ML072420100

Letter from M. Gorski, Massachusetts Department of Environmental Protection, Regarding Yankee Nuclear Power Station Draft Environmental Assessment for the License Termination Plan

ML072420100
Person / Time
Site:	Yankee Rowe
Issue date:	03/31/2005
From:	Gorski M State of MA, Dept of Environmental Protection
To:	John Hickman NRC/NMSS/DWMEP/DD
References
Download: ML072420100 (24)

Text

COMMONWEALTH OF MASSACHUSETTS fEXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION WESTERN REGIONAL OFFICE 436 Dwight Street e Springfield, Massachusetts 01103 e (413) 784-1100

• FAX (413) 784-1149 MITT ROMNEY ELLEN ROY HERZFELDER Governor Secretary KERRY HEALEY ROBERT W. GOLLEDGE, Jr.

Lieutenant Governor Commissioner March 31, 2005 US Nuclear Regulatory Commission Decommissioning Directorate Office of Nuclear Material Safety and Safeguards Washington, D.C. 20555-0001 Attention: John B. Hickman, Project Manager - Yankee Nuclear Power Station

Dear Mr. Hickman,

Thank you for your letter of March 3, 2005 that seeks Massachusetts Department of Environmental Protection (MADEP) comments on the "Predecisional Draft Environmental Assessment Related to Consideration of License Termination Plan" at the Yankee Nuclear Power Station (YNPS) in Rowe, Massachusetts. The purpose of the Environmental Assessment (EA) is to determine the environmental impacts (radiological and non radiological) of approving the License Termination Plan (LTP) for the YNPS and releasing the site for unrestricted use (as defined in 10 CFR 20.1402). The LTP was submitted to the Nuclear Regulatory Commission in November 2003 and it established a goal of completing decommissioning by mid 2005.

As you know the MADEP has been fully engaged in the ongoing decommissioning activities at the YNPS over the past several years and appreciates the opportunity to comment on this element of the license termination process. The owner of YNPS, Yankee Atomic Electric Company (YAEC), has indicated in the LTP that they intend to comply with the Commonwealth of Massachusetts' clean up standards for both radiological and non radiological contaminants.

As the physical plant has been dismantled the DEP has reviewed and approved a number of permit applications under pertinent Massachusetts Environmental Laws in order to advance the decommissioning project. Although there are more permits to be reviewed before the project has been completed, substantial progress has been made to date towards realizing YAEC goals.

In order to provide comments in their proper context, the MADEP has attached a redline/strike out copy of the EA word document you sent the MADEP via e-mail on March 3, 2005.

However, there are a few significant areas of comment that should to be highlighted here in the cover letter. They are listed below:

1. The extent of existing radiological and non radiological contamination at YNPS has been updated in the EA to reflect more recent data. (see sections 3.1.1 and 3.1.2)

This information is available in alternate format. Call Donald M. Gomes, ADA Coordinator at 617-556-1057. TDD Service 800-298-2207.

DEP on the World Wide Web: http://www.mass.gov/dep Q Printed on Recycled Paper

2

2. The understanding of groundwater conditions at YNPS continues to improve so the EA has been edited to incorporate more recent information. (see section 3.3.2)

3. Commonwealth of Massachusetts standards have been added to the EA to provide clarity on state requirements. (see sections 3.1, 3.4, 4.3)

Again, thank you for the opportunity to comment on the EA. Hopefully our comments will be helpful to you during NRC deliberations. If you have any further questions please contact Mr.

David Howland of my staff at 413-755-2280.

Sincerely, Mike si Regional Director Encl. Marked up EA document Cc Mr. Michael Whalen, MADPH Mr. Marvin Rosenstein, USEPA - Region I Mr. Joseph Lynch, YAEC

U.S NUCLEAR REGULATORY COMMISSION YANKEE ATOMIC ELECTRIC COMPANY DOCKET NO. 50-29 YANKEE NUCLEAR POW ION CONSIDERATION OF LICENSE' IN ON PLAN' PREDEClSIONAL DRAFT ENVIRONMENTAAWSSESSA T:

1.0 INTRODUCTION

The U.S. Nuclear Regulatory Commission (NRC) (or t e staff) g Yankee Atomic Electric Company's request for approval of the Li erminat TP) submitted for the Yankee Nuclear Power Station (YNPS) in achuse NRC has prepared this environmental assessment (EA) to deter nmenta acts (radiological and non-radiological) of approving the LTP and uhe site for unrestricted use (as defined in 10 CFR 20.1402). Thi consi rule, 10 CFR 50.82 that appeared in the FederalRegister on Jul 9,199 1 ecommissioning of Nuclear Power Reactors), which established th riteria ens tion and the requirement for a license termination plan.

As discussed in Section 1.3 belo prim scope o is EA is the evaluation of the impacts of the radiation release criteria e ad cy of t nal status survey, as presented in the LTP.

1.1 Bacjkj d YNPS " rpater nuclear reactor situated on a small portion of a 2,200-acre site. ocate stern Massachusetts in Franklin County, near the southern Ve er. T most of the 2,200-acre site are owned by the Yankee Atomic Electri I portion on the west side of the site (along the east bank of the Sor) d by USGen New England, Inc. The YNPS plant was constructed nd operated commercially at 185 megawatts electrical roductio erae) until 1992. In 1992, YAEC determined that closing of the plant wrd be in the bic interest of its customers. In December 1993, NRC amerd the YNPS op iense to retain a "possession-only" status. YAEC began dis tling and decom ginactivities at that time. These activities continue and their rel nce with respect hi EA is discussed in Section 1.3. The spent nuclear fuel remaining 0 was transferred 2003 from the spent fuel pool to the independent spent fuel storage S lation (ISFSI) lo d adjacent to the plant. The spent fuel pool was subsequently drained ordance with rotocols.

In November 2003, YAEC submitted its LTP with a goal to complete decommissi ,pg by mid-2005 (YAEC, 2003). Draft Revision 1 to the plan was submitted Septer~ber2,, . (YAEC, 2004a), in response to a NRC request for additional information (NRC, 2004 ubs* y, on November 19, 2004, YAEC submitted Revision 1 to the LTP (YAEC, 2004 W YAEC is proposing to decontaminate the YNPS site to meet u Itted re of 10 CFR 20.1402. Additionally, YAEC has stated that it intends to co ith the Uh of Massachusetts cleanup criteria established by the Massachusl (MDI and the Massachusetts Department of Environmental ProtecfiA demolished to grade or entirely removed, or uffes remove ill be and most buried Pl D)Ee following ost Sl 1~st remain after phased release of the site: the administration b] ard building, a sm*Wchyard outside the guard building, the ISFSI, the ISFSI security buil cess roads. After the irradiated fuel has been removed from the site and prior to license termii SI and ISFSI security building will be removed. ,

1.2 Need for the Proposed Action Licensees of nuclear facilities must apply to thj termini and decommissioning a facility. YAEC subt L requi r y 10 CFR 50.82, before requesting license termination. The NRC thr: proposed procedures, adequacy of radiation criteria for license in ratus rF license survey planned for voluntarily completing decommissioning appear s ient according to the plan, would demonstrate that the site is suitable foA lease 14 1.3 Scope P4 t

To fulfill its obligations under & nal lfionmef Policy Act (NEPA), the NRC must evaluate the radiological an n ntal impacts associated with approval of the LTP an ubsequent on of tl hese evaluations involve an assessment of the im the re ildings es and residual material present at the site at the ti, se te As describl atemi ideration accompanying the Final Rule on Decommi ktors (61 FR 39278), the NRC must consider the following in or, e thi (1) the adequate funds will be available for final site (2) on release ci license termination, and (3)We adequacy of survey required to verify that these release criteria have Infeen met.

ssues Stud 'in Detail

Consistent with NEPA regulations and guidance to focus on environmental issue concern, impacts to land use, water resources, and human health were selected or det tudy because of their potential to be affected by an approval of the LTP. TIeis s ae discussed in this EA due to the potential for impacts from remaining s*ra nd/or residual material left at the site. A&

1.3.2 Issues Eliminated from Detailed Study Issues eliminated from detailed study in this EA includ quality resources, ecological resources (including endangere( J threj Phed spec i quality, off_-

socioeconomic conditions, transportation, noise, visua tededbecauset bease='ld not management, and accident scenarios. These issues be affected by implementation of the LTP at the site (i.l the site meets radiation release criteria in the final status survey). The financial L eview, which is a required part of the LTP approval, is not related to human healt2 ment and will not be discussed in this EA. J Impacts from decommissioning activities at the YP a are no

• din this EA. NRC has already assessed power plant decommissi n pr atic NEPA documents. Specifically, the environmental for de missioning activities (NRC, 1988, 2002) discusses the range of fmer plant decommissioning activities. Further, the iologil sing the site for unrestricted use are bounded by impac valuate ,"Generic Environmental Impact Statement in Support of Rulem ng on 8liologi or License Termination of NRC - Licensed Nuclear Facilities." Ct 1 Decon ioning impacts at the YNPS site were also addressed in the YAEC' hu A ;sioning Activities Report (PSDAR) (YAEC, 2000). £ Additionally, the Commis ht ade a {*i~

ic ination that, if necessary, spent fuel generated i lny reactor 1!ored s out significant environmental impacts for at least 3 s beyond ts licen! ng life (64 FR 68005 and 10 CFR 51.23).

Thherefo doe te envi tal impacts of spent fuel storage in the onsite es. The independent spent fuel storage installation (ISESI) . Ihc)wi insed briefly in Sections 3.2 and 4.1.

2.0 PR( IVES 2.1 The F The pi review and approval of YAEC's LTP. The NRC staff will

!sedaction is, review e plan to ensu e license termination activities (i.e., designation of radiation relej criteria and des e final status survey) will comply with NRC regulations. If NRC ap es the plan, the r val will be issued in the form of an amendment to the YNPS i Ii (Possession Oq License No. DPR-3).

plans to con ,te decommissioning of the YNPS site for unrestricted use, as described LTP and coi tent with NRC regulations at 10 CFR 20.1402. In addition, YAEC intends ommonwealth of Massachusetts cleanup criteria specified by the MDPH, Page and by the MDEP in the Massachusetts Contingency Plan (MCP) and Solid WE II as applicable. To meet NRC's unrestricted release criteria, areas of th site wi divided into survey units. These units will be sampled or surveyed in accordance the Pto verify that site-specific criteria have been met. These criteria, known as "derive W ation guideline levels" (DCGLs), are discussed further in Sections 3.4 and,.

Initially, YAEC plans to release all but 87 acres of the si unrestric r having passed the final survey. The remaining 87 acres woul am on t c fuel is shipped offsite for permanent disposal (see Sec 4.1) an t e IS decommissioned. At that time, the remaining acreage d ag e surve gent on survey results, the license terminated.

2.2 Alternatives As an alternative to the proposed action, the staff cons* action alternative". The no-action alternative would maintain the status quo. s wo no change to current environmental impacts, which are larger than those re ulting r sed action.

3.0 AFFECTED ENVIRONMENT 3.1 Site Description The YNPS site is located at 49 Yankee ad, a im miles north-northwest of the northwestern Massachusetts town of in F kin C The site is adjacent to the Vermo ter on d chara rized by heavily wooded, steep hills.

It is situated within the Deerfield alle d abuts eastern shores of the Deerfield River and Sherman Reservoir. bound* the De Id River valley rise 500 to 1000 feet above the site, reaching ele ati of 210 ab ean sea level (ERM, 2004a). The combinedp ulation of th arest t and Monroe, is less than 500.

The YN cout 2,2 s in the towns of Rowe and Monroe. Most of this pro x tres) is owned by YAEC; the remaining portion is owned by USGen N Inche USGen property is a narrow strip of upland to the west of the ding a ire eastern bank of Sherman Reservoir. USGen also owns the resee' ,property west of the Sherman Reservoir, and property down erman ncompassing both banks of the Deerfield River. YNPS operations ted out 15 developed acres, primarily on land owned by YAEC, b endin rty owned by USGen (ERM, 2004a).

The S site is divide ee areas based on past site activities and land use:

ustrial Area: appli ately 12-acre fenced portion of the site that contains industrial ant structures an perations.

diologically C rolled Area (RCA): 4-acre parcel within the industrial area that contains

.ological m ials associated with plant operation.

Page Non-Industrial Area: remaining land outside the fenced industrial area that c( Pins the USGen Sherman Station hydroelectric plant, the Sherman Reservo and DD transmission lines traversing the site, administration building and visitor center, r, wad areas and undeveloped woodland (YAEC, 2004b; ERM, 2004a). W During construction of the storage installation for the-spei a

construction and demolition debris was placed into what 15w the S struction Area (SCFA). This area of approximately 1.5 acres coj s soil anA on to wo concrete, asphalt, and metal debris. In accordance wI t)EPs Es 40-*

plans to remove the materials from this area, returnin ' other for regrading.

Ecology and Cultural Resources The US Fish and Wildlife Service confirmed in corresp AEC that no federally listed endangered or threatened species occur on th e. ( b) Massachusetts species of concern have been identified on the YNPS ite. A n g salamander was identified in a headwater channel of Wheeler Bro e bristly nt was discovered in a drainage area along the Wheeler Brook Dive id the stern fenceline.

Longnose suckers are documented to exist i o AEC is working with the Massachusetts Division of Fisheries & Ie ation eritage FOUdation and Endangered Species Program (NHESP)t vel*p tection of these species during the remainder of decommissioni etivitie eritage Foundatio is_

isto conduct project

1(AiJi[ietm.;i Ihnit [tpn1U to raq4.Uim m :agintheUnited States.)

Several resources of cultural an dric si cance eR at the site; however, none of-these have been affected by decomm ing a( Ds. AA03 report documents these resources, most of which are located in th :laýýAL, 2003). The report also includes a managemegLplan that m sachu! ýI1 Commission guidelines.

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doe eafteF 4' gb-, C6, Ru-i'Ru-ý'Am7-'Gm, aRd-244Gm--AGGGFd+ng4Y-,

-the- all final status survey-s-,

W-is-i- plannon and GendUG ating- rp-le-AGe n-riteria. Moved to end of section The (ab, Feo 2170rity acres),

of the siteas F Ned in Section utside 2.5 of area the industrial the LTP. The non-impacted was determined area consists to be non-impacted of forested, rugC rain that has not been disturbed. This determination is based on

he Historical SiteA sment (YAEC, 2004c) and additional characterization surveys.

)gically-impa

,ýxtending oq  ! pproximately areas of the1000 site feet fromthe include theindustrial vapor container area and(now

ýd areas comprise approximately 30 acres, the majority of which are dismantled).

surrounding open Theland Page minimally impacted (contain residual radioactivity at levels no greater than a fra(

proposed DCGLs). For a more detailed description of initial radiologica charac ation Of theof the impacted area, refer to the YNPS Historical Site Assessment and Sec 2.4 ie LTP.

The Historical Site Assessment also identified low levels of ntami " arily Co-60, in the sediments of Sherman Reservoir. This radioactive m Aýwas 3s a result of permitted and monitored radioactive liquid releases. Ch erization wed the radioactive material concentration is a small fraction of propose with potentially contaminated sediments are included in the al status*

evaluation.-alF-re

.... lsefi .. an-VFetpbi elhae 6saGhusetts I

k~elythe PGE-of the n.itia. pas resubmit thei.

o After a reveofe rSeGuio th talar.ateriztion, E dneieited phe wl wir, ongo e

detected are below risk levels desigiqv it sDe baetuent of Environmental Protecmio vitess Characterization Process the dan b f e s iy Site characterization activities e tor in two es, initial and continuing. The results of the initial phase were submitt po the I in Ja 2004. After a review of the results of the initial characterization, s nitiatedo phase, which will be ongoing throughoutp emainder tecommii ies. The results would be used not only toitieds ities, bu nfirm the appropriateness of the radiolo* te'he dos .1ad basis for the corresponding DCGLs by media.

Site charact rvysed to determine the nature and extent of radiological contamination pose of the site characterization survey is to:

(1) permit la0 ies; ()dmntaethat iisunlikely that significant quantities~il h gone undetected at the site after remediation; (3) provi formati the final site survey (i.e., identify survey unit classifications for impact areas); and .nput to dose modeling (NRC, 2003). Site characterization activi include the co various types of samples, including soil, sediment, water, con e, metal, and su sidues. Surveys and sampling conducted during site ch cterization are ba o knowledge of the plant history and likely areas of contamination.

I ordance with 10 R 50.82(a)(9)(ii)(A), radiological conditions of the site were provided in n 2.0 of the LT he results of sample analyses and the use of the results in identifying nificant radio lides expected to be present after remediation are described in ents 2B C of Chapter 2 of the LTP.

Page YAEC conducted a series of sample analyses using site media believed to repr the distribution of radionuclide contaminants, and their decay-corrected iso dis over the operational history of the plant. In its technical basis document, Y de bes the method that was used to determine radionuclides that could 1 be 4 presee (YAEC 2003). The radionuclides include, but are not limited to: 3 " C, 54I 7 ,, 58 Co, 59 63, 65 Ni, 0Co, Ni, Zn, 90 r, 9 Nb, 99T, 0 R*U, lmAg, 12 6

155 238 239 241 241 243 O5,129 1 ad n, 152 Eu, 154 E E-u, P'u, P'u, 240 u, P'u, Am, C~m, and 24 C se rd dlude fissio and activation products, which are typical of those foun , pressuriT, These radionuclides are also described in two NRC do. -ents: N GI kpr plants "Technology, Safety and Costs of Decommissioning a ,essurize ferenc Power ReactorStation,"Materials,"(Smith (Evanset al.,et 1978) and NUREG/CR-al., 1984).t o 1L* I.ived Activa in Based on dose model assumptions (including the expect ;h the site will be remediated) YAEC has identified the followinq 22 radiojINIM ntially contributing to the 3H, C 108mA 125 b 134 Cs 1dose 37 after 15 2 license 1 54 termination:

15 5 238 23 9 24 0 Fe, 2 4 1Co, 62 4 1 Sr, 243 cs, Eu. Eu. Eu, pu, pu, Pu, Pu, Am, c0 s.Atsrvdingly, these radionuclides would form the basis in plann condL 1 1status surveys,

.nd demonstratina comnliance with the site rel 3.1.2 Existing Hazardous and (

Chemical Use Over the YNPS plant's operating af- umbE rd* *materials or chemicals were used throughout the industrial area. S thes aterials

!anazai water treatment and other maintenance chemicals, fuel, lub g an isform* ils (including oils containing PCBs),

and chemicals used for the van reactor sdingboron, hydrazine, 1,1,1-trichloroethane, and trisodiuplF ;phate) some of the building structures and surfaces cogain asbestosAlI ntaini ir lead-based paint (ERM, 2004a).

is claslM a small quantity generator of hazardous hlation and Recovery Act (RCRA). However, YAEC is nerating over 1,000 kilograms of hazardous wastes per zardous and mixed wastes associated with gulates YAEC's hazardous waste generation and at the site must comply with MaGsihuse MDEP IE setts

, Contingency Plan (MCP) (310 CMR 40.0000), which 3 ~cleanup of oil and hazardous materials releases to soil or water

)EP Solid Waste Regulatons at 310 CMR 19.000, which regulate the ation of the SCFA and the review of beneficial reuse determination had intendsed to remediate onsite contamination to enable future use of ons, however deed restrictions will be utilized in the remediation of the Page The primary non-radiological contaminant of concern at the site is pol (PCBs). A release of PCB-containing paint chips from the vapor contc containment) into the Sherman Reservoir was discovered in the sprint migrated to the reservoir through the stormwater drainage system. I action was taken aF he paint chips to remediate some of the storm drain sediments. Addition leanu ongoing since 2001, including remediation of soils in landscaped areas Sherman Reservoir and western storm drainage ditch.

beare being remediated toth Gebetvof1..il and in Ssoi ens wI ments in the aso ... ,Ply withmeet the requirements of both the M and the Substances Control Act (TSCA)f parts-peFmillion generally to a level of lmilli rams/kil g.

under TSGA 7 YAEC has documented its PCB remedia m in twethree-reports prepared according to MCP requirements: Phase II Co Phase Ill Remedial Action Plan,,,t.&f detai*.and Phase IV Remedy Implementation Plan.

il Le Jite Assessment;-a-n4 ipation activities in more Massachusetts and Vermont public health agenc iss' ýd~lý"l due to the presence of mercury in fish from the Sherman Reservoir., ,epo o industrial activities is a likely source of the mercury fouM Additi

• f. PCBs were detected at trace levels in the tissues of fish in the vi orm 4,in Outfall. The source of the PCBs is likely the PCB-containinq pai hip c 19&ýIhe reservoir. The licensee is controlling any remaining PCB-contaigffa pain Wnronmental impact is expected. As discussed in Section 3.1AF YAEC mhe rof remediating the PCB-contaminated areas of the reservoir_ r the Ed Outfall (ERM, 2004a).

YAEC began an additional site - j larac ation of ils, groundwater, and sediments in 2003 and identified several are r furth dy. A rding to the June 2004 Site CharacterizationStatus Relp M, 20

• ndn anu**ary 2005 Phase II Comprehensive ntamnin l~water and sediment, as well as Site Assessent Rort, oil, wer that required further evaluation.

Groundi cussedl ion 3.3.2. Sediment impacts include PCBs, which " t estigations. Soil impacts include low levels of the followinq pacts near parking areas;- PCBs near the transformer yard;- dioxin rmer lead around the former shooting rangeT and beryllium near the ISFS Ii ischarge structure. YAEC will continue to work with the MDEP to f uir ad demonstrate that the entire site has been adequately characteriz he ecessary, according to MDEP regulations. When the site is releas om NR it will remain under state jurisdiction until all nonradiological contaM t'ion issues with the MDEP.

As lussed earlie r, mi buildings are being demolished to ground level, and some tsw v,"hp*t

)e remediated to meet Fuel Pool/Ion the DCGLs Exchange Pit, before they are or SPF/IXP) willperforated be removed to eu-My. Basement backfill the basements and other holes.

will be used to fn~ate groundwat elserw. Soils emolition debris generated from dismantlement activities may be used mate passes the final status survey or contains no detectable contamination.

te demolition debris would 4-ey will be conducted under a Beneficial Use D) permit from MDEP, which will include a deed restriction and compliance Page with MDEP and MDPH requirements for such reuse.wth the approval of theC Rwealth- I Macs~ahusetts.

3.2 Land Use YNPS industrial and administrative operations are condu ap 15 acres of land, primarily owned by YAEC but also including prope ned by liscussedi Section 3.1. The USGen property, consisting of a seg t that extco lentire ,,

eastern bank of the Sherman Reservoir, is subject to 01 Gra Con Dn issued by the Massachusetts Department of Environm I Man ment. U ad to restrict future uses of its property for preservation p s cept as nece operation of its hydroelectric power plant (ERM, 2004 Approximately 87 acres of the site is dedicated to the lo age (about 2 0 years) of spent fuel and other high-level radioactive waste in the . llatoon ISFSI consists of a concrete pad within a fence and a buffe qea vveter rad ius.

Transmission lines and two public roads traverse north-south direction approximately 1500 feet elant, l6vest, rL rL  ! river.

boro Road Monroeruns Hillin a Road is approximately 2500 feet from the Pi l in a north-south direction between the towns of Rowe and oe Some farms and a few commercial site le loca- s ing area. There are no exclusively commercial areas within fiv iles ofA site ly industrial property in the area is the adjacent USGen hydroe 3ciated powerhouses that are situated near the Sherman and ot r */servofalong th eerfield River. The nearest highway and railroad right-of-way are eacot c ted a t five m south of the site. Several public lands and conservation areas a cat ed A n five rJi of the site (YAEC, 1999, 2004a). The river is used for recreation apd I fis *hii ir producing hydroelectric power.

divided into surface water and groundwater. The following haracteristics of each within and around the YNPS site.

rin its immediate vicinity include the Deerfield River, W .tl ok and an associated tributary, a divertment from Wheeler an the stormwater drainage systems for the eastern and western al a. Wheeler Brook and its tributaries flow about 400 to 500 feet a around the south and east sides of the site before Wheeler Brook Reservoir (Framatome, 2003).

s formed by darwming the installation of (Sherman Dam) on the Deerfield is approximately two miles long, a quarter mile wide, and up to 75 feet Page deep along its central channel (Framatome, 2003). The discharge canal, which harges into the Sherman Reservoir, was constructed to receive return water from tje plant'1 ling water processes. r L Stormwater at the site flows into two systems, the East SF Drain id the West Storm Drain System, draining the eastern and westernsh respectively. The East Storm Drain System dischargej pre Sherm while the West Storm Drain System discharges to the Deerfield r. StormT oindeveloj uplands is captured by the Wheeler Brook Divertment. ie diverthe Brook, which flows into the Sherman Reservoir. ,

Wetlands on the site are located in several areas andI rder water bodclWh as the Sherman Reservoir, Deerfield River, Wheeler Brook, a ted tributaries. Additional wetland areas were identified in the two stormwater deti ls at the site. Some isolated wetlands exist in the southern part of the site. Wetland W delineated in an Abbreviated Notice of Resource Area Delineation (WEl h was approved by the Town of Rowe Conservation Commission in March 20Z, Wastewater Discharges During the plant operation, stormwater, see k onjiooling water were discharged as wastewaters through seve Itfalls 'eervoir and the West Storm Drain System (to the river). Curr y, stor* d astewaters from the laboratory or from decommissioning a tiE.s ard ;cha ughtree remaining outfalls.

Discharges are approved under a N al I permit issued iointly by the MDEP d PA lichusets specific limits for pH, oil and grease, suspended solids, a -..

,_-4 d also 5ires the maintenance of a Stormwater Pollution Preventio n (ERM 04b)._ se discharges are also monitored and treated for radiological paramef N a d otocols and requirements.

tewAte stewater g syst nd stores wastewaters received from the radioacýt Ltory s rge lin, water is treated and then batch-discharged.

Discha A temporq ugh the treatment plant or through the stormwater drainage *,cove cwas National PollutiOn Discharge El..imation System NPDES per system will be dismantled and disposed of off-site as radioactive w The auxili em leing used to supply water from the Sherman Reservoir to support smantling activities. The system will be dismantled once it is no I*(YAEC, 2004a).

longer j ded for the!

Wral associated leach fields have been used at the YNPS site.

T ach fields raeptic are lo(% ýItenerally on the western portion of the site. Three of these leach systems fio have been in use ice 1978, when two formerly-used leach fields were abandoned in Page Aquifers and Geology)

A The groundwater system at the YNPS site is a product of the geology, the petrology and hydraulic conductivity of the rocks, the glacial history, the geomoj and the hydrology of this area. The YNPS site is located on the ea ide of iire Mountains predominantly on a terrace of the Deerfield River. The te is re the east side of a two mile wide glacially-derived river valley where the v alls ris 0 feet above the river elevation. The YNPS plant is adjacent damme keerfield,/

River, Sherman Dam and Sherman Reservoir. The lo gradient Deerfield River is 28.4 feet/mile over a river distance out 3 es from fl der at the Sherman Pond to the West Deerfield, Massach ing s tation (I 2003).

The local groundwater system is extremely complex, wit ndwater-bearing units, from top to bottom: -the-stratified drift, glaciolacustrine, andli stratified drift unit contains permeable surficial sands and gravels,10 to 20 feet tl ,th -laid, ice-contact deposits derived from a melting glacier. The glaciolac strine u s sediments about up to 260 feet thick of glaciolacustrine origin, con -with m ely thin water-bearing units of fine to medium-grained sand within relativel im ermeable fine- rained s he be unit is a gray, medium-grained, moderately foliated metamorphic at lainterspersed amounts of megacrystals of plagioclase feldspar albi his b r member of the Lower Cambrian Hoosac Formation, which is r ively ca pe fractures (YAEC, 2004e).

Contamination and Monitoring As discussed in Section 3.1.2, N *iegan itional -wide characterization of groundwater in 2003 and identif Ieveral as for f er study. According to the June 2004 Site CharacterizationStatus R vt(ERM C), adiological contamination in groundwater nd sedimen IIas Ioc of contaminated soil, were identified that required fl evaluati adiolog water contaminants identified were found f 1,1- u Mgesl *sence of a plume. These contaminants to be inj reas include n PCBs, and petroleum hydrocarbons. YAEC will continue the MDEP to fulfill MCP requirements and demonstrate that ground ieena aracterized and remediated where necessary.

Radiological onitoq he YNPS site (excluding monitoring for the Radiologic3 onitoM' Program) has occurred since the plant shut down in 1992. C l naonitoring wells are in operation throughout the site.

These itoriq wel Is' led in stages, as follows: two in the late 1970s, 15 in 1993-94, 21 om 1997 thrc)Und 17 during the summer of 2003, with 14 of the older wells abandoned du omissioninq (demolition) activities. Most of the wells that were ad prior to 200~ a lo ated in the RCA, although a few are either downgradient or Jient of the RC A. 11of the wells installed before 2003 except one are shallow, ranging in from 7 to 31 fe elow the land surface. The exception is a 49-foot bedrock monitoring the RCA.Th onitoring wells installed during the summer of 2003 contain wells 6ed as folio~ ree in the stratified drift unit, seven in the glaciolacustrine unit, and unit.

Page Groundwater samples have been collected for radiological analysis sir 19 1. 1'til 2003, YAEC analyzed the groundwater from wells existing before that time s *'tritium, gross alpha, gross beta, and gamma spectroscopy. The analytical results f/ !amples (i.e.,

groundwater samples from monitoring wells screened primIy in thj drift unit) indicated that only tritium was present above the minimur*ction,. *l*in. The larget tritium concentrations were observed in wells located neA lmediately nt of the spent fuel pit and ion exchange pit (SFP/IXP). ff '

In 2003, YAEC made several changes to improve site 'acteri*An and~

analytical procedures:

1. During the summer of 2003, YAEC installed 17 mor as mentioned above, to characterize the glaciolacustrine and bedrock units m atly. YAEC is installing installed additional monitoring wells in 2004 and m* Lore if needed as required by MDEP to improve its characterization of these 4 ater at the site.

2. YAEC began quarterly sampling events in in 2004 Pampling procedures by measuring the groundwater levels in all owells cit v hours before any water samples were collected. YAEC ha d0to cc the water samples from the monitoring wells over a shorten

3. YAEC improved and explained its Wytical 3 analyzing for the radionuclides of ern at ble 2-6 of the LTP lists the radionuclides of concern (or see )n 3. F ).YI'JI In A and November ndwater2003, samplesYAEC by conducted analyses for these *i )fconcer, and for Mn-54. Tritium was the only plant-generated radionuclide vas d --d in sýd les from the July and November 2003 events.

The largest im conceni rica at the YNPS site was groundwater flowing froA erman which is downgradient from the Sherman Dam anglm . G~roundwater from Sherman Spring had a n f 7o JeE.rfie tritium S )Curies/liter (pCi/L in December 1965. The tritium contaminq rted repaired in nin a stainless-steel liner was installed. Tritium levels in groundwater q have steadily decreased over time and have been non-detectaL rrounds.-

Tritium c space the s Otime througl drogeologic units at the site. The tritium plume extends from hiQ*

area at the tritium concent tritiM concentrations %

h Sresent owards Sherman Spring and the Deerfield River, with the uly iand Novemberdowncqradient immediately 2003, sampling events of the are variable SPF/IXP.The pproximately 2,000 pCi/L in the stratified drift unit, 45,000,pCi/L in by maximum ciolacustrine uni id 6,000 pCi/L in the bedrock unit.

an I Page Potential human health hazards associated with the YNPS site range from poter exposure to very low levels of radioactivity in soils and groundwater, to limited area offrelat high levels of radioactivity within the remaining portions of the ctm --- ad reactor support structures and systems.

The intent of the final decommissioning activity at the s al contamination at the site to meet NRC's unrestricted re F"criteria. ieet the criteria of the MDPH and MDEP. After decommissionir ctivities aj iense I releas termination activities will verify adequacy of the radioloj the final status survey. Unrestricted use of the site is ed in ,rl FR 20.

A site will be considered acceptable for unrestrictel residual radiba'W hat is distinguishable from background radiation results - [total effective dose equivalent] to an average member of the critical groi not exceed 25 mrem

[millirem] (0.25 mSv) [milliSievert] per year, includi ndwater sources of drinking water, and that the residual radioactivity to levels that are as low as reasonably achievable (ALARA)....

As planned, the 0.25 mSv/yr (25 mrem/yr) T ay limit e achieved at the site through the application of DCGLs used to m auuacy o

• 'igenerating ediation activities. The DCGLs in use at the YNPS site were calcu mo dels sed on guidance provided in NUREG/CR-5512, Volumes 1 ar Id 7, and the thecomputer DCGLs.codes RESRAD Version 6.21 and RESRAD-B E erc These dose models translate residual ioýacti' vatnto P( aradiation doses to the public, based on select land-use scenarios os hways, identified critical groups. A critical group is defined as the group of " als onably e eycted to receive the greatest exposure to residual radioactiviity the Bmption a given scenario. Such scenarios and their associated modeling esigneA overesta e, rather than underestimate, potential dose. A YAEC I to E ollow M M.qical site criteria of the Commonwealth of Massa( mr/) rubblA on-site as fill; 10 mr/yr for the entire site; and the risk L(Cun ).qicaland non-radiological risk as determined by a Risk to 4.0 ENV 4.1 Land YAEC state* federal goverr all of theentities on-profit property forassociated conservation withpurposes.

the YNPSYAEC site tohas local, Ps antoAmericai ped releasd I ~ *itle Association survey to document the site's legal boundaries.

Idn ition, natural and It al resources inventories and management plans have been

-oc ,ped. The mana( ent plans specify the obligations necessary to preserve the site for rvation (YAEC, A )4b).

ion of tl

• EC license is not reasonably expected to result in any adverse impacts to land use. Soils not meeting the radiological criteria for license termination Page will be removed and disposed of at a licensed facility as low-level radioactive wa Initially, most of the YAEC-owned property would be released, except for appro imately containing the spent fuel storage facility and associated buffer zone. t ac §e would be cility is decommissioned. r n heavily, expected to to the site is area. op o i directly adjacent Recre

• nal Land on and in the surrounding increase.

communities populated River will likely continue and could lightly Deerfield I by the it will requir MDEP Solid Was of site other restriction required by the indus the The deed any use of the former appro by the MDEP for excavations in that area.

yal pen and will prohibit pasive recreation, 4.2 Water Resources Approval of the LTP and eventual termination of the lie'nse arq to result in any

• significant impacts to either surface water or grouJ r. The tion release criteria must be met as a condition of license te_ nd rele site.

4.2.1 Surface Water Land areas from which precipitation rui to sL investigation, remediation where necei nry E iefee final urvey. YAECtowill subject need to further verify that DCGLs have been met i ordar !i ithth Sec n of the LTP, thus demonstrating compliance with the release criteri ther. EC will d to demonstrate compliance with the MCP surface water requirem 5rlt nradiol cal and radiological contaminants.

YAEC's future license terminati so wo be e cted to result in any adverse impact to surface water flow or quality a tchs disi ase along with other license termination ,ptivities.

ount oflleW ious area will be reduced by about 8unaltered acres tation of areas the currently occupied stormwater drainagesroads, and by buildings, current

~n sto leave s that have formed in the drainages. Drainage pipes continue as sheet flow from the drainages into water maining septic systems (discussed in Section 3.3.1) for stemregulations em (upqradient supply before thewell) and sewage property system will remain title is transferred.

have been installed and monitored in the vicinity of the site are being conducted on or near wetlands resources. YAEC has o Permit Package to address the regulatory requirements applicable to

!2004d). The activities requiring wetlands-related permits include PCB nissioning of circulating water intake and discharge structures, removal of Page the Southeast Construction Fill Area, implementation of Sherman Dam flood coi and regrading of the site. Additionally, a wetlands restoration plan has keen de* ped (Woodlot, 2004) to implement the permit requirements. Further inforrr pncj eerningmeasures, wetlands activities can be found in the Integrated Permit Package anIn and Restoration and Replication Plan (Woodlot, 2004). k 'AA YAEC samples three surface water sites for its Radiolo FEnvironr ,ring Progr (REMP) at the YNPS site. The Deerfield River is sam downstr~ 9NPS siteA Bear Swamp Lower Reservoir with an automatic samp VnI y LV va.U1 10.

• VJ W composited for each month. YAEC also collects mont 0le17s from and from an upstream Deerfield River site at the Harri oir. Sample

• ree sites are analyzed for gamma emitting radionuclides, t gross beta. Thl m and Laer samples contained gamma spectroscopy results for 2003 indicated that no detectable levels of plant-generated radionuclides. Also beta averages for 2003 were slightly greater at the upstream Deerfield River sij ownstream site (YAEC, 2004d). Based upon these recent data, YAEC states aters do not require remediation pertaining to plant-generated radionuclides.

4.2.2 Groundwater YAEC states that remediation will not lil, ,qu *und 5r at the YNPS site to meet NRC's license termination criteria Iuse HH- cted to meet NRC's unrestricted release criteria when the si rele,a ( SI is decommissioned and the license terminated). If decommiss' es at t S site increase the concentrations of plant-generated r issolve e groundwater, the monitoring program at this site should detect nang uroundw r samples from approximately 55the existing 39 monitoring wells sho Iicate iges in groundwater downgradient from the radiologically-controlled area. use soj onitor wells may-be have been abandoned during decommissioning, ne itorir eed to be installed to meet MDEP requiremen~kto characteri ntial c hig evel of plant-generated radionuclides dissolved g cround Ground1 site uired to meet the dose-based radiological criteria of the MDPH ar MDEP V Risk Assessment process (for both radioloaical and non-i 4.3 Human

=1.'*

Comp 2 for unrestricted release (and, therefore, human health protec:re**Iuemen* ent upon successful remediation and/or removal of contj ated soil, grou ncillary contaminated materials, and structures to acceptable lev Icorresponding t( dose of 0.25 mSv/yr (25 mrem/yr) or less per year) to an av e member of the il group. In addition, residual radioactivity must meet the ALARA ements of the rull in Sec. 3. FAEC has also agreed to meet the more restrictive radiologic release the MDDDD id the MDEP.

Page Derived Concentration Guideline Levels YAEC has defined levels of residual radioactivity for various sources Fat correspond to meeting the dose limit. These acceptable levels are defined as thE F Potential radiation doses for the bounding exposure scenarios are ch lated ng an average fixed concentration level for each of the potential sources idua]l

'LY. The sources are soil, building surfaces, subsurface partial structures, concretE groups were identified to whom the DCGLs would be a cable: a fjl o critical tfarmer group (associated with soil, building surfaces, subsurfE partial O sources) and a building occupancy group (associated the. buffin g surfa The DCGLs for each source were derived using the ral ses per unit actiqW a.

separate dose constraint for each source. Table 4-1 li, sGLs for each radionuclide from each source. Within each critical group, each DCGL w, correspond to a fraction of the 0.25 mSv/yr (25 mrem/yr) dose limit so that the ftr (average member of that group from all sources would equal the limit. J For the resident farmer critical group, the doses c inding tb ind totaling 25 mrem/yr) are: e

• groundwater: 0.0077 subsurface partial structures: 0.005mr mSv/yr (0.77 m yr).(0. V concrete debris and soil: 0.2373 mS r (23.7 re In areas that have co-mingled soil oncr t ebris, Y would use the smaller of the two DCGLs for each radionuclide (see b 4-1) d for ar with only soil, YAEC would use the soil DCGLs.

For the building occupancy riti group, wo ake a sum-of-fractions approach to ensure that, a member o lic wer ber of the building occupancy critical group an esident f ical gro aI dose would be less than 0.25 mSv/yr (25 mrem/y/

Any actu uld like less than the 0.25 mSv/yr (25 mrem/yr) limit. This is due to the c -ilingand the assumption that the entire source would have residual ah t is more likely that the sources will have residual radioactivity at ss DCGLs.) Provided compliance with the 10 CFR 20.1402 Iithrou the results of the final status survey, there would be no anticipat vere uman health from approval of license termination, as described in the onmental i ent for license termination (NUREG-1496) (NRC, 1997a).

Ex re Scenarios T anner in which t DCGLs are derived for the YNPS site is documented in Chapter 6 of P, Revision 1. eriving the DCGLs, an adult resident farmer is considered to represent erage membe the critical group. The hypothetical resident farmer is assumed to build on the co

• ated soil (or soil/concrete debris mix), draw water from a well placed m

• tiun , grow plant food and fodder on the contaminated area, raise livestock on Page the contaminated area, and catch fish from a pond on the contaminated area. T esident farmer scenario is considered the bounding scenario because it embod the test number of exposure pathways, represents the longest exposure durations, an lud e greatest number of sources, of all scenarios envisioned. The DCGLs are sho 4-1.

The NRC will evaluate the appropriateness of the postula posu and the methodology used for deriving the DCGLs as part of its w ofothe RC staffs Safety Evaluation Report will provide the details of this ew.

Survey Design YAEC would use a series of surveys, including the fin urvey, to demon compliance with the radiological release criteria consis e Multi-Agency Radiation Survey and Site Investigation Manual (NRC, 1997a). PI he final status survey involves an iterative process that requires appropriate n (on the basis of the potential residual radioactivity levels relative to the D s) lanning using the Data Quality Objective process. YAEC has committed to a integra hat would address the selection of appropriate survey and laboratory nentatio dures, including a statistically-based measurement and sampling iuating the data needed for the final status survey. YAEC ha t it be p ted to modify the classification levels based on new informat* urin mmis ning process.

/

I Page TABLE 4-1: DERIVED CONCENTRATION GUIDELINE LE LS

• To convert to Bq from pCi, multiply by 0.037.

Subsurface F Radionuclide Soil .p./g- Building Surface Partial Concrete Debi-s (pCilg (d Structures

( p C i/g)i . (pCi/g)

( dp__ _ _ _0 c m_)_

H-3:9.5E+o 1 (cellar holes) 3.5E+02 Q 3.4E+OS 1.35E+02 2.8E+02 (grading)

C-14 S.2E+00 1.0E+07 2.34E-+-03 7.2E÷00 Fe-55 2.SE+04 4.0E+07 1.4E+-02 Co-60 3.SE+00 I.SE+04 3.45E+03 4.3E--00 Ni-63 7.7E+02 3.7E+07 6.16E+04 1.OE+02 Sr-90 1.6E+00 1.4E+05 1.39E+01 7.6E-01 Nb-94 6.SE+00 2.6E+04 - 7.0E+00 Tc-99 1.3E+-Ol 1.4E+07 - 6.1E÷O1 Ag-10Sm 6.9E+00 2I5E+04 - 7.OE00 Sb-125 3.OE+01 1.OE+05 3.1E-0I Cs-134 4.7E+00 2.9E+04 - 4.7E-÷00 Cs-137 S.2E+00 6-3E+04 1..45E-03 6.7E÷00 Eu-152 9.5E+00 3.7E+04 - 9.5E-00 Eu- 154 9.OE+00 3.4E+04 - 9.1E +'00 Eu-155 3.SE+02 6.5E+05 - 3.8E÷02 Pu-238 3.1E+01 5-7E+03 - 9.5E-00 Pu-239 2.SE+01 5.1E+03 - S.8E00 Pu-241 9.3E+02 2.5E405 - 1.4E-'02 Am-241 2.SE+01 5.OE+03 - 4. 1E-00 CCm-243 3.OE+01 7.2E+03 4.7EO00 Represents a dose of 23.73 nuen,"yr Represenr.t a dose of 25 nueni"vr Represents a dose of 0.5 niemiyr, radicnuctides based upon those found in concrete samples as discussed in Reference 6-11 ENCIES M ERSONS CONSULTED AND SOURCES USED Page A copy of the Environmental Assessment was provided to the Commonwealth of Massachusetts on XX,.200-4. k The NRC staff have determined that the proposed action would not E endangered species or critical habitat designated under th ndangj Therefore, no consultation is required under Section 7 of daný Likewise, NRC staff have determined that the proposed n woul/

archaeological resources. Therefore, no consultation i quired urq National Historic Preservation Act.

6.0 CONCLUSION

/

The NRC has prepared this EA (ADAMS Accession No.:MLX (X)XXXXX) related to the issuance of a license amendment that would approve th NRC has concluded that there are no significant enviro and the proposed license amendment does not warrant the preparation an a Impact thebasis Statement.

of this EA, the Accordingly, it has been determined that a Finding of o Sign t is appropriate.

The documents related to this proposed action le for p ~ection and copying at NRC's Public Document Room at NRC H e Wh t North, 1555 Rockville Pike, Rockville, Maryland 20852. Most of t do ratilable for public review through our electronic reading room (AD htt ading-rm/adams.html.

7.0 LIST OF PREPARERS C. McKenney, Health Physicist, D" i of W e Mana e*nt, dose assessment.

J. Peckenpaugh, Hydrologist, D' on. of e Man ent , groundwater issues.

C. Schulteject Ma*na ion of ement and Environmental Protection, non-radiolj environ ues.

J. Thon I PI, on of Waste Management and Environmental Protection, Final St 8.0 LIST OF ALARA onablyhievable CFR if;ode Ne lRegulations DCGL derivedl on guideline limit dpm/ cm2 disintegr I'r minute per 100 square centimeters EA environn *issessment EP Environr Protection Agency F: - Federal gister survey ind it spent fuel storage installation kil termination plan Page MCP Massachusetts Contingency Plan MDEP Massachusetts Department of Environmental Protection MDPH Massachusetts Department of Public Health, Radiation mrem/ millirem per year mSv/yr milliSievert per year NEPA National Environmental Policy Act NRC Nuclear Regulatory Commission ORISE Oak Ridge Institute for Science and Edu on PCBs Polychlorinated biphenyls pCi/L picocurie per liter PSDAF post shutdown decommissioning activit o RCA Radiologically-controlled area RCRA Resource Conservation and Recovery A TEDE total effective dose equivalent TSCA Toxic Substances Control Act YAEC Yankee Atomic Electric Company YNPS Yankee Nuclear Power Station

9.0 REFERENCES

10 CFR 20. Code of Federal Regulations, I U, for protection against radiation."

10 CFR 50. Code of Federal Re ulati

,Title "Domestic licensing of production and utilization facilities."

10 CFR 51. Code of Federal Re ns, T 10, E ,, Part 51, "Environmental protection regulations for domestic licensirjld rela tlegulal inctions."

61 FR 392- "Decomrr of Nuc ýactors." FederalRegister. July 29, 1996. A 62 FR I ic Ifor License Termination. Final Rule." FederalRegister.

July 21, 64 FR 68005. Review." FederalRegister. December 6,1999.

Evans et a d AcI!tion Products in Reactor Materials," NUREG/CR-3474.

August 121 gulatory Commission, Washington, D.C.

ERMIJ04a. "Baselini ental Report," April 30, 2004. Environmental Resources Ma rgmement, Boston, IE usetts.

E 2004b, "Expand lEnvironmental Notification Form," March 31, 2004. Environmental Furces Managemj Boston, Massachusetts.

4c, "Sit raracterization Status Report," June 4, 2004. Environmental Resources i,Massachusetts.

Page ERM, 2004d, "Integrated Permit Package, Yankee Nuclear Power 2004.

Environmental Resources Management, Boston, Massachusetts.

Kennedy and Strenge, 1992. "Residual Radioactive Conta atior nmissioning."

NUREG/CR-5512, Volume 1. October 1992. U.S. Nucle ulý ;sion, Washington, D.C.

Kleinschmidt, 2004. "Post-Decommissioning Grading and St 7Avater Analysis," August 2004. Kleinschmidt Energy and Wa Resou Consult MASS, 2004. "Certificate of the Secretary of Environ ir,s on the ExparI Environmental Notification Form," May 7, 2004, Massa u r (ecutive Office of Environmental Affairs, Boston, Massachusetts.

MHC, 2003. Letter, Massachusetts Historical Comm' on to inkee Nuclear Power Station Decommissioning, Rowe; MHC#33426," date August NRC, 1988. "Final Generic Environmental Imr nt on thl Irnmissioning of Nuclear Facilities." August 1988. U.S. Nucl9111 L*Com mis Washington, D.C.

NRC, 1997a. "Generic Environmental Irr Mnt Stý bf Rulemaking on Radiological Criteria for License Termini n of I* ýar Facilities." NUREG-1496. July 1997. U.S. Nuclear Regulgo y Comj n, D.C.

NRC, 1997b. "Multi-Agency Rad Survef!id Site 5stigation Manual (MARSSIM)."

NUREG-1575. December 1997., 'NuclgffRegulat' Commission, Washington, D.C.

NRC, 2002. "Generic Environr tal Iml Fon the Decommissioning of Nuclear Facilities. S~p plement De* h Dec( of Nuclear Power Reactors." November 2002. NU*k-0586, S1 1, U.S ulatory Commission, Washington, D.C.

ecommissioning Guidance," NUREG-1757. September be (Rowe) Nuclear Power Station -- Request for ination Plan," dated June 16, 2004.

nnaissance Survey, Archeological Resources Management

~ion," November, 2003. Public Archeology Laboratory, Inc.,

0 Safety and Costs of Decommissioning a Reference or Power Station." NUREG/CR-0130. June 1978. U.S. Nuclear Washington, D.C.

Page Woodlot, 2004. "Yankee Nuclear Power Station Site Closure Project Wetland R iration and Replication Plan," August 2004. Woodlot Alternatives, Inc., Topsham, aine, Environmental Resources Management, Boston, Massachusetts.

YAEC, 1993. "YNPS Decommissioning Environmental Re "De 99 Yankee Atomic Electric Company, Rowe, Massachusetts.

YAEC, 2000. "Post Shutdown Decommissioning Activi Report," e, from the YNPS Final Safety Analysis Report, Yankee ic Elec om Massachusetts.

YAEC, 2003. "YNPS License Termination Plan," Revi ovember 24, 200 Atomic Electric Company, Rowe, Massachusetts.

YAEC, 2004a. "YNPS License Termination Plan," Draf ptember 2,2004, Yankee Atomic Electric Company, Rowe, Massachus . 3 YAEC, 2004b. "Site Closure Project Plan," RevMarch 3 nkee Atomic Electric Company, Rowe, Massachusetts.

YAEC, 2004c. "YNPS Historical Site ) )04, 'Wikee Atomic Electric Company, Rowe, Massachusetts.

YAEC, 2004d. "Annual Radiological Fronmeg[ Opei )ort," Yankee Rowe Station Radiological Environmental Monitor' 'rogra rffJanuar - December 31, 2003.

Yankee Atomic Electric Company ., Ma§Vchusetts YAEC, 2004e. "Hydrogeologic 5 )rt of Supp al Investigation" March 15, 2004.

Yankee Atomic Electric Conmpa HR owe, rminati r'evision 1, November 19, 2004, Yankee Olassa ML043240450 Data Collection for YNPS Decommissioning," Rev 1.

L Marlborough, Massachusetts.

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