ML16344A106

Notification Pursuant to 40 C.F.R. Part 266, Subpart N; Vhwmr 7-109(b)(2)

ML16344A106
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	11/16/2016
From:	Boyle J Entergy Nuclear Vermont Yankee
To:	Office of Nuclear Material Safety and Safeguards, State of VT, Dept of Environmental Conservation
References
SVY 16-036
Download: ML16344A106 (2)

Text

Entergy Nuclear Vermont Yankee, LLC 320 Govornor Hunt Road

^Entergy Vernon, VT 05354 Tel 802 451 3106 John W. Boyle Vermont Yankee Nuclear Power Station Director. Nuclear Decornmissioning SVY 16-036 BY UPS OVERNIGHT AND EMAIL November 16,2016 Department of Environmental Conservation Waste Management and Prevention Division Hazardous Waste Management Program One National Life Drive, Davis I Montpelier, VT 05620-3704

SUBJECT:

Notification Pursuant to 40 C.RR. Part 266, Subpart N; VHWMR § 7-109(b)(2)

On March 23, 2016, we notified (the "Notification") your office that, consistent with Subpart N of 40 C.F.R. Part 266, as incorporated into the State of Vermont's Resource Conservation and Recovery Act program pursuant to VHWMR § 7-109(b)(2)(collectively, the "Mixed Waste Rule"), Entergy Nuclear Vermont Yankee, LLC("Entergy VY")claimed the conditional exemption for the onsite storage and treatment of low level mixed waste("LLMW").

Entergy's Notification was based on its conservative assessment that LLMW could be generated as a result of the planned disassembly and demolition of the building commonly known as the North Warehouse at the Vermont Yankee Nuclear Power Station in Vernon, Vermont.

Specifically, the Notification reflected Entergy's expectation that certain North Warehouse structural components could include hazardous materials, in addition to radiological materials, and therefore constitute LLMW as a result of that structure's age, Entergy VY's laboratory analysis showing lead-based paint on structural steel, and the use of that building for storage of Nuclear Regulatory Commission ("NRC")-authorized materials.

In expectation of the North Warehouse disassembly and demolition (expected to commence in mid-November), Entergy retained a leading national consultant, Haley & Aldrich, Inc.("H&A"),

to analyze representative building components (including siding, roofing and caulking)from the North Warehouse. H&A focused on reasonably anticipated contaminants, e.g., RCRA-8 metals, PCBs and asbestos. H&A's analysis determined that no relevant regulatory thresholds for hazardous materials or waste handling are exceeded for these North Warehouse components.

Given the absence of a hazardous component, the North Warehouse building materials slated for disassembly and demolition are no longer considered to be, or treated as, LLMW. Instead, the North Warehouse disassembly and demolition now will be managed under applicable NRC mandates related to radiological materials. Lighting bulbs and ballast materials have been treated separately as universal waste.

In light of this information, Entcrgy VY hereby respectfully withdraws its Notification related to on-sitc storage and treatment of the North Warehouse dated March 23, 2016.

Please contact Joe Lynch (802-451-3160) or me (802-451-3196) if you have any questions.

Si John W. Boyle cc: Mr. Daniel H. Dorman Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. Jack D. Parrot, Senior Project Manager Mail Stop T-8F5 U.S. Nuclear Regulatory Commission 11545 Rockville Pike Rockville,MD 20852 Mr. Tony Honnellio Radiation Program Manager, Health and Safety Coordinator New England, Region 1 U.S. Environmental Protection Agency 5 Post Office Sq., Suite 100(OSRR02-2)

Boston, MA 02109