aroclor-1254 ND 46U 43 U R40 U 46 U 46 U Aroclor-1260 ND 46 U 43 U R 40 U 46 U 46 U Total PCBs 57113 2890 -RI norganics (mg/kg)

Antimony ND ND ND R R R R R R Arsenic 2.8 8 14 0.64 UJ 0.21 U R 0.2 U R R Cadmium ND ND ND 1.9 U 1.7 U R 1.5 U 1.9 U 1.9 U Chromium 21 63 105 7.7 7.2 9.8 J 5 9.4 6.1 Chromium (Hexavalent) ND ND ND 2.79 UJ 2.6 US R 2.5 US 2.87 UJ 2.98 UJ Copper 45 135 225 3U 4.2 U R 2.4 U 3.5 U 5.9 U Lead 5.2 16 26 1.8 UJ 0.44 R 1.1 J 0.42 UJ 0.44 US Mercury ND ND ND 0.39 U 0.29 U R 0.49 U 0.41 U 0.42 U Nickel 28 84 140 6.7 7.6 12 5 4.1 U 6 5.6 Selenium 4.9 15 25 5. UJ 5.3U R 4.6 UJ 6U '6 U Silver 0.4 1 2 0.59 U 0.54 U R 0.47 U 0.61 U 0.61 U Thallium ND ND ND 0.47 U 0.67 U R 0.61 U 0.71 U 0.73 U Zinc 270 810 1,390 49 U 45 UJ R 39 UJ 51 UJ 51 Ui Notes:

Summary of detected compounds only

- = All constituents below detection limits ND= Not Detected in Background Blank Cells Were Not Analyzed

]= Esimated result R= Rejected result, unusable for project decisions U= Not detected, value is the sample detection/reporting limit UJ= Not detected, value is an estimate of detection/reporting limit

• PCBs not detected in background samples. Average of detections limits used to calculate Site background concentration.

Page 4 of 7

Table 25 OHM in Sediment (Non-Radiological)

Background (400 Series)

Yankee Nuclear Power Station Rowe, MA Station SD-401 SD-402 SD-403 SD-404 SD-405 SD-406 Sample Designation SD-401-00-04-1 SD-402-0(-O4l SD-403-00-04-1 SD-404-00-04-1 SD-405-00-04-1 SD-406-00-04-I Date Sampled 8/14/2003 8/14/2003 8/14/2003 8/14/2003 8/14/2003 "/14/2003 Total Petroleum Hydrocarbons (mg/Kg)

TPH-DRO (Diesel Range) 27 34 13 U1 24 ) 80 J 191 Volatile OrganicCompounds (ug/Kg) 1,1-Dichloroethene 231 24 1 15 J 19 J 21 7 UJ 1,2,4-Trimethylbenzene 6 UJ 10 UJ 5 U1 7 UJ 9 UJ 7 UJ 2-Butanone 30 J 21 UJ 11 J 22 1 67 32 J 4-1sopropyltoluene 6 UJ 10 U1 5 UJ 7 UJ1 9 1UJ 7 UJ 4-Methyl-2-pentanone 6 UJ 10 UJ 5 UJ 7 U1 9 UJ 7 UJ Acetone 110 J 19 UJ 42 J 761 280 190 J Carbon disulfide 6 U1 10 U1 5 U) 7 UJ 9 UJ 7 Il Chloromethane 6 U1 10 UJ 5 UJ 7 UJ 9 UJ 7 UJ Methylene chloride 18 U0 31 Ill 15 UJ 21 UJ 27 U1 21 UJ Naphthalene 6 UJ 10 UJ 5 UJ 7 UJ 9 U) 7 UJ Toluene 21J 31 J 12 J 27) 20 14 TOTAL VOCs 184 55 80 144 388 236 Semi-Volatile Organic Compounds (ug/Kg) 2-Methylnaphthalene 630 U 890 U 430 U 760 U 960 U 630 U 2-Methylphenol 150 ) 890 U 430 U 760 U 960 U 630 U 3+4-Methylphenol 630 U 230 J 430 U 760 U 960 U 630 U Acenaphthene 630 U 890 U 430 U 760 U 960 U 630 U Anthracene 630 U 890 U 430 U 760 U 960 U 630 U Ben-o(a)anthracene 630 U 180 1 430 U 760 U 200 1 630 U Benzo(a)pyrene 630 U 890 U 430 U 760 U 230 1 630 U Benzo(b)fluoranthene 630 U 890 U 430 U 760 U 2201 630 U Benzo(g&h,i)perylene 630 U 890 U 430 U 760 U 960 U 630 U Benzo(k)fluoranthene 630 U 890 U 430 U 760 U 220 J 630 U bis(2-Ethylhexyl)phthalate 630 U 890 U 430 U 760 U 960 U 630 U Carbazole 630 U 890 U 430 U 760 U 960 U 630 U Chrysene 630 U 200 J 430 U 170 J 230 J 630 U Dibenzo(a,h)anthracene f30 U 890 U 430 U 760 U 960 U 630 U Dibenzofuran 630 U 890 U 430 U 760 U 960 U 630 U Di-n-oetyl phthalate 630 U 890 U 430 U 760 U 960 U 630 U Fluoranthene 630 U 380 J 170 1 320 J 430 J 630 U Fluorene 630 U 890 U 430 U 760 U 960 U 630 U lndeno(1,2,3-cd)pyrene 630 U 890 U 430 U 760 U 960 U 630 U Naphthalene 630 U 890 U 430 U 760 U 960 U 630 U Phenanthrene 630 U 890 U 140 J 760 1 960 U 630 U Pyrene 630 U 320 1 130 J 280 1 380 1 630 U TOTAL SVOCs 150 1,310 870 770 1,910 -

Polychlorinated Biphenyls (ug/Kg)

Aroclor-1254 91813T431U 761U 190013 T 1300131 Aroclor-1260 Total PCBs I U9 8913 43 U 76 U 1900 UJ 1300 UJ Inorganics (mg/Kg)

Antimony R R R R R R Arsenic 1.6 2J 0.21 UJ 1.7 J 2.8 1.6 Boron Cadmium 1.3 U 1.8 U 0.91 U 1.61U 2U 1.3 U Chromium 9.8 19 4.5 17 21 16 Cheromium (Hexavalent) 3.5 UJ 5.2 U1 2.7 UJ 4.7 U1 6 UJ 3.9 UJ Copper 21 37 6.4 35 45 42 Lead 2.7 ) 2.8 1 0.65 UJ 2.8 J 5.2 1 2.7 J Lithium Mercury 0.58 U 0.4 U 0.34 U 0.69 U 0.65 U 0.32 U Nickel 11 25 12 20 28 23 Selenium 3.9 J 5.7 UJ 2.8 1U 4.9 J UJ 4.1 UJ Silver 0.4 J 0.58 UJ 0.29 UJ 0.5 UJ 0.64 Ill 0.42 UJ Thallium 0.93 U 1.4 U 0.67 U 1.2 U 1.5 U 0.97 U Zinc 130 270 49 170 250 200 Notes:

Summuary of detected compounds only

- = All constituents below detection limits Blank Cells Were Not Analyzed J= Estimated result R= Rejected result, unusable for project decisions U= Not detected, value is the sample detection/reporting limit UJ=Not detected, value is an estimate of detection/reporting limit Page 7 of 7

Figures CI 77ý1/

Z.

VA YAEC Property Boundary Scale 1:25,000 0.5km 0 500 m 0.5 mi 0 1,000 ft Figure I - Locus Map Yankee Nuclear Power Staton - Rowe, MA

Forme30,OGe FuelOlAST 0

0 Fanner Cirait --

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Forner Saton Servi Trimum're Farmer MainTurreonner Fom'er Sta ervice Trwa*u*" (2)

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Undeground Storge Tart (ST)

T nedmoer No-PCB 01 Tr=nfne PCB01 Notes:

The Following are not Shown on Figure Twanefnner Yard Bmxftdy

- 500 Gal. Diesel Portable AST

- 330 Gal. Fuel Oil AST Located InVisitors Center Basement Figure 4 - AST, UST and

- Former 275 Gal. Diesel AST Located in Middle Parking Lot Transformer Location Map

- Former 550 Gal. Fuel Oil UST Located at Visitor's Center Yankee Nuclear Power Station - Rowe, MA

t '// f- -(ý41 I

• 'ý3 I V1

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Scale 1:12,500 0.25 km 0 250 m 0.25 mi 0 5O ft Compound 'mAg)' (g/g YAEC Property Boundary SB-I157. Targeted Deep Sample See aomment 1 SB-155" Targeted Surface Sample SB-168A Background Surface Sample a Former UST iIL Scale 1:120 Comments

1. Value represents maximum conwfrllmon detected at sample loatdon.

Figure 15 - Soil Sample Locations (Non-Industrial Area) and OHM Results Exceeding MCP Reportable Concentrations Yankee Nuclear Power Station - Rowe, MA

THIS PAGE IS AN OVERSIZED DRAWING OR FIGURE, THAT CAN BE VIEWED AT THE RECORD TITLED:

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(u~ ,t R WATI mW SamWEVAL ND PCIMLUETATA MTE=TLI OFADCIJ 2D0pQ MW.NOMI WUlASAMM P0 WT POEMT ATADE1~TEM LW OFUM00pai NiLY OKNOYBE2W04 660 HORIZONTAL MCALE : fact 0 WO 200 300 400 80 B0 700 800 900 0 0 U0 U 400 400 Yankee Nuclear Power Station j HydrogeoIol CroSSection C - C' Revision: 2, JAN 2005 Figure 18

Figure 26 Proposed Pathway to Integrated Environmental Site Closure Yankee Nuclear Power Station, Rowe, MA Phase II Comprehensive Site Characterization & Risk Screening Focused Remedial Actions Assessment Report January2005 to June 2005 January2005 to September 2005 January2005

" Comparison of radiological data to

• Phase IV PCB Sediment Remediation

• Summary of likely/known sources of Derived Concentration Guideline completed January 2005 Levels (DCGLs)

• Interim excavation and management release of radioactivity and oil/hazardous materials (OHM) to the

• Comparison of OHM data to MCP of PCB impacted soil under Release Method 1 Standards/Guidelines Abatement Measure (RAM) environment

" Rationale for selection of

• Development of sampling plans to

• Phase IV PCB Soil Remediation &

radioactive/OHM confirm results, define extent of TSCA Permitting constituents/chemicals of concern impact and likelihood of remediation

• Removal/Off-site disposal of (COCs) and areas/media targeted for

• Conduct remedial actions where radioactivity > DCGLs investigation impacts necessitate risk reduction

• Removal of SCFA & re-use under

• Results of investigation and testing to

• Quantitatively characterize risk on BUD identify the nature and extent of select issues: " Potential remedial activities:

contamination in potentially affected o SCFA Soil for Re-use o Soil/concrete removal at media (soil, groundwater, surface o Demolition Debris Spent Fuel Pool water, sediment, air, fish and food o PCBs in Soil o Removal of lead-impacted stocks such as syrup and milk)

• Identify areas where additional soil at Old Shooting Range

• Summary of on-going/scheduled remediation is necessary to satisfy site o Other areas being evaluated investigations and/or remedial actions closure total risk thresholds Collection of Final Site Status Data Site Closure Risk Assessment January2005 to December 2005 October2005 to March 2006

• Final Status Survey (FSS) data for

• Integrate post-remedial radiological radioactivity and OHM data representative of

" Confirmatory OHM sampling residual impact following completion of remedial

• Complete quantitative human health activities and ecological risk assessments

• Most recent year of groundwater " Release summary report for monitoring for groundwater data stakeholder review

• Other OHM characterization data " Conduct public meetings & address that is representative of post-remedial comments site conditions

• Prepare Final Risk Assessment

Appendix A APPENDIX A -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 Integrated Permit Package and Appendices - May 7, 2004 Phase IV Remreedy Implementation Plan - April 23, 2004 Quality Assurance Project Plan (QAPP) - August 6, 2004 Risk-Based Disposal Approval Application (RBDAA) - June 30, 2004 Southeast Construction Fill Area Beneficial Use Determination (BUD)

Application - August 2004 Historical Site Assessment APPENDIX A-PAGE I YANKEE /15181 /1/28/05 ER~\l ERNI APPENDIX A-PAGE I Y~dNKEE /I151SI/1 /128/05

Hydrogeologic Report of 2003 Supplemental Investigation - March 16, 2004 Natural Resources Inventory and Management Plan - April 2004 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 Permitting Documents:

Application for Beneficial Use Determination for Structures - September 22, 2004 Expanded Environmental Notification Form (EENF) - March 31, 2004 Secretary's MEPA Certificate on the EENF - May 7, 2004 Southeast Construction Fill Area Corrective Action Design (CAD)

Water Quality Certification - September 9, 2004 Wetland Restoration and Replication Plan - August 2004 ERM APPENDIX A-VAGE 2 YANKEE /15181 /1/28/05

Appendix B APPENDIX B -

SUMMARY

OF RADIOACTIVE ANALYSIS METHODS 1.0 RADIOACTIVE SAMPLE ANALYSIS METHODS 1.1 Overview Several analysis methods are available for the measurement of radioactivity in environmental samples. The method used for analysis depends on the objective of the analysis and the isotope(s) of concern.

Table I provides a summary of the radiation detection and analysis methods used in radioactivity sample analysis.

Table 1: Summary of Radiation Detection Methods Radiation Detection Method Used For... Analysis Consideration Gamma Spectroscopy Gamma Emitters Low Cost, Minor Sample Prep.

Moderate Cost, Requires Chemical Gross Beta Beta or Beta/Gamma Emitters Preparation Moderate Cost, Requires Chemical Gross Alpha Alpha Emitters Preparation Beta, Alpha, or Low Energy Gamma Moderate to High Cost, May Require Liquid Scintilation Emitters Chemical Preparation and Separations High Cost, Requires Separation Alpha Spectroscopy Alpha Emitters Chemistry

.High Cost, Requires Separation Beta Spectroscopy Beta Emitters Chemistry 1.2 Gamma Spectroscopy As noted in Table 1, gamma spectroscopy is the least expensive method generally employed for sample analysis. This method is able to identify and quantify any radioisotopy that emits gamma radiation with few exceptions. The most common type of detector currently used for this analysis is a High Purity Germanium (HPGe). Prior to the mid 1980s, germanium lithium (Ge(Li)) detectors were used in most gamma spectroscopy analysis, and, prior to the mid 1970s, sodium iodide (Nal)

ERM APPENDIX B-PAGE 1 YANKEE /15181 /1/28/05

were used. Sample preparation for gamma spectroscopy sample analysis generally involves either drying for soil samples, and/or, placing the sample into a specific container to control the geometry of the sample-detector system to match the detector calibration conditions.

1.3 Gross Beta and Gross Alpha Gross beta and gross alpha analysis involves preparing a sample such that its potential radioactive constituents are removed and evaporated onto a small (2 inch diameter) steel planchete. This planchete is then placed under gas-flow proportional counter and counted for beta or alpha particles. This analysis method is sensitive to any radioisotope that emits beta or alpha particles including naturally occurring radionuclides. This method is incapable of identifying the specific radionuclides contained within a sample, only whether alpha of beta radiation is emitted from the sample.

1.4 Liquid Scintillation Liquid scintillation analysis requires that the potential radioactivity be chemically removed from a sample and placed into a small (50 ml) vial containing liquid scintillation fluid. This vial is then placed into a scintillation counter. This analysis is capable of measuring radioactivity from radionuclides that emit low energy gamma radiation (not detected via gamma spectrometry), beta or alpha particles provided the radionuclides are chemically separated from the sample material during the sample preparation and processing. Depending on the specific analysis needed, the sample preparation and separation process for liquid scintillation analysis can be a substantial component of the analysis cost.

1.5 Alpha and Beta Spectroscopy Similar to liquid scintillation analysis, this method requires that separation chemistry be performed on each sample. This process generally results in a thin layer of dried processed sample deposited on a steel planchete. This planchete is placed close to a spectroscopy detector where a specific "fingerprint" of particle energy is identified. This "fingerpint" is used to identify and quantify a specific radioisotope.

1.6 Sample Analysis for Final Status Surveys Many of the radioisotopes not included in the LTP include the emission of gamma rays. All final status survey (FSS) samples will include analysis by gamma spectroscopy in the same way as the characterization samples ERM APPENDIX B-PAGE 2 YANKEE /15181 /1128/05

have included. As such, any of these radionuclides will be identified, if present, during the FSS despite their absence from the LTP.

In addition to performing gamma spectroscopy of all FSS samples, at least 5% of all samples will be analyzed for radionuclides that only emit beta or alpha particles. These analyses will be performed by either alpha spectroscopy or liquid scintillation. The samples selected for these expanded analysis will, in part, be based on the activity of each sample as measured by gamma spectroscopy. Given that all the production of each type of radioisotope is similar (AP versus FP) and that the chemical properties are not vastly different, then it is reasonable to expect that samples containing elevated levels of APs as identified by gamma spectroscopy are likely to contain elevated levels of other APs with no gamma ray emissions.

2.0 RADIOLOGICAL ANALYSIS METHODS USED IN REMP 2.1, Gross Alpha & Beta Analysis Air particulate samples, collected on a weekly basis, aid in verifying the in-plant controls used for monitoring the release of radioactive materials.

Air particulate samples are analyzed on a low background alpha/beta gas proportional counting unit, following a delay of a 100-hour minimum to allow for the decay of radon products. Blank filters of the same size and type as the client filters are used for background subtraction. If the beta activity concentration is greater than 0.2 pCi/m 3 , the sample may need to be analyzed for individual gamma emitters. Each sample is composited by sampling location and held until the end of the quarter for a gamma isotopic analysis.

Environmental water samples are also analyzed for gross alpha and/or gross beta radioactivity. Samples are evaporated and a planchet 2 containing the particulate residue is analyzed by a gas proportional counter. Measurable amounts of naturally occurring alpha and beta emitting radionuclides are often found in environmental water samples.

Gross alpha and gross beta measurements are rapid screening methods which may indicate the need for a nuclide specific isotopic analysis.

2.2 Gamma Spectrometry The following media are typically analyzed for gamma isotopic content:

• milk ERM APPENDIX B-PAGE 3 YANKEE 115181 11/28/05

0 water

• charcoal cartridges 0 airborne particulate filters

• fish/shellfish

• vegetation/food crops

• sediment/soil samples Samples are prepared by various controlled methods (blending, drying, milling) in order to maximize the volume which can be analyzed, and to achieve sample homogeneity. In order to ensure the precision and accuracy of the gamma measurements, specific counting containers are used to load sample media in a reproducible manner. Samples are analyzed via high purity germanium based gamma ray spectrometry detection systems. The gamma spectrometry software accounts for baseline corrections, background peak interferences, and photopeak multiplet resolution. Detected photopeaks are identified using a comprehensive library, specifically tailored for environmental monitoring around nuclear power facilities.

Concentrations are calculated and reported for 27 radionuclides, whether they are present in the sample or not. These radionuclides, listed in Table 2 represent gamma emitters most appropriate for nuclear power plant effluents. The gamma spectrometry analysis exceeds the current NRC assay requirements (3 radionuclides for MDC or Reporting Levels) for this analysis atYNPS. In addition to the 27 reported radionuclides, another 16 radionuclides are included in the software library and will be identified, if present. Lastly, the gamma spectrometry software will report to the analyst all photopeaks found in the sample, whether identified or not.

Thus, a radionuclide like Eu-154, with approximately ten measurable photopeaks, would be revealed by its unique combination of characteristic gamma photons, whether or not it is included in the library.

Table 2. Radionuclides Reported in Gamma Spectrometry Analysis Radionuclide List for YR REMP Analysis AcTh-228 Co-60 Mn-54 Ag-t08m Cr-51 Nb-95 Ag-Horn Cs- 134 Ru-103 Ba-140 Cs-137 Ru-106 Be-7 Fe-59 Sb-124 ce-Hi1 1-131 Sb-125 C-141-133 Se-75 co-57 K-40 Zn~-65 Co-58 La -140 Zr-95 ERM APPENDIX B-PAGE 4 YANKEE /15181 /1/28105

Iodine Analysis The required low detection limit for 1-131 in milk, vegetation and water samples can only be achieved by radiochemical separation and concentration of the iodine.

The beta-gamma coincidence system is calibrated to detect the characteristic 1-131 beta and gamma radiation. This system combines a plastic scintillator beta detector with a Na(l) gamma detector. Beta gamma coincidence counting allows for a very low background since the system is optimized for 1-131 and therefore, increased detection sensitivity.

2.4 Tritium Analysis The determination of tritium in environmental samples involves distillation and analysis of the pure distillate by liquid scintillation spectrometry. The tritium counting efficiency is determined using an efficiency curve generated as a function of the sample quench.

A multi-channel analyzer associated with the liquid scintillation counting system is optimized for the tritium beta energy. Additionally, the spectra are evaluated to ensure that the distilled samples are free of interferences.

2.5 Strontium Analysis The determination of Sr-89, 90 in environmental media is achieved by pre-concentration followed by separation and purification followed by analysis for total strontium using the CerenkOv counting technique. The Cerenkov radiation, resulting from the interactions of the Sr-89 and Y-90 beta emissions in the liquid scintillation counter is detected and processed by the multi-channel analyzer. Following yttrium(Y)-90 in-growth, Sr-90 is separated and the Y-90 fraction is analyzed by Cerenkov counting. The concentrations of each strontium isotope are determined mathematically based on the two measured results.

3.0 LABORATORY QUALITY ASSURANCE PROGRAM The quality assurance program at the Framatome-ANP Laboratory (FANP) is designed to serve two overall purposes: 1) Establish a measure of confidence in the measurement process to assure the licensee, regulatory agencies, and the public that analytical results are accurate and precise; and 2) Identify deficiencies in the sampling and/or measurement process to those responsible for these operations so that corrective action ERNI APPENDIX B-PAGE 5 YANKEE /15181 /1/28/05

can be taken. Quality assurance is applied to all steps of the measurement process, including the collection, measurement and reporting of data, as well as to record keeping of the final results. Quality control, as part of the quality assurance program, provides a means to control and measure the characteristics of the measurement equipment and processes, relative to established requirements.

The FANP employs a comprehensive quality assurance program designed to monitor the quality of analytical processing to ensure reliable environmental monitoring data. The program includes the use of controlled procedures for all work activities, a nonconformance and corrective action tracking system, systematic internal audits, audits by external groups, a laboratory quality control program, and a staff training program. Monitoring programs include the Intra-laboratory Quality Control Program administered by the Laboratory QA Officer (used in conjunction with the National Institute of Standards and Technology Measurement Assurance Program, NIST MAP) and a third party cross check program administered by Analytics, Inc. Together these programs are targeted to supply QC/QA samples at 5% of the client sample analysis load. In addition, a blind duplicate program is conducted through client environmental monitoring programs.

A yearly summary of the FANP Laboratory performance on Quality Assurance samples is provided in the Annual Radiological Environmental Operating Report that is submitted to the NRC.

ERM APPENDIX B-PAGE 6 YANKEE /15181 /1/28/05