ML083240377

From kanterella
Jump to navigation Jump to search
State of Ma, Dept. of Environmental Protection, Review of Final Phase II - Comprehensive Site Assessment Report for Environmental Assessment of Yankee Nuclear Power Station in Rowe
ML083240377
Person / Time
Site: Yankee Rowe
Issue date: 10/16/2008
From: Gorski M
State of MA, Dept of Environmental Protection
To: Norton W
Office of Nuclear Material Safety and Safeguards, Yankee Atomic Electric Co
References
Rowe-BWSC-RTN#1-13411..
Download: ML083240377 (19)
v • d • e


Text

- ' ... COMMONWEALTH OF MASSACHUSETTS r 2-3 EXECUTIVE OFFICE OF ENERGY & ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION WESTERN REGIONAL OFFICE.

436 Dwight Street

  • Springfield, Massachusetts 01103 * (413) 784-1100 DEVAL L. PATRICK IAN A. BOWLES Governor . Secretary TIMOTHY P. MURRAY LAURIE BURT Lieutenant Governor Commissioner October, 16, 2008 Yankee Atomic Electric Company 49 Yankee Road -

Rowe, MA 01367 Attention: Wayne Norton, President RE: Rowe-BWSC-RTN#1-13411..

Phase HI- Comprehensive Site Assessment Report.

- Final Report - Review 310,CMR.40O0000".. .

YankeeNuclear Power Station 49 Yankee Road

Dear Mr. Bourassa:

The Massachusetts Department of Enviromnental Protection-(the MassDEP) has completed review of the Final Phase 1I - Comprehensive Site Assessment (Phase II) Report for environmental assessment of the Yankee Nuclear Power Station (YNPS) in Rowve, MA, according to the MassDEP's Bureau of Waste Site Cleanup (BWSC) regulations at 310 CMR 40.000 (the Massachusetts Contingency, Plan, or, theMCP)ý* The

- MassDEP's approval of this Final Phase Ii Report, asdescribed below, represents the final approval necessary to achieve site closure under theMassachusetts Contingency Plan. The Final-Phase II Report consists of a number of individual reports, sub'mitted on behalf of Yankee Atomic Electric Company .

(Yankee) by its consultants to satisfy the requirements of the MassDEP's October 7, '2005 review0of the Interim Phase l1 Report (the Interim Phase HlReview). The primary environmental consultant for the Final Phase Ii reports wasERM; Inc. of Boston, MA, and the Licensed Site Professionals (LSPs) of record for these reports were JohnMcTigue and GreggDemers of ERM.

  • . YNPS was shut down in 1992 and has undergone decommissioning in accordance with Nuclear Regulatory Commission (NRC) regulations under 10 CFR Part 50. All radiological issues associated with decommissioning fall under the authority of.the NRC, the Massachusetts Department of Public Health's Radiation Control Program (the MADPH), the MassDEP and the United States Environmental Protection Agency (the EPA), as applicable. The NRC-issued onAugust 10,,2007. a partial release of the YNPS License Termination Plan (LTP) for all areas of the YNPS site except the Thdependent Spent Fuel Storage

-Installation (ISFSI). The MADPH issued its partial release approval t6 YNPS on March 14, 2008.

This information is available in alternate format. Call Donald M. Gomes, ADA Coordinator at 617-556-1057.'TDD# 866-539-7622 or 617-574-6868.

DEP on the World Wide Web: http://www.mass.gov/dep "

Printed qonRecycled Paper

. Yankee Atomic - Final Phase II Report Review Page2 of.9 Non-radiological contamination at the site falls under the authority of the MassDEP and the EPA, as applicable. The assessment and remediation of polychlorinated biphenyls (PCBs) at the YNPS was primarily performed according to the authority and oversight of the EPA, in accordance with EPA Toxic Substance Control Act (TSCA) requirements and approvals. The EPA approval letter for the PCB remediation was issued to Yankee on April 26, 2006, and the required PCB Remediation Certification statement was completed by Yankee on.March 28, 2007:'The MassDEP had previously classified the YNPS site as a.Tier 1B site, according to the BWSC regulations at 310 CMR 40.000..

The Final Phase II Report contains the results of assessment for both radiological and non-radiological parameters at the site. All assessment and remedial actions at the YNPS site have at this point been' completed (with the exception .ofthe ISFSI utilized for slIent fuel storage, which is not within MassDEP authority). Yankee completed cumulative (radiological and non-radiological) Human Health and Ecological Stage II Risk Assessments (theRisk Assessment),for the YNPS site, according to MOP regulations and requirements, following remedial actions. As agreed to by the MassDEP, the Phase 11 investigation and

  • Report were completed within the context of the MCP for the purposes of site closure, but not as a formal Release Tracking Number (RTN) for the entire site. The MassDEP is issuing this Review of the Final Phase I! Report according to its authority under M.G.L. c. 2 1E and the regulations promulgated thereunder at 310 CMR 40.000..

The Final Phase II Reports submitted by Yankee in response to MassDEP's Interim Phase 11 Review

-included the reports outlined below (note that all documents associated with the YNPS site are public information and may be viewed or copied at the MassDEP Regional Office in Springfield, MA, or at the Yankee Public Document Repositoiy in Greenfield, MA)..... - - -

- Groundwater Monitoring Plan to Support Closure tinder the Massachusetts Contingency Plan, dated September 1, 2006;,

o Supplemental Phase HIComprehensive Site Assessment Report, dated September 21,.2006, by ERM, Inc.; -.

  • Human Health Risk Assessment Work Plan & Environmental Risk Characterization Work Plan, dated September 11, 2006, byGradient Corp.;

o Revised Beneficial Use Determination (BUD) for Structures, dated November 6, 2006, by ERM, Inc.;

o Addendum to the Phase II Comprehensive Site Assessment Report, dated February 6, 2007, bý:

ERM, Inc.;

o Method 3 Risk Characterization, dated November 2007, by Gradient Corp.;

  • Response Action Outcome Statements, RTN 1-13411; dated February 25,2008 by'ERM, Inc.;-and o Post-Closure Maintenance and Monitoring Report, dated May 6, 2008 by MACTEC, Inc.

On June 9, 2007, MassDEP issued to Yankee the Revised Beneficial* Use Determination (BUD) Permit approval (the BUD Permit) regarding the disposition of on-site structures and fill material within the historical Industrial Area of the plant site. As required, Yankee submitted to MassDEP a Groundwater Monitoring Plan, which was approved by MassDEP on June 19, 2007 (copy of approval attached).

The YNPS sitemwas divided into three land areas for the purposes of assessment and remediation. These areas are:

9 The Radiologically Controlled Area (RCA), which is approximately a 4-acre parcel immediately surrounding the former operating nuclear plant area;,.

o The Industrial Area, which is approximately a 13-acre parcel immediately surrounding the RCA, within the previous YNPS plant fence line, which formerly contained industrial structures

Yankee Atomic Final Phase II Report Review Page 3of 9 associated with the plant; and The Non-Industrial Area, which is that portion of YNPS property outside the fenced Industrial Area, containing woodlands, roadways, etc., which encompasses approximately 1,783 acres, including surface water bodies adjacent to and downstreamn from YNPS site. The Southeast Construction Fill Area (SCFA).is just outside the previous Industrial*Area, and has been assessed and remediated according to separate permit approvalsfrom the MassDEP's Solid Waste Section.

The Interim Phase II Review contained a detailed summary of environmental assessment work performed as part of the Interim Phase 1I Report - that summary will not be repeated inthis Review;howevera copy of the Interim Phase AI Review is attached for reference.. This Final Phase II Review will not-sunmarize in detail the additional assessment results, but will address whether-the requirements of the Interim Phase II review have been satisfactorily c.omnpleted, for each' of the environmental media assessed at:the-site. For each of the following review sections, the applicable conditions of the Interim Phase II Report requirements are listed.

L1 Final Phase Ii Report - General (Interim Ph. II Condition 14)

The cumulative Final PhaseII Report contained the following information, as required:

o Summaries of additional assessment work, including analytical data (non-radiological and radiological) in tabular form, with appropriate standards:or criteria for each media shown (for reference purposes); -... .... . . - ... ...

Updated basemaps,depicting the locations of soil sampling locations; groundwater monitoring wells,.suiface water and sediment sampling locations, and fish sampling locations;

  • Groundwater contour maps of the Industrial Area and immediate vicinity, and updated maps of tritiunm concentrations inrgroundwater; C

contour maps of the top of bedrock, top of till, and top of glaciolacustrine unit;

- Contour maps of gross alpha and gross beta activity in site groundwater monitoring wells;

, Historic sumnaries of RadiologicalEnvironmental Monitoring Program'(REMP) monitoring ..

perfonred prior to 1971;..

The ASTM Phase I BWSC (21E) assessment report for the Non-Industrial Area of the Facility; and ."'

Cumulative (radiological and non-radiological) Human Health and Ecological Stage II Risk Assessments for the YNPS site, prepared in accordance with approved Scopes-of-Work (SOWs),

according to Mag§DEP regulations and requiiremients.

.-2. Soil -.Assessment (Interim Ph. 11 Conditions -2, 3, 4 &:6)

Decommissioning activities within the Industrial Area resulted in the removal of substantial volumes of soil

.(and demolition material, including concrete rubble) for proper disposal as radiological waste at permitted off-site disposal facilities, according to NRC requirements. Soil remediation was also completed for non-radiological parameters within' the Industrial Area, and 'in more'limited amounts in the Non-Industrial Area.

Confirmatory soil samples were obtained after remedial activities were completed.' As required in the.BUD' Permit, following assessment and soil removal, a 3-foot thick layer of clean soil was placed over the entire,

.3:5-acre BUD. Fill Area, which encompasses.the RCA at the center of the Industrial Area..

A total of approximately 2,700 soil samples have been obtained and analyzed for non-ridiological'

Yankee Atomic - Final Phase 1 Report Review' Page4of9-.

parameters as part of the assessment of the YNPS site. The soil sampling required by the Interim Phase II Review was completed, both within the Industrial Area and in the Non-Industrial Area. All of these additional soil samples were analyzed at a minimum for the standard non-radiological parameter list for the YNPS site (as approved by MassDEP), which consists of all samples being analyzed forvolatile organic compounds (VOCs) by EPA Method 8260 and the thirteen (13) Priority Pollutant metalsý bY EPA Method 601 0B, and selected additional samples being analyzed for various portions of the following parameter list:

0 Semi-volatile organic compounds (SVOCs) by EPA Method 8270;

  • Polychlorinated biphenyls (PCBs) by EPA Method 8082;.

o Extractable petroleum hydrocarbons/volatile petroleum hydrocarbons (EPH/VPH) by the MassDEP method;

  • Dioxins and furans;
  • Hydrazine;
  • Pesticides; and.
  • Herbicides by EPA Method 8151.,

The results of full radiological analyses for approximately 1,600 soil samples were utilized in the Risk Assessment review, including the specific additional soil sampling required by the Interim Phase 11 Review.

A large amount of additional radiological monitoring and assessment of soils (and other media) was

.performed at the YNPS -site to satisfy the NRC and MADPH requirements for the NRC License Partial Site.

Release ,as part of the Final Status Survey (FSS) for the, site.

All soil samples were analyzed for the presence ofradionuclides by gamma-spectroscopy, and as outlined in the LTPrequiremefits,'a minimum bf 5% of these samples were also analyzed for the Hard-To-Detect (HTD) radionuclides H-3 (tritium), Amn-241, C-14, Cn,243/244, Fe-55, Ni-63, Pu-238, Pu-239/240, Pu-241, .

Sr-90 and Tc-99. For all media samples, including soil, the radiological analyses by gamma spectroscopy at a minimum quantified the FSS list of radionuclides Ag-.108m, Cs§134, Cs-137,.Co-60, Eu-152, Eu-154, Eu-155 Nb-94 and Sb-125. The LTP states that these radionuclides are analyzed as part of the entire gamma spectroscopy library, and that if any other radionuclides were detected by. gamma spectroscopy above.

minimum detectable activities (MDAs), they would have been reported as part of these analyses.

Following remedial activities, the results of soil analyses (both radiological and non-radiological) do.

not exceed the risk criteria-of the Risk Assessment.

  • 3. Groundwater Assessment (Interim Ph. U Conditions 2,3, 4,.7, 8, 9 & 10) . .

A total of 83 groundwater monitoring wells have been installed and monitored at the site to date, including 22 wells installed in 2006. subsequent to (and, in part, in response to) the Interim Phase HIReview. Due to decommissioning activities, 26 monitoring wells have been properly abandoned in accordance with' MassDEP guidelines. Currently, there are a total of 57 monitoring wells ofnsite, consisting of shallow (water-table) wells, intermediate depth wells, and deep, bedrock wells. Groundwater flow maps show that groundwater flow beneath the previous Industrial Area is primarily towards the Deerfield River below Sherman Dam. (towards the vicinity of Sherman Spring), with some indication of a minor amount of deeper, radial flow towards Sherman Reservoir.

Groundwater samples were analyzed for the standard YNPS non-radiological parameter list, and the additional samples required in the Interim Phase II Review were also analyzed for boron, as required.

Several monitoring wells have historically shown limited exceedances of groundwater standards for non-radiological parameters, primarily for arsenic.

Yankee Atomic - Final Phase II Report Review,,

Page5of99 All groundwater samples were analyzed during at least four quarterly Phase II monitoring rounds for the presence of radionuclides by gamma spectroscopy, and also for the HTD radionuclides. All groundwater samples from all monitoring rounds were analyzed at a minimum for tritium, gross alpha and gross beta, and a significant number of selected monitoring wells have also been analyzed historically for the gamma spectroscopy and the HTD.parameter list.

The former Visitors' Center potable well was sampled and analyzed for'radiological analyses, and the results of the last two years of sampling and analysis of the YNPS Facility potable well were included in.the Final Phase II Report. The results showed no exceedances of any MA'Drinking Water Standards &

Guidelines (MCLs), and no detectable tritium or other planit-related radionuclides.

The Final Phase Il Report states that tritium continues to be the only plant-related radionuclide detected in groundwater at YNPS site. The source of the tritium contamination in ýgroundwater at the site was the result of a documented leak(s) in the former Spent Fuel Pool/Ion Exchange Pit: complex (SFP/IXP complex) Which began in the 1960s, within the center of the former Industrial Area/RCA. The tritium contamination in groundwater extends laterally downgradient from the former SFP/IXP complex location towards Sherman Spring and the Deerfield River, primarily in the shallow glaciolacustrine unit. The deeper tritium contamination is more limited in extent and concentrations, extending at depth into the sand layers within the glacial till and into bedrock in one well, MW-l105B. (within the former RCA), and extending laterally "

from the former SFP/IXP complex a shorter distance towards Sherman Reservoir.

The June 19, 2007 Post-Closure Groundwater Monitoring Plan approval issued to, Yankee by MassDEP.

requires continued sampling of 4 monitoring wells'and Sherman Spring:within aind downgradient ofthe.

BUD Area, during the post-closure monitoring period of 30 years and includes analyses for the radionuclides by gamma spectroscopy, Sr-90 and tritium. .Tritium-monitoring is also required at 2 additional site monitoring wells, non-radiological monitoring is required at 4 additional site monitoring wells, and 30-year postýclosure monitoring (radiological and non-radiological) is also required at 3 monitoring wells located at the SCFA.

During the most recent monitoring in March of 2008, tritium continued to.be detected in 8 of the site monitoring wells, with the highest tritium concentration of 25,700 picbCUries/liter (pCi/1) in well MW-;'

.107C, an intermediate-level well screened ata depth of 27 to 32 feet immediately downgradient of the former SFP/IXP complex location (this has decreased from a.concentration of 48,000 pCi/I in 2003 in this well). In 2008, tritium continued to be detected in bedrock monitoring well MW*1.05B, at.4,7.10.pCi/l

  • (equivalent to 2003 levels), while the water sample from Sherman Spring was non-detectable (ND) for tritium (decreased from previous levels).

The groundwater sample from well MW-107C continues to exceed the USEPA drinking water criteria (MCL) of 20,000 pCi/L. However, as required by the.BUD Permit, the recorded deed notification(s) for the BUD Area, which encompass this well location and the central area of groundwater tritium contamination, prohibits the installation or use of any water supply wells within the BUD Area. . Given the BUD Area deed restrictions and based on the remaining data outside the BUD Area, the results of groundwater analyses for both radiological and non-radiological parameters doinot exceed the risk criteria of the Risk Assessment.

S..Yankee Atomic 1 Final Phase II Report Review

.Page.6of9

4. Surface Water - Assessment (Interim Ph. 11 Conditions.2, 3, 4, & 11)

As part of the entire Phase II -Assessment, a total of 126 surface water samples were collected from the site and surrounding vicinity., with samples collected from upstream (background) locations, Sherman Reservoir, the Deerfield River, Sherman Spring, the East and West Storm Drain'Ditches, and in Wheeler

'Brook (as part of the SCFA assessment). Initial Phase It surface water samples were analyzed for the standard YNPS non-radiological paframneter list and for radionuclides by gamma spectroscOpy and for HTDs.

  • All of the additional surface water samples required in the Interim Phase UIReview were obtained as

'required and analyzed for the thirteen (13) Priority Pollutant metals plus lithium and boron, and for radionuclides by gamma spectroscopy plus tritium.

The additional surface water samples showed slightly elevated levels of some metals in Sherman Spring and the Deerfield River immediately downriver of the YNPS. Tritium was detected. in Sherman Spring and the West Storm Drain Ditch in 2006, The results of the surface wafer analyses for both radiological and

. non-radiological parameters do not exceed the risk'criteria of the Risk Assessment.

5. Sediment - Assessment (Interim Ph. II Conditions 2, 3, 4, & 11)

As part of the entire Phase II Assessment, a total of approximately 700 sediment samples were collected.

'from the site and surrounding vicinity, with samples generally collected from the same locations as surface water samples. Initial Phase 11 surface water samples were analyzed for the standard YNPS non-radiological parameter list and for radionuclidesby gamma spectroscopy and for HTDs; All of the additional.sedinment samples requ ired in the Interim Phase II ReViewý were.obtained as required and analyzed' for the thirteen (13) Priority Pollutant metals plus lithium, boron and total uranium, and for radionuclides by gamna spectroscopy plus HTDs.

As part of decomnissioning activities, PCB-contaminated sediments (from PCB-containing paints previously used at the YNPS) were remediated from Sherman Reservoir and the West Storm Drain Ditch in accordance with T.SCA approvals from the EPA, as noted previously. Confirmatory sediment samples were obtained from these areas after remediation.

  • Theadditional sediment samples showed slightly elevated levels of some metals and some radionuclides (including Cs-137) in Sherman Spring, the Deerfield River immediately downriver of the, YNPS, and in Sherman Reservoir near the Cooling WaterDischarge. Total uranium was slightly elevated in the Deerfield River immediatelydowlniver of the YNPS.. The results of the sediment analysesfor~b6thfi2adi~lbgical"'

and non-radiological parameters do not exceed. the risk criteria of the Risk Assessment.

6. Fish - Assessment (Interim Ph. II Conditions 2, 4, & 12)

Fish were collected in the Summer/Fall of 2006 from background locations upriver at Harriman Reservoir; two locations within Sherman Reservoir (the East Storm Drain Outfall near the YNPS facility, and the northern end of Sherman Reservoir); and the Deerfield River immediately downriver of the YNPS facility, upriver of the Monroe Bridge dam.. Fillets from the fish were analyzed for PCBs (both Aroclors and congeners), for radionuclidesby gamma spectroscopy, and for tritium.

-Fish samples from Sherman Reservoir showed slightly elevated levels of PCBs, relative to the background samples from Harriman Reservoir.' Fish samples from Sherman Reservoir showed

Yanke'eAtomic -`Final Phase II Report Review Page .7.f9 detectable, but very low-levels of tritium, while the background samples from Harriman Reservoir and the 'samples from the Deerfield River were non-detectable for tritium. The Final Phase II Report concludedthat the detectable levels of tritium were naturally-occurring and not related to YNPS plant operations. No other radionuclides were detected by gamma spectroscopy in the fish samples, except for.

naturally-occurring K-40. The results of the fish analyses for both radiological and non-radiologieal parameters do not exceed the risk criteria of the Risk Assessment.

6. Risk Assessment - Results (Interim Ph. II Conditions 13 & 14)

As required by the Phase II Interim Review, Yankee's consultant, Gradient Corp., submitted to MassDEP the Scopes-of-Work (SOWs) for cumulative (radiological and non-radiological) Human"Health and Ecological Stage II Risk Assessments (the Risk Assessment) for the YNPS site, accordingto the regulations, requirements and guidance as outlined in the MCP. The SOWs were approved by MassDEP's Office of Research &-Standards (ORS) on December 6, 2006.j-The completed-Method 3 Risk Chaifctefizatidn (the.'

Risk Assessment) for the YNPS was submitted to MassDEP on November 13,'2007. The Risk'Assessment concludes that the YNPS site meets the MassDEP's Risk Assessment standards for cumulative risk attributable to the site (radiological and non-radiological) of no more than 1 XP0- Excess :Lifetime Cancer Risk (ELCR) and no more than a Hazard Index (11) of 1.

USEPA/Region I provided assistance to MassDEP/ORS in-the review of the Risk Assessment. The ORS review of the Risk Assessment was issued on December 31., 2007 (copy attached). The ORS review memorandum states that the Risk Assessment is consistent with the risk assessment requirements of the MCP.

The NRC's August 10, 2007 Partial Site Release issued in accordance with the YNPS License Termination

  • Plan (LTP) concluded that the YNPS site meets the NRC approved Yankee Atomic Electric' Company's LTP/FSS standard of no more than 25 millirem/year (mrem/yr) total radiation dose above background, or Total Effective Dose Equivalent (TEDE) attributable to the site. The MADPH's March 14, 2008 partial site release approval concluded that the YNPS site meets the MADPH standard of no more than 10 mrem/yr TEDE attributable to the site. Neither of these approvals required the placement of the 3-foot Soil cover over the BUD Fill Area (the RCA) to meet these respective dose-based standards.

The MassDEP's approval of the Risk Assessment conclusions are contingent, in part, on the Deed Notifications (Activity and Use.Limitations; or.AULs) for the YNPS site, which contain the. following" requirements; (among others) for 30-year post'closure'maintenance aind lmonitoring by Yankee:'

  • The continued,maintenance of the three-foot layer of clean soil placed over the 3.5-acre BUD Fill Area in the central portion of the YNPS site, and the requirements for no excavations or other
  • invasive procedures within that soil layer;
  • The requirement that no potable water supply wells may be installed or used within:the BUD Area;

-and

  • The requirements for continued monitoring of the YNPS site, including the BUD Area and the SCFA. " .

'Yankee recorded the Deed Notification for the SCFA on October 3, 2007, ýand the Deed Notification for the YNPS portion of the BUD Area on February 1, 2008, and TransCanada recorded the Deed.

Notification for the TransCanada portion of,the BUD Area on June 27,2008. Yankee executed Financial Assurance Mechanisms (FAMs) for the BUD Area ori November 25, 200.7; and for the'SCFA on. .

February 11, 2008, consisting of letters-of-credit in the monetary amounts approved by MassDEP, for 30-

Yankee Atomic Final Phase Ii Report Review Page 8 of 9 year post-closure maintenance and monitoring costs. As noted previously, the MassDEP's June 19, 2007.

approval of the Groundwater Monitoring Plan requires long-term monitoring of the BUD Area and the SCFA.

UI. MASSDEP DETERMINATIONS Personnel of the MassDEP have reviewed the Final Phase ii Report for the YNPS in accordance with MGL

c. 2 1E, the regulations promulgated thereunder at 310 CMIR 40.0000 (the Massachusetts Contingency Plan, or the MCP), and applicable MassDEP policies and guidance. The MassDEP has determined that the Final Phase 11 Report is acceptable in accordance with MGL c: 21E and 310 CMR 40.0000, and that YNPS has achieved site closure under the MCP, subject to the conditions outlined below.
1. Yankee shall continue to comply with the requirements for post-closure maintenance and monitoring of -

the entire BUD Area (both the YNPS portion and the TransCanada portion of the BUD Afea), as outlined in the MassDEP's Revised BUD Permit Approval, dated June 9, 2007.

2. Yankee shall continue to comply with all of the stipulations contained within the Deed Notification for the YNPS portion of the BUD area, as recorded on February 1, 2008, at the Greenfield Registry of Deeds, Book 5455, Page 320.
3. Yankee shall continue to comply with all of the stipulations contained within the Deed Notification for the SCFA, as recorded on*October 3, 2007 at the Greenfield Registry of Deeds, Book 5401, Page 167.
4. Xanke shall, continue to comply i¢ith the requirements for post-closUre monitoring of the YNPS BUD-Area (including the portion of the BUD Area on the TransCanada property) and the SCFA, as outlined in the MassDEP's approval of the Groundwater Monitoring Plan dated June 19, 2007,*including the requirement for submittal of monitoring results to MassDEP within 45 days of the date of sampling. As outlined in the. attached ORS Risk Assessment review memo, the metal thallium shall be added to the analytical parameter list for sampling of Sherman Spring as part of post-closure monitoring.
5. Yankee shall continue to comply with the post-closure maintenance and monitoring requirements for the SCFA, as outlined in separate correspondence from MassDEP.
6. Yankee shall continue to comply with all other applicable local, state and federal regulations and.

requirements, including those of the NRC, EPA, MADPH, and the Rowe Conservation Commission.

7. Appropriate Health & Safety (H&S) measures shall be utilized for all post-closure maintenance and monitoring work at the YNPS.

MassDEP -is issuing this Final Report Review for.Public comment. In accordance with 310 CMIR 40.1400,*

Yankee shall publish a legal notice in a newspaper which circulates in the community of Rowe, which shall identify that the Final Report Review has been issued and which shall identify the 30-day public comment period. MassDEP will accept public comments on the Final Report Review for a period of 30 days following MassDEP's receipt of documentation that the legal notice has been published.

  • l
  • Yankee Atomic - Final Phase I1Report Review, Page 9 of 9 The MassDEP reserves the right to require additional investigatory or remedial work at the YNPS site, if continued monitoring results indicate such a need. If you should have any questions or comments regarding this correspondence please contact Larry Hanson (#413-755-2287) or David Howland (#413-755-2280) of this office.

Sincerely Mfhael J. Gorski Regional Director Yankeeph2final908 LH cc: Joe Bourassa - Yankee Atomic ElectricCompany Robert Mitchell - Yankee Atomic Electric Company John McTigue - ERM, Inc.

Rowe Board .of Selectmen Rowe Board of Health Michael Whalen, MA DPH 7 Radiation Control Program John Hickman - Nuclear Regulatory Commission Anna Symington, Tony Kurpaska - DEP/WERO/BWSC David Howland, Steven Ellis, Daniel Hall - DEP/WERO Nan.cy Bettinger, Carol Rowan -West - DEP/Boston/Office of Research& Standards Earnest Waterman, Kimberly Tisa, Mary Ballew, Philip Newkirk - EPA Franklin Regional Council of Governments Citizens Awareness Network Deborah Katz TransCanada.- William Taylor, Thomas Hwang, Esq.

COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENERGY'& ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION ONE WINTER STREET, BOSTON, MA 02108. 617-292-5500 -

DEVAL L. PATRICK IAN A. BOWLES Governor Secretary TIMOTHY P. MURRAY LAURIE BURT Lieutenant Governor Commissioner MEMORANDUM To: Larry Hanson, Project Manager David Howland, Regional Engineer ,! . VV Through: Carol Rowan West, Director, ORS

,From: Nancy Bettinger, ORS .

Date: December 31, 2007 3 JA 2'00g

Subject:

Method 3 Risk Characterization Former Yankee Nuclear Power Station Rowe, Massachusetts As requested, ORS has reviewed the revisions made to the Method 3 Risk Characterization for the formner Yankee Nuclear Power Station site in Rowe, Massachusetts. The revised Method 3 Risk Characterization was submitted to MassDEP by Gradient Corporation on behalf of Yankee Atomic Electric Company in response to ORS's August 24, 2007, comments on the June .2007 draft of the Method 3.Risk Characterization.

The risk assessment is comprehensive, clearly presented, and consistent with the risk assessment requirements of the MCP. Gradient has incorporated most of the recommendations. offered by ORS in our August 2007 memorandum., In ourview, the risk assessment is essentially complete.

For the record, however, ORS wishes to note the following:.

  • Where surface water concentrations of contaminants of concern exceed Massachusetts Surface Water Quality Standards, a condition of"no significant risk" does not exist by definition under the MCP. For toxics, the National Recommended Water Quality Criteria (NRWQCs) are cited as Massachusetts Surface Water Quality Standards. The Risk.

Characterization report acknowledges that the maximum detected leVels of some inorganics (cadmium, copper and lead) in WheelerBrook surface water do exceed the.

criteria (surface water standards), but it does not state explicitly that a condition of "no significant risk" does not exist in Wheeler Brook. The practical implication of a condition of significant risk in Wheeler Brook is that long term monitoring, which is already planned, will be needed to confirm that the sources of contamination to the Brook This information is available in alternate format. Call Donald M. Gomes, ADA Coordinator at 617-556-1057. TDD# 1-866-539-7622 or 1-617-574-6868.

MassDEP on the World Wide Web: http://www.mass.gov/dep.

-: "Printed on Recycled Paper

and thus to Sherman Reservoir have been eliminated, and that contaminant concentrations in surface water are decreasing as expected.-

  • . The maximum detected concentration of cadmium in Sherman Reservoirof 0.00009 mg/L slightly exceeds the hardness-adjusted surface water standard of 0.00008 mg/L.

This apparent exceedance may be insignificant by itself for two reasons: (1) The maximum detected concentration reported in Table 3-20 is the-same as the maximum Sherman Reservoir concentration; and (2) The absolute value of the exceedance is small.

Nevertheless, considering that the maximum is based on only three samples, additional monitoring may be warranted in order to evaluate whether exceedances persist.

  • The thallium concentration (0.003 mg/L) in the sample collected from Sherman Spring in the Deerfield River Study Area is significantly higher than the NRWQC for.protection of human health (0.00047, mg/1). Sherman Spring discharges to the Deerfield River. The human health-based surface water standard is not applicable to the Sherman Spring itself, which is not fishable. Nevertheless, additional monitoring in Sherman Spring mdy be prudent to ensure that contaminant.levels in the spring decrease as expected.

. In ORS's August 24, 2007 memorandum, the fourth bullet under the "Human Health" heading calls for a fuller description of uses and activities that will be prohibited by Activity and Use Limitations and other institutional controls applied in the vicinity of the site. This comment was not explicitly addressed in the November 2007 revision of the Method 3 Risk Characterization. Nevertheless, ORS understands that the activities of concern will be addressed in the AULs that are applied.

  • In ORS's August 24, 2007 memorandum, the sixteenth bullet under the "Human Health" heading notes, several typographical errors in the toxicity value fables. Most appear to have been corrected in the November 2007 revision. At least one error remains, but it will not affect-the outcome of the~risk assessment. . .

If you have any questions about this memorandum, please feel free to contact me at (617)556-1159 or at nancy.bettinger@state.ma.us.

'COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENERGY &ENVIRONMENTAL AFFAIRS'.

DEPARTMENT OF ENVIRONMENTAL PROTECTION WESTERN REGIONAL OFFICE

4. . 436 Dwight Street Springfeld, Massachusetts 01103 * (413) 784-1100 DEVAL L. PATRICK IAN A.-BOWLES Governor Secretary TIMOTHY P. MURRAY LAURIE'BURT Lieutenant Governor Commissioner

-OCT 3 ,2008 Yankee'Atomic Eledtric Company" 49 Yankee Road Rowe, MA 01367 Attention: Wayne Norton, President RE: Rowe-DSWM-08-253-008 DEP Solid Waste, Permitting SE Construction, Fill Area (SCFA)

Closure Certification.& Permit Approval.

Yankee Nuclear-Power.Station...

49 Yankee Road

-'BWPSW43 Transmittalt #W120065T.

Dear Mr..Norton:

The Solid Waste section of the Massachusetts Department of Environmental-Protection (the Department). has completed review of the Final Closure Certification (Closure Certification) report and permit application.for the Southeast Construction-Fill Area (the SCFA) of the Yankee Nuclear.

- .Power Stationj(YNPS)- in--Rowe,-MA. The Clbsure-Certi-fication repo~rt Was prepared on behalf-of .Yankee Atomic Electric-Company (Yankee) by-its consultant, Environmental Resources Management. (ERM) of Boston,"MA,-and.

was. signed and stamped by Gregg A. Demers, Massachusetts-registered Professional Engineer .(P*E.) #39434"of ERM.

As a part of decommissioning activities for the YNPS,'the SCFA'was assessed and closed in accordance-with the Department's Solid'Waste regulations at 31.0. CMR 19.000. -The SCFA is.a fill area of approximately

, 11.2 acres.in size,.located:immediate.ly .southeast of the former Yankee industrial facility (within Yankee property),.where soil and debris from construction activities at the site was historically~placed.-

MassDEP previously issued to Yankee the following Solid Was'tepermiit reviews/approvals for the SCFA:. "

  • the FinalComprehensive Site Assessment (CSA) permit approval, datedApril 9, 2002; -
  • the Corrective Action Alternatives Analysis (CAAA, br'remedial

.feasibility) permit.approval, dated April:13, 2004; and the Corrective Action Design (CAD) Final Closure Plan permit.

approvali..dated January 11, 2005. * -

The Closure Certification Report was submitted in compliance 'with This information is available in alterndte format. Call Donald M. Gomes, ADA Coordinator at 617-556-1057. TDD# 866-539-7622 or 617-574-6868.

' .. . - *DEP on the World Wide Web: http://www.mass:gov/dep S ". ....

' * ." Printed on Recycled Paper .,. ' . *.

Yankee/Rowe -Southeast Construction' Fill Area 2

.Closure Certification Approval SWM File #08-253-008 MassDEP's CAD Plan approval for the remediation of the SCFA. The Closure. Certification report documents that the. closure activities were performed at the SCFA in accordance with the approved plans -and aas required,-by the MassDEP, and proposes post-closure maintenance and monitoring of the'SCFA.. .

.TheClosure Certification report: includes the following information:

  • Summary text describing the: final closure activities completed for the SCFA;
  • Plans *and cross-sections of the SCFA following remediation;
  • Test-pit logs and photographs; and SA post-closure maintenance and monitoring plan.

As a part of decommissioning activities for the YNPS, the SCFA was assessed and closed in accordance with applicable environmental regulations, including the Nuclear Regulatory Commission (NRC),..

regulations .10 CFR Part 50, and the applicable regulations of the Massachusetts Department of Public Health's Radiation Control Program (the MA RCP).,the.United States Environmental Protection Agency (the EPA), and the MassDEP.

Assessment of the SCFA consisted of the installation and monitoring of

groundwater monitoring wells, sampling.and.analysis.of'surface water and sediment from Wheeler Brook near the SCFA, landfill gas monitoring around the perimeter of the SCFA, and sampling and-analysis of soils fromthe SCFA prior to and during remediation. The- CSA report and the Closure Certification Report stat6 that radiological monitoring of the SCFA,. Wheeler Brook and the surrounding area has shown results that are consistent with natural background levels, i.e., there has been no evidence there of any facility-related radionuclides or radioactivity, except.for a small amount of radiologically-impacted asphalt removed from .the.SCFA during.remedial -activities, as*outlined below.

-As -pýart--o'f the Final CSA, ERM previously Completed a Qualitative Risk Assessment for the SCFA in accordance with the requirements outlined in the. Department's. Landfill Technical Ghidance Manual (the LAC) .. ERM -

concluded that no significant risk of harm to human health or the environment was identified for .the SCFA,. although several metals, including iron.and manganese, we re-elevated in the surface water of Whedler'-Brbok* immediately downgradient. of the SCFA:. The MassDEP's Office of Research.& Standards .(ORS) December 3-1, 2007 review of the

.Method 3: Risk Characterization (the Quantitative.Risk Assessment) for the entire.YNPS site noted that the. exceedance of surface water standards for cadmium, copper and lead in Wheeler' Brook. immediately downgradient of the SCFA requires that long-term:surface. water' monitoring 'of Wheeler Brook be .continued to demonstrate that these levels are decreasing over time.

Remediation of the SCFA was performed from July, 2005 through May, 2006, and consisted of excavation of the upper portion of'the SCFA, with removal of approximately 13,000 cubic yards of non-conforming material-.

(primarily soil) 'from the excavated area. Non-conforming material consisted of soil impactediby polychlorihatedbiphenyls (PCBs),

construction & demolition.-(C&D) debris (primarily scrap metal), C&D debris and soil containing asbestos-containing material (ACM), and approximately 50 cubic yards of radiologically-impacted asphalt (containing the radionuclide. Co-60' slightly above background levels)'.

Yankee/Rowe Southeast Construction Fill Area:- 3 Closure Certification Approval SWM File #08-253-008 Portions of, the soils within the SCFA were contaminated by PCB.-

containing paint chips generated during'the maintenance of the YNPS facility;, the assessment and remediation Of PCBs at the SCFA was' governed by an EPA Toxic Substances Control Act (TSCA) permit approval.

All of the non-conforming material was' removed off-site for disposal at proper, permitted'disposal facilities, except. for approximately 1,800 cubic.yards. of RCB-impacted soil which was thermally treated on-site'. at YNPS according to 'an EPA TSCA permit approval, and which was reused.on-.

site-as- fill according to' the MassDEP's June 19, 2007 Beneficial.:Use Determination (BUD) permit.

Upon completion of excavation and removal activities, Yankee completed a' total of 14 test pits at the. SCFA, to the natural so'ils at the'base of the SCFA fill (maximum 22 feet in depth). The test pits, which were inspected by MassDEP personnel, contained only.-very minor amounts of..

remaining C&D debris. S6veral of the test pits ..contained sawdust at the base of the.SCFA, which'had apparently been produced by an historic sawmill which operated 'at'the location of the SCFA, priork to the construction of the YNPS. The maximum residual PCB concentration remaining in 'the soils of the SCFA following remediation was 6.45 milligrams/kilogram (mg/kg), which meets the EPA TSCA Low Occupancy Criteria of'25 mg/kg. '

Clean fill was used to 'grade the SCFA excavation area to proper slopes ,

to facilitate drainage,, and 6 inches of clean topsoil was then placed.,

over the SCFA And seeded. with grass. MassDEP inspections subsequent .to the seeding showed that the grading work was acceptable and that-a.

healthy grass cover had been established.

ERM proposes to inspect the SCFA on a quarterly basis for three years,,

and to:repair any,erosion which might be observed. In accordance with Yankee's. "'Post-Decommissioning Planting Plan and Specifications", thee

. SCFA

. will not'be mowed but willibe allowed to undergonatural plant monitoring will be performed at one upgradient.

.well and two Groundwater wells incord~hce With succession. Yankee's. "Post-'

wdowngradieht Closure Groundwater Monitoring Program", annually.for 5 years, then every: 2 year's' for the remainder bf the 30-year' post-closure monitoring

period, with analyses for the non-tadiological p outlf.e at 310 CMR 19.132, as.-well as tritiumr. 'Surface water will be 'sampled at

. the previous-five lodations a.long Wheeler' Brodk on the, same 'frequency and for'the s ame parameters a's' groundwater.

Yankee submitted to MassDEP a'copy of the Record Notice of Landfill Operation-for the SCFA, as outlined in'310,CMR'19.141; ýincluding a survey map'of the'SCFA and appropriate supporting docmeentAtion.. The'

.. documentation contained pfoo'f that the Record Notice was recorded on October 3, 2007 at Book 5401,:'Page 167, in the Franklin County

'Registry of Deeds. On February.:ii, 2008,, Yankee executed a Financial' Assurance Mechanism. (FAM) in the' amount of $72,625.00.for post-closure maintenance, and monitoring atthe SCFA, and provided documentation to

'the MassDEP of such execution.-

S- MASSDEP DETERMINATIONS In accordance with 310 CMR 19.130 (31) (d),'the MassDEP has' reviewed 'the Closure .Certification Report and has performed inspections' of the. SCFA both during ands'after Closure.' Based on the review,'of the Report, the

Yankee/Rowe Southeast, Construction Fill Area. 4 Closure Certification Approval SWM.File #08-253-008 inspections and -the consultant's certification; the MassDEP is issuing this letter of. compliance certifying that the SCFA has been closed in accordance with the approved plans.

In "accordance with 310 CMR 19.140(6), the post-closure period begins on the date of this determination. In accordance with>310 CMR 19.142, the post-closure -period-extends for a minimum period of 3.0 years from the date of this approval, however, the MassDEP may reduce (upon written request by the permittee) or extend, (in order to- ensure protection of public health,:. safety or the environment) the 30-year. post-closure period. This certification permit shall remain valid for the entire post-closure period.

Note that-this document is a permit issued pursuant to MGL Chapter 111 Sections 150A and 150A1/2 and the regulations promulgated thereunder at 310 CMR 16.00 and 310 CMR 19.000. This permit is- subject to the standard--.conditions presented at 310 CMR 19.043(5) and;to, the conditions

-and requirements listed below: -

1. Yankee Atomic Electric Company (Yankee) is the permittee for the SC FA.
2. During the post-closure period, the permittee shall perform the following activities -at the SCFA as described -in 310. CMR 19.142,

.,Landfill Post-Closure Requirements, of the Solid Waste Management Facility. Regulations, and as further specified inlthis -permit:

(a) Perform inspections for settlement. and erosion during all monitoring rounds- for-the. enti-re post-closure peri-od; .

(b) Take corrective actions to remediate - and/or mitigate conditions that would compromise the integrity of the final cover -(topsoil- and vegetative cover);,

(c) maintain the integrity-o f1 the final Cover -- (topsoil and

-vegetative cover); and (d) monitor and maintain the environmental monitoring systems for-surface water and groundwater.

3. All maintenance/repair of the S.CFA final cover conducted as a result of sto'tm damage, erosion, or . other, circumstances shall be summarized and reported-to the MassDEP within thirty (30) days of the date of the repair/maintenance.
4. The permittee shall submit a post-closure report, as required by 310 CMR 19.142 (6) Reporting Requirements, not later than February 1 5 th of each year.
5. The SCFA shall not be used for any post-closure activity without prior written approval from the MassDEP. The performance of any activity on the SCFA that compromises the final cover or failure to adequately maintain the-' final cover shall- invalidate the certification and may be considered to be a violation of this permit. Under no circumstances shall excavations or penetrations be made into -the SCFA, surface without prior written MassDEP approval. ..

Yank'6e/Robwe - -Southeastý Construction Fill Area 5 Closure:Certification Approval SWM File #08-253-008

6. Yankee shall comply with all of the stipulations contained within the Deed Notification.for the SCFA, as recorded on October .3, 2007 at the Greenfield Registry of-Deeds; Book.5401, page 167.

.:7. " Yankee. shall comply with the continuing requirements- for pbst-Closure groundwater- monitoring of the SCFA, as outlined, in the

-MassDEP's approval *of the .YNPS Groundwater .Monitoring Plan dated,,

-June 19, .2007, including "the- requirement, for- sampling of monitoring wells CFW-l, CFW-5., -and CFW-6' annually* for 5 years,

- then every -2 years forthe remainder, of the 30-year post-closure

  • period. As proposed in the closure Certification Report, surface

-water samples shall be obtained, from each:%,of the five previous SCFA surface water sampling 'locations. on the same frequency. and for the same timeperiods as the SCFA groundwater sampling.

8. -The SCFA groundwater and surface- water samples shall. be analyzed zý:-:.-.for- the . parameters Outlined in 310 CMR-..19.132 -.. (1)(h) (l-3).,

-including VOCs.by EPA Method' 8260 and dissolved metals, ard .-also

. for tritium. All VOC analyses by EPA Method 8260 shall be performed as Outlined -in 310 CMR 19.132(h) (1-3)i specifically methyl ethyl ketone, methyl isobutyl-- ketone, and acetone shall be included, and .iunknown- peaks having intensities greater than 5 times the background intensity shall be identified.

9. Results of SCFA monitoring, including data in tabular -form and laboratory-. .analytica., data.: sheets, shall. be .submitted -to the

-"MassDEP within 45 days of the-date of sampling.

- 10- -MassDEP- reserves the right to modify: the SCFA -environmental -

monitoring program at any .time.

11. Yankee shall comply with all other applicable local, state, and federal regulations and . requirements .- concerning. the -.SCFA, including. those of the NRC, EPA, MADPH, and the Rowe Conservation

- Commission. . -

12. - Appropriate Health & Safety -(H&S) measures shall be utilized for

'all post-closure maintenance and monitoring work at-the -SCFA.

13. Should utilization of FAM monies be required according. to the

.regulations outlined at -310. CMR 19.051(9), the.-MassDEP reserves.

the right to -- tilizb .any portion .of the FAM for. post-closure maintenance and -monitoring at. the. SCFA." The permittee shall-

" submit . to the. MassDEP revised% estimates " of post-closure

- maintenance and monitoring costs- every, two years following the

-issuance of this Closure Certification approval. .

14. The MassDEP and its agents and'employees shall have-the right to.
  • " enter upon " the -SCFA- site at all .. reasonable times .'and with..

. .reasonable " notice, to- inspect"the SCFA. and. any.: equipment,.

. structure or land located thereon,,take samples, recover-materials or discharge*, have access .to and photocopy records, to' perform.

tests and to otherwise -monitor compliance.,with.this Permit and.all environmental -laws - and ---regulations. - This:- right of entry, and

" inspection. -shall be. in -. addition to the -MassDEP'.s access

- .authorities. ..and rights under .applicable federal and states -laws.

-. ".and regulations, as..well asl. any- permits- or Other.-agreements...

between-the-Permittee and the MassDEP. . . -

Yanke*e/Rowe - Southeast Construction :Fll Area. . 6 Closure Certification;Approval .

SWM File #08-253-008 Pursuant to 310 CMR 19.037(5)., any person aggrieved by the issuance of

-this approval; except as provided for under 310 CMR 019.37(4) (b), may file an appeal"-for. judicial review of said. decision in 'accordance with the. provisions of M.G.L.: c. iii,; s. 150A and, C. 30A not later than thirty 130] days following notice of this 'decision. -The standing of.,a person to file 'an appeal* and the procedures -for, filing such appeal shall be .governed by' the provisions-' of M.G.L.. c. 30 A. Unless the person requesting an appeal requests. and is granted a stay of the terms and conditions of .the permit by a. court of competent jurisdiction, the permit" decision shall remain effective' or become effective at the conclusion of the 30 day period.

Any aggrieved, person intending to appeal the decision to ýthe superior court shall provide notice to the MassDEP of said 'intention to commence such action. Said Notice of Intention shall include ,the MassDEP File Number (08-253-008) and shall identify with particularity the issues and.

r'eason(s) why :itis believed'the approval. decision' was not proper. Such notice shall be provided to the Office of General Counsel oflthe MassDEP and the Regional. Director for the" regional'-office which made the decision. The appropriate addresses to which to sendsuch notices are:

Office of General Counsel MassDEP One Winter- Street Boston, MA 02108

.Regional Director MassDEP 436 Dwight Street 5th Floor Springfield, MA 01103

-'No allegation---shall be made in any judicial-. appeal- of this decisi-cn-unless the matter complained of was wraised at the appropriate point in the administrative review :procedures established in -those .regulations, provided that matter. may be raised..upon a showing that it is material and that it was not reasonably possible with due diligence to have been raised during.'such procedures' or that matter sought to be raised is of critical importance to the public health or environmental "impact of the-permitted activity.

This approval pertains only to the solid waste management aspects of the proposal and does not negate the responsibilities of the owners or, operators to, comply with any other local, state, or federal laws and regulations now or in the future.

,Yankee/Rowe6- Southeast Construction Fill Area 7 Closure Certification Approval SWM File #08-253-008 The MassDEP reserves the. right to require additional investigatory or remedial work at the SCFA, if continued.monitoring results indicate such a need. If you. should have any questions or comments regarding this correspondence please contact Larry Hanson (#413-755-2287) of this office.

. .Sincerely, DZ ie1 all Section Chief, Solid Waste Management Western Regional Office Yankscfacert-cc: Joe Bourassa - Yankee Gregg Demers - ERM, Inc.

Rowe Board of Selectmen Rowe Board of Health Michael Whalen, MA-DPH -- Radiation Control Program John Hickman - Nuclear Regulatory.Commission David.Howland -. DEP/WERO Nancy Bettinger - DEP/Boston/Office of-Research & Standards Kimberly Tisa - EPA Franklin Regional Council of Governments Citizens Awareness Network - Deborah Katz

AFTER 5 DAYS RETURN TO

ýýe POS).

THE COMMONWEALTH OF MASSACHUSETTS DEPT. OF ENVIRONMENTAL PROTECTION WESTERN REGION o O $ (pirrBOWES 436 DWIGHT STREET - 5TH FLOOR 02 IM 00042546,40

$00O-590 OCGT31 2008 SPRINGFIELD, MASSACHUSETTS 01103 MAILED FROM zip CODE 'D110 03

/-/ //

USNRC N~3Q2 I Office of NRR Washington, DC, 20555 0 PRINTEONRECYCLED PAPER

Retrieved from "https://kanterella.com/w/index.php?title=ML083240377&oldid=2565821"