Text

Response to Request for Additional Information Re Notification Pursuant to 40 C.F.R. Part 266, Subpart N; Vhwmr 7-109(b)(2)
	ML16169A284
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	06/08/2016
From:	Boyle J; Entergy Nuclear Vermont Yankee
To:	Simoes S; Office of Nuclear Material Safety and Safeguards, State of VT, Dept of Environmental Conservation
References
	SVY 16-017
	Download: ML16169A284 (113)
	v • d • e

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Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Rd Vernon, VT 05354 802-451-3196 John W. Boyle Vermont Yankee Nuclear Power Station Decommissroning Director SVY 16-017 BY UPS OVERNIGHT AND EMAIL June 8, 2016 Steve Simoes Environmental Analyst VII Vermont Department of Environmental Conservation Hazardous Waste Program One National Life Drive, Davis 1 Montpelier, VT 05620-3704

SUBJECT:

Request for Additional Information re Notification Pursuant to 40 C.F.R. Part 266, Subpart N; VHWMR § 7-109(b)(2)

Dear Mr. Simoes:

This letter responds to your May 5, 2016 letter requesting additional *information regarding Entergy Nuclear Vermont Yankee, LLC's ("ENVY") plan 'to manage low level mixed waste

("LLMW') that may be generated by or is otherwise associated with the planned disassembly and demolition of the North Warehouse at the Vermont Yankee Nuclear Power Station

("VYNPS"). ENVY's responses to your requests for additional information are provided below.

In addition, following the submittal of our March 23, 2016 notification letter, ENVY received the results of additional laboratory analyses of the paint used on the North Warehouse structural steel. Those results indicated the presence of chromium in the paint. Accordingly, ENVY is providing the enclosed supplemental notification letter to include the waste code for chromium.

1. What are the requirements in ENVY's NRC license applicable to storing LLMW in containers for the purposes of§ 266.230(b)(1)?

ENVY's NRC operating license does not include any specific conditions or requirements applicable to storing LLMW in containers. However, as a 1O C.F.R. Part 50 licensee, ENVY is subject to the applicable labeling and packaging requirements in 10 C.F.R. Part 20 and 49 C.F.R. Parts 172 and 173.

2. What is the process by which ENVY will transfer to and load the LLMW demolition debris into the containers?

ENVY intends to remove the North Warehouse in three stages, First, the building will be removed and loaded into shipping containers. Second, the concrete foundation pad will be removed and placed into containers. Finally, the frost wall and footings will be removed and loaded into shipping containers. The waste shipping containers will be

. -~taged in the are~ o.f _the NQrtl:) War~house to minimize the distanc_eJh-at the waste wiH --. :: *-:--_, ,._,. -.. ,. ,.c, :*,

- *'be transported. , * -.

'J' SVY-16-017 I Page 2 of 3

3. How long does ENVY intend to store full containers of LLMW demolition debris prior to shipment off-site?

ENVY does not anticipate any long-term on-site storage of LLMW containers prior to their shipment off-site. Dismantlement of the North Warehouse is currently scheduled to occur over several months, between August and November 2016. ENVY intends to ship all full LLMW containers off-site prior to the end of December 2016.

4. Where does ENVY intend to store containers of the LLMW demolition debris on-site (both those that are accumulating the LLMW and full containers of the LLMW)?

ENVY plans to store LLMW containers that are accumulating LLMW in the vicinity of the North Warehouse. Full containers of LLMW will be stored within the Vermont Yankee Security Owner-Controlled Area (SOCA) until they are shipped off-site for disposal.

5. How does ENVY's emergency plan address a potential release of non-radiological hazardous waste or non-radiological hazardous constituents for purposes of§ 266. 230(b)(5)?

ENVY is currently a small quantity generator of hazardous waste, as that term is defined in Vermont Hazardous Waste Management Regulations ("VHWMR") § 7-307(c).

Accordingly, although ENVY must comply with the emergency preparedness requirements in VHWMR § 7-307(c)(14), because it is not a large quantity generator, it is not required to maintain a specific "emergency plan" to address potential releases of non-radiological hazardous waste or non-radiological hazardous constituents. In addition to fully complying with the requirements in VHWMR § 7-307(c)(14), ENVY maintains several plant procedures for the purpose of ensuring adequate contingency planning and availability of appropriately trained response personnel to mitigate the consequences of spills, leaks, or fires involving hazardous materials and wastes. For example, the enclosed Oil and Hazardous Materials Spill Prevention and Control Operating Procedure (OP 2106, Rev. 35 (Oct. 22, 2015)) specifies the actions required by plant personnel to prevent oil or hazardous material from threatening the public and from contaminating the Connecticut River and groundwater. 1 It also identifies the notification requirements in the event of a spill or release, provides detailed descriptions of available emergency response equipment and supplies, and includes the VYNPS Spill Prevention Control and Countermeasure Plan ("SPCC"). This robust procedure and the accompanying SPCC serve as the functional equivalent of an "emergency plan" for potential releases of non-radiological hazardous waste or non-radiological hazardous constituents.

In addition, ENVY maintains a VYNPS Hazardous Waste Contingency Plan (provided as Appendix B of the enclosed VYNPS Hazardous Waste Program Procedure (PP 7503, Rev. 8)). The Contingency Plan meets the requirements of VHWMR § 7-308(b)(14),

which is applicable only to large quantity generators. As noted above and in the Contingency Plan, because ENVY is currently a small quantity generator of hazardous waste, the Contingency Plan presently is not in effect at VYNPS. ENVY does not This procedure is currently undergoing revision to better reflect the current conditions of the site as VYNPS continues preparations for long-term SAFSTOR. ENVY expects to implement the

~*.::::-~ ~, *....: *--.. ~- ,. - . *revised procedure iri the* Ju.ly*fo Atigu*st*201"6 *timeframe and* 1/Jill provide the Agency with the : LI: . ::::..,. ... ~,> ;;, .

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updated version once it becomes effective.

J SVY-16-017 I Page 3 of 3 anticipate becoming a large quantity generator again; however, in that unlikely event, ENVY would implement the Contingency Plan at that time.

6. Does ENVY intend to treat the LLMWon-site? (While it is the Agency'.s understanding that ENVY does not intend to treat the LLMWon-site, 40 C.F.R. § 266.235 specifies that the only treatment allowed under the storage and treatment exemption is that which occurs within a tank or container ~n accordance with the terms of your NRG license.)

ENVY does not intend to treat any LLMW on-site. ENVY will notify the Agency when on-site LLMW storage activities cease and it no longer claims the LLMW storage and treatment conditional exemption. ENVY anticipates providing this notification in late 2016.

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

John W. Boyle Enclosure 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. Parrott, 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 & Safety Coordinator New England, Region 1 U.S. Environmental Protection Agency 5 Post Office Sq., Suite 100 (OSRR02-2) .

Boston, MA 02109

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VERMONT YANKEE NUCLEAR POWER STATION OPERATING PROCEDURE OP2106 REVISION35 OIL AND HAZARDOUS MATERIALS SPILL PREVENTION AND CONTROL

. USE CLASSIFICATION: REFERENCE RESPONSIBLE PROCEDURE OWNER: Manager, Operations REQUIRED REVIEWS Yes/No E-Plan 10CFR50.54( q) No Security 10CFR50.54( o) No Probable Risk Analysis (i>RA) No Reactivity Management No LPC Effective Affected Pages No. Date IImplementation Statement: NIA Effective Date: 10/22/15

"-"'-"=~--

~op 2106 Rev. 35 Page 1 of23

TABLE OF CONTENTS PURPOSE ............................................................................................................................................................. 3 DISCUSSION ....................................................................................................................................................... 3 A TTACIIMENTS ................................................................................................................................................ 5 QA REQUIREMENTS CROSS REFERENCES ..........................................................._.................................... 5 REFERENCES AND COMMITMENTS ************************r********************************************************************************** 5 PRECAUTIONS/LIMITATIONS ....................................................................................................................... 7 PROCEDURE ....................................................................................................................................................... 9 A. Initial Response ........................................................*..... :;:.......................................................... 9 B. Containment of Large Releases ................................................................................................ 12 C. Oil to the Connecticut River ............................ :........................................................................ 16 D. Acid Spill at the Intake Structure .............................................................................................. 16 E. Sodium Hypochlorite Spill at the Intake Structure ..................................................... :............ 17 F. Sodium Bromide Spill at the Intake Structure.......................................................................... 18 G. Simultaneous Sulfuric Acid and Sodium Hypochlorite Spill at the Intake Structure ............. 18 H. *.Simultaneous Sulfuric Acid and Sodium Bromide Spill at the Intake Structure .................... 19 I. Nitrogen Leak ............................................................................................................................ 21 J. Toxic Airborne Release ............................................................................................................. 21 K. Mercury Spills ........................................................................................................................... 22 L. Hazardous Waste Spill Response Equipment .......................................................................... 23 FINAL CONDITIONS ....................................................................................................................................... 23

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OP 2106 Rev. 35 Page 2 of23

PURPOSE To outline the action required by plant personnel to prevent oil or hazardous material from threatening the public, contaminating the river, or contaminating the ground water. This procedure also outlines the notification requirements for such a spill and contains Vermont Yankee's Spill Prevention Control and Countermeasure (SPCC) Plan.

DISCUSSION Program procedure PP 7503, Hazardous Waste Program, was developed to establish program guidance and hazardous waste handling procedures to ensure VY is in full compliance with all applicable State and Federal Regulations and provide assurance that operations at VY do not adversely affect employee and contractor health and safety, Connecticut River water quality and aquatic life, or air and ground water quality. The program procedure functions as the single controlling umbrella document for all ha:lardous waste regulations and statutes that apply to VY.

Additionally, the program procedure designates the responsibility of departments and individuals for developing and implementing procedures or programs to ensure compliance with each regulation. [2000-050-04]

Response to incidental releases (i.e., <two gallons) of oil or hazardous substances where it can be absorbed, neutralized, or otherwise controlled at the time of the release by employees in the immediate release area, or by Hazardous Waste Handling personnel, is not considered in the scope of this procedure. The Shift Manager is responsible for evaluating available information and fully utilizing th.is procedure as appropriate. Regardless of the magnitude of the spill, the Shift Manager shall ensure one of the individuals listed on Appendix Bas the HaZardous Waste Coordinator is notified.

If an onsite spill is imminent or has occurred, it is important to take actions to preserve the health and safety of the public and plant personnel, and prevent or mitigate damage to the environment.

This procedure describes the various containment techniques to be employed by plant personnel in the event of a spill or release in various areas of the plant complex. Spills/releases may originate from plant equipment, plant storage, or transport vehicles. The attached Figures 1, 2, and 3 in Appendix D indicate the containment facilities for these areas, locations of storm drain isolation valves, and expected directions of flows.

Once containment is achieved, cleanup must begin. Should the spill be of large magnitude it will be necessary to contract outside services as specified in this procedure. In the case of mercury _spills, a large magnitude spill is defined as more than one pound (2 Tablespoons).

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OP 2106 Rev. 35 Page 3 of23

The following is a list of the onsite areas where large quantities of hazardous chemicals are located:

Hazardous Material Location Sulfuric Acid Tank (Concentrated) Intake Structure Figure 2 of Appendix D (Item B) 15% Sodium Hypochlorite Tank Intake Structure Figure 2 of Appendix D (Item B)

Sodium Bromide Tank (Although this Intake Structure material is classified only as a mild skin and Figure 2 of Appendix D (Item B) eye irritant, it could generate bromine gas if mixed with sulfuric acid)

Nitrogen Tank East of Reactor Building Figure 2 of Appendix D (Item A)

Hazardous & Mixed Hazardous Waste North Warehouse Figure 2 of Appendix D (Item D)

Paints, Epoxies & Ethylene Glycol South Warehouse Figure 2 if Appendix D (Item C)

Various Chemicals Chemistry Laboratory Figure 2 of Appendix D (Item E)

Flammable Products & Other Chemicals Stores Warehouse Figure 2 of Appendix D (Item F)

Hazardous Materials Storage Bldg Figure 2 of Aooendix D (Item G)

Compressed Gases Refer to Figure 2 of Appendix D (Item K)

Carbon Dioxide Tank Figure 2 of Appendix D (Item H)

Bulk Hydrogen Facility South of Cooling Towers Figure 2 of Appendix D (Items J&L)

Mercury (large quantity) RB 280', RB 303' I&C Shop Barometers 60 ozs RB 303' l&C Shop Manometer 30 ozs Section 5 .0 of Appendix D provides a list of the onsite areas where large quantities of oil are located.

Th,__ese locations are identified on Figure 1 of Appendix D.

Apparatus and Spill Kits Capabilities (ER982014-01 Commitment UND2000-093 _ 00)

OP 2106 Rev. 35 Page 4 of23

NOTE All absorbent materials located in the spill kits are color-coded.

Pink Absorbents are for aggressive liquids such as acids/bases.

Gray absorbents may be used for any liquid.

White absorbents are for oil.

Spill response equipment will be inspected on a quarterly basis per the Chemistry Department Surveillance Schedule. Detailed inventory of Spill Kits is located in Appendix E to this procedure.

ATTACHMENTS

1. Table 1 Manhole/Isolation Valve Locations

2. Appendix A Outside Assistance Contacts

3. Appendix B Hazardous Waste and Safety Coordinator Contact List

4. AppendixC Valve Lineup

5. AppendixD Vermont Yankee Nuclear Power Station Spill Prevention Control and Countermeasure (SPCC) Plan

6. AppendixE Spill Response Equipment Inspection

7. Appendix F VYNPS Spill Report Record (Typical)

8. Figure 1 Deleted

9. Figure 2 Deleted

10. Figure 3 Deleted

11. Figure 4 Deleted QA REQUIREMENTS CROSS REFERENCES

1. None REFERENCES AND COMMITMENTS

1. Technieal Specifications and Site Documents

a. None

2. Codes, Standards, and Regulations

a. 29CFR1910.120, Hazardous Waste Operations and Emergency Response

b. State of Vermont, "Hazardous Waste Management Regulations", Section 7-309

c. State of Vermont Regulation, "Community, Right to Know", Section Five

d. 40CFR Part 110, Discharge of Oil

e. 40CFR Part 112, Oil Pollution Prevention OP 2106 Rev. 35 Page 5 of23

3. Commitments

a. ER980141_02, Mercury Spill (Revise OP 2106 Initial Response)

b. 2000-050-04, Revise OP 2106 to Reference PP 7503

c. CR-VTY-1995-00573 CA-04, (ER950573:_04), Include Apparatus to Mitigate the Consequences of a Hazardous Spill

d. _CR-VTY-2004-3097

e. CR-VTY-2015-01165 CA-02

f. ER-05-0517

g. ER-04-1257

h. CR-VTY-2012-05957 CA-02, Incorporate oil equipment rate of flow information

i. LR-LAR-2013-00159 CA-01,02, Include Station Blackout Diesel in OP 2106

4. Supplemental References

a. EC 57228, Relocation ofB.5.b Pump

b. NPDES Permit

c. SARA Title III

d. DWG G-1914~0, Railroad Layout and Switchyard Excavation

e. DWG G-191443, Plant Area Grading and Drainage Plan

f. Oil and Hazardous Materials Pollution Contingency Plan for the Waters of the State of Vermont

g. Federal Water Pollution Control Act

h. DWG G-191444, Plant Area Grading and Drainage Sec_tion and Details

i. E_AUDIT93020Pl, Revise Figure I to Include Spill Response Kits and Spare

Main Transformer and Add OP 2610 to References.

J. EOSI SPCC, Walkdown Report Prepared June 15, 2005

k. Mat~rial Safety Data Sheets I. Safety Standard 307, Barricades, Safety Signs, and Tags

m. UND97071, Evaluate Alternate Methods for Plugging Manhole 12A

n. EN-EV-120, PCB Management

o. EN-LI-102, Corrective Action Process

p. EN-OP-102, Protective Caution Tagging

q. EN-EV-106, Waste Management Program

r. EN-EV-112, Chemical Control Program

s. AP 0010, Situational Reporting Requirements

t. AP 0021, Work Orders

u. OP 0150, Conduct of Operator Rounds

v. AP 0310, l&C Surveillance, Preventive, and Corrective Maintenance Program

w. AP 0505, Respiratory Protection

x. AP 0510, Opening, Sampling, and Working in Confined Spaces

y. RP 2163, Lube Oil Purification

z. OP 2180, Circulating Water/Cooling Tower Operation aa. OPOP-F0-2195, Fuel Oil Transfer System bb. OP 2501, Use Oil Management and Furnace Operation cc. OP 2610, Liquid Waste Disposal OP 2106 Rev. 35 Page 6 of23

dd. AP 3125, Emergency Plan Classification and Action Level Scheme ee. OP 4105, Fire Protection Systems Surveillance ff. AP 4010, Surveillance Testing Program gg. OP 4152, Equipment and Floor Drain Sump and Totalizer Surveillance hh. OP 4195, Fuel Oil Transfer System Surveillance ii. OP 4321, Instrument Valve Lineup, Tagging, and Control .

jj. RP 4653, National Pollutant Discharge Elimination System (NPDES) Permit kk. AP 4801, Management of Underground Storage Tanks (USTs)

II. AP 6805, Document Control mm. PP 7503,.Hazardous Waste Program PRECAUTIONS/LIMITATIONS

1. Only personnel familiar with or trained in the hazards of the chemical involved should_

respond to the immediate area of the spill.

2. Proper protective clothing' and appropriate respiratory protection shall be worn when entering the immediate area of a spill.

3. Full and properly donned Fire Brigade turnout gear will provide adequate splash protection and respiratory protection for all hazardous chemicals at Vermont Yankee.

4. Turnout gear will not provide adequate protection when entering a confined space involving a large concentrated acid spill.

5. Prior to opening the discharge valve of an oil separator manhole, MH-A, MH-B, or MH-C, the water shall be sampled and verified by Chemistry Department to be acceptable for release as per RP 4653, National Pollutant Discharge Elimination System (NPDES) Permit.

6. Prior to opening V-YARD-10, 11 or 12, Storm Drain Isolation Valves (refer to Appendix C), following their use to contain a spill, the water shall be sampled and verified by the Chemistry Department to be acceptable for release prior to reopening the storm drain isolation valve(s) as per RP 4653, National Pollutant Discharge Elimination System (NPDES) Permit.

<<* OP 2106 Rev. 35 Page 7 of23 r

7. Symptoms/Event

a. Discovery of oil, chemical or hazardous material in or near any of the following areas or containment facilities:

Fuel Oil Storage Tank Moat

Main or Auxiliary Transformer

Diesel Generator Day Tank Rooms

Startup Transformer

Intake Gate Hydraulic Oil System

Intake Structure Moats

Discharge Structure Hydraulic Oil System

Switchyard V -ditches or Drains

North Warehouse

South Warehouse

Diesel Generator or Heating Boiler Room Floor

House Heating Boiler Fuel Oil Storage Tank

Diesel Fire Pump Fuel Oil Tank Room

Station Blackout Diesel Building

40 kW DG; DG-4-lA

b. Discovery of oil in any of the following oil separators or manholes:

MHA

MHB

MHC

MHC-1

MH 12-A

MH32

c. Receipt of any of the following low oil level alarms:

Auto Transformer

Main Transformer

Auxiliary Transformer

Startup Transformer

Diesel Generator Day Tanks

Nitrogen Storage Tank

Main Lube Oil Sump

Lube Oil Storage Tank

Station Blackout Diesel Storage Tank

d. Any unexplained transformer temperature or gas pressure variation.

e. Any unexplained decreasing storage tank level.

f. Discovery of oil in river.

g. A blowing or billowing cloud near the nitrogen inerting system.

h. Broken or empty mercury barometer/manometer.

.,... .. . ' -.* . ~ .

OP 2106 Rev. 35 Page 8 of23

PROCEDURE NOTE Procedure sections and steps are laid out in a logical order of performance. However, at the direction of the Incident Commander or Shift Manager, with the exception of Section A; the procedure steps may be performed concurrently or in a different order as required by the incident.

A. Initial Response

1. Immediately notify the Control Room upon detecting a spill of oil or hazardous material, and then perform remedial actions as qualification allows to mitigate the spill.

2. Consult the SDS for cautions/actions regarding the chemical spilled (not necessary for spilled oil).

3. Refer to AP 3125 to classify the situation as appropriate and AP 0010 for reporting requirements.

4. Notify and request assistance from one of the individuals listed as Hazardous Waste Coordinator AND one of the individuals listed as Safety Coordinator on Appendix B. (ER980141_02)

5. Complete Part A to the Spill Report Record (or similar) shown in Appendix F.

NOTE The VY Fire Brigade Leader assumes and retains incident command until relieved by a qualified individual from the fire department or commercial hazardous material team. The Hazardous Waste Coordinator or alternate is notified and requested to respond to the command ost to act as an advisor to the Incident Commander.

6. The Fire Brigade and other first responders shall:

a. Determine the source of the release,

1) If the release involves airborne toxicant, refer to Section J.

OP 2106 Rev. 35 Page 9 of23

CAUTION No individual should perform any action for which they are not trained and qualified to perform, and then only if the action can be erformed safel .

b. Take appropriate immediate action to mitigate the release per the appropriate procedure section.

NOTE Small oil spills may be contained by using oil absorbent pads or other absorbent material.

c. Attempt to stop or prevent any oil or hazardous material from contaminating the environment,

d. Barricade off the immediate area to keep unauthorized personnel out,

e. Use available means to contain and prevent the oil or hazardous material as much as practical, from entering the storm drains and ditches,

f. If needed, obtain additional sand from the Vernon Town Garage, Brattleboro Sand and Gravel, or Lane Construction Co.,

g. Refer to Section B for information on containing large releases in specific areas.

h. Complete Part B to the Spill Report Record (or similar) shown in AppendixF.

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OP 2106 Rev. 35 Page 10 of23

NOTE Parts C, D and E to the Spill Report Record (or similar) shown in Appendix F to this procedure is to be completed by Chemistry to document reportability determinations to regulatory agencies and other individuals contacted.

7. Should spilled or leaking oil or hazardous material reach, have the potential to reach, or is anticipated to reach the land or water of the state (i.e., leave a building or moat or spill off asphalt), immediately notify:

a. Control Room

b. Vermont HAZMAT 24-hour phone at 800-641-5005.

c. National Response Center at 800-424-8802.

d. If additional manpower is required, Fire Department at 603-352-1100.

e. If more than a gallon of PCB contaminated oil is spilled, the EPA regional office at 781-860-4300.

f. If an oil or chemical leak into the river is in progress or is expected, call Wilder Dam at 802-291-8000.

8. Should spilled or leaking hazardous material enter or if it is anticipated that it will enter the river; immediately notify:

a. U.S. Coast Guard, Burlington, Vermont, Tel. (802-864-6791).

b. New Hampshire Emergency Management, Tel. (603-271-2231).

9. When the fire department, if called, arrives on site, the senior fireman will be the Incident Commander and command at the incident shall be turned over to him as soon as practical, provided he is trained in HAZMAT response.

a. The Fire Brigade Commander shall act as assistant and communicator to the Incident Commander.

OP 2106 Rev. 35 Page I I of23

10. The Fire Brigade Commander shall consult Appendix A and request additional offsite assistance as appropriate.

CAUTIONS

Absorbent and containment material must be disposed of per EN-EV-106.

PCB oil spills must be cleaned up in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . See EN-EV-120 for more detail.

Only properly trained personnel shall perform.Steps 11 and 12.

11. Place absorbent material on the oil or hazardous material.

12. Contain and remove the spilled oil or hazardous material and all contaminated soil and debris.

13. Initiate a Condition Report per EN-LI-102.

B. Containment of Large Releases

1. Large releases into the following areas shall be contained using the following methods:

a. Fuel Oil Storage Tank and Waste Oil Tank

1) Verify sump pump for fuel oil storage tank is off.

2) Verify the valve on the discharge of Oil Separator manhole B is closed.

3) If it is anticipated that oil will enter adjacent storm drains, close storm drain isolation valve, V-YARD-11 at MH-45 (Near Circ Water Discharge Structure).

b. Diesel Generator Day Tanks

1) Secure the associated FO transfer pump by opening its feeder breaker:

MCC-9C, P lA Fuel Oil Transfer Pump A

MCC-:8C, P-92-lB FO Transfer Pump B

~' * (-;,._~* J_ ~'

OP 2106 Rev. 35 Page 12 of23

2) Verify the discharge valve from Oil Separator manhole B is closed.

3) If it is anticipated that oil will enter adjacent storm drains, close storm drain isolation valve, V-YARD-11 at MH-45 (Near Circ Water Discharge Structure).

c. Auto'Transformer (345KV yard)

1) Determine if oil has entered storm drainage V-ditches.

2) If oil has entered storm drainage V -ditches:

a) Close storm drain isolation valve, V-YARD-10 at MH-44 (Near Low Level Radwaste Storage Area).

b) Close storm drain isolation valve, V-YARD-12 at MH-33 (Near l 15KV Switchyard).

d. The following areas drain to Manhole A and require the following action which isolates their common discharge:

Main Transformer

Auxiliary Transformer

Startup Transformer

Lube Oil Intake/Discharge Box

1) Verify the valve on the Discharge Oil Separator manhole A is closed.

2) If it is anticipated that oil will enter adjacent storm drains, close storm drain isolation valve, V-YARD-10 at MH-44 (Near Low Level Radwaste Storage Area).

a) If V-Y ard-10 is closed, install floor drain plugs in the East Switchgear Room and by the North door to the main office building.

b) If plugs are installed, inspect them for leakage and document results on operator rounds. (VYOPF 0150.05) c) When V-Yard-10 is open, remove floor drain plugs and restore them in the East Switchgear Room.

.'h ~,.,,

- - ,, * .. OP 2106 Rev. 35 Page 13 of23

e. The following breaker drains to the same areas:

1) OCB-K-186 a) Determine if oil has entered storm drainage V-ditches.

b) If oil has entered V-ditches, utilize the contents of the oil spill kit located between the northeast and southeast comers of the 115KV Switchyard. If additional absorbency is required, place sandbags at the inlets of the 12 inch culverts located at the northeast and southeast comers of the l 15KV Switchyard. (Sandbags are located in the Stockroom and will require filling.)

c) Obtain sand from the sand storage shed or from local excavator or contractor such as the Vernon Town Garage, Brattleboro Sand and Gravel Co., or Lane Construction Co.

f. North Warehouse Floor Drain NOTE The drains in the North Warehouse have been lu ed with concrete.

1) Verify the valve on the discharge of Oil Separator Manhole C is closed.

2) If it is suspected the plugs are leaking or the oil or hazardous material will enter adjacent (outside) storm drains, close storm drain isolation valve, V-YARD-10 at MH-44 (Near Low Level Radwaste Storage Area).

a) IfV-Yard-10 is closed, install floor drain plugs in the East Switchgear Room and by the North door to the main office building.

b) If plugs are installed, inspect them for leakage and document results on operator rounds. (VYOPF 0150.05) c) When V-Yard-10 is open, remove floor drain plugs and restore them in the East Switchgear Room.

OP 2106 Rev. 35 Page 14 of23

g. South Warehouse Floor Drain NOTE

1) If it is suspected the plugs are leaking or the oil or hazardous material will enter adjacent (outside) storm drains, close storm drain isolation valve, V-YARD-11 at MH-45 (Near Circ Water Discharge Structure).

h. House Heating Boiler Fuel Oil Storage Tank

1) If-it is anticipated that oil may enter adjacent storm drains, cover the storm drains with drain blockers.

2) If it is suspected that oil will enter adjacent storm drains, close storm drain isolation valve, V-YARD-10 at MH-44 (Near Low Level Radwaste Storage Area).*

a) lfV-Yard-10 is closed, install floor drain plugs in the East Switchgear Room and by the North door to the main office building.

b) If plugs are installed, inspect them for leakage and document results on' operator rounds. (VYOPF 0150.05) c) When V-Yard-10 is open, remove floor drain plugs and restore them in the East Switchgear Room.

i. Discharge Structure Access Road

1) If oil or hazardous material will enter adjacent storm drains, close storm drain isolation valve, V-YARD-11 at MH-45 (Near Circ Water Discharge Structure).

j. Station Blackout Diesel

1) Secure source of oil leakage.

2) If it is anticipated that oil will enter adjacent storm drains, close storm drain isolation valve, V-YARD-11 at MH-45 (Near Circ Water Discharge Structure).

. .-.h '< OP 2106 Rev. 35 Page 15 of23

C. Oil to the Connecticut River

1. If it appears imminent that an oil spill will enter the river:

a. Ensure appropriate contacts are made per Steps A.7 and A.8.

b. The Hazardous Waste Coordinator (HWC) shall contact the appropriate contractor for oil boom deployment.

c. If requested, make provisions to move the boom as directed by the HWC.

2. Absorbent material may then be placed on the oil contained by the boom.

CAUTION This material must be disposed of as directed by the hazardous waste coordinator er EN-EV-106.

3. Contain and remove the spilled oil and oil contaminated debris.

D. Acid Spill at the Intake Structure NOTE Additional sand may be obtained from a local excavator or contractor such as the Vernon Town Garage, Brattleboro Sand and Gravel Co., or Lane Construction Co.

CAUTION No individual should perform any action for which they are not trained and qualified to perform, and then only if the action can be erformed safel .

1. Obtain sand from the Vermont Yankee sand shed.

2. Dike the spill to contain it as much as practicable, using sandbags and sand.

(Sandbags are located in the Stockroom and will require filling.)

3. Apply copious amounts oflime or soda bicarbonate. (these chemicals are stored in the Main Warehouse.)

OP 2106 Rev. 35 Page 16 of23

CAUTION If H in the river dro s below 6.5, fish ma be killed.

4. If the plant is operating on closed cycle, or the circ water system is secured and there is a catastrophic acid leak, which drops circ water pH below 6.5, do not go on open cycle.

5. If the plant is operating in open or hybrid cycle and circ water pH approaches or drops below 6.5, then shift to full closed cycle operation immediately per OP 2180.

E. Sodium Hypochlorite Spill at the Intake Structure 0

NOTE Additional sand may be obtained from a local excavator or contractor such as the Vernon Town Garage, Brattleboro Sand and Gravel Co., or Lane Construction Co.

1. Obtain sand from the Vermont Yankee sand shed.

2. Dike the spill to contain it as much as practicable, using sandbags and sand.

(Sandbags are located in the Stockroom and will require filling.)

CAUTION Residual chlorine at >0.5 m in the river ma cause a fish kill.

3. Have the Chemistry Department monitor chlorine in the circ water.

NOTE Cooling tower operation will dissipate the chlorine in the circ' water more ra idl

4. If residual chlorine approaches 0.2 ppm in the circ water, then go to full closed cycle operation immediately per OP 2180 .

. :...... , . OP2106Rev.35 Page 17 of23

F. Sodium Bromide Spill at the Intake Structure NOTE Additional sand may be obtained from a local excavator or contractor such as the Vernon Town Garage, Brattleboro Sand and Gravel Co., or Lane Construction Co.

1. Obtain sand from the Vermont Yankee sand shed.

2. Dike the spill to contain it as much as practicable, using sandbags and sand.

(Sandbags are located in the Stockroom and will require filling).

3. Have the Chemistry Department monitor the circ water system chemistry.

4. If the sodium bromide spill cannot be isolated, then go to full closed cycle operation immediately per OP 2180.

G. , Simultaneous Sulfuric Acid and Sodium Hypochlorite Spill at the Intake Structure CAUTIONS

When mixed together, sulfuric acid and sodium hypochlorite will generate chlorine gas, which is lethal. SCBA gear must be worn to approach this spill.

No individual should perform any action for which they are not trained and qualified to perform, and then only if the action can be erformed safel .

1. Evacuate the chemical treatment shed area.

a. Barricade the area to prevent personnel entry.

NOTE Additional sand may be obtained from a local excavator or contractor such as the Vernon Town Garage, Brattleboro Sand and Gravel Co., or Lane Construction Co.

2. Obtain sand from the Vermont Yankee sand shed.

OP 2106 Rev. 35 Page 18 of23

3. If possible, dike the spill to:

a. Obtain separation of the sodium hypochlorite and sulfuric acid.

b. Contain them using sandbags and sand (sandbags are located in the Stockroom and will require filling).

4. Apply copious amounts of lime or soda bicarbonate to neutralize the acid. These chemicals are stored in the Main Warehouse. A small amount of soda bicarbonate is stored at the Intake Structure.

5. Have the Chemistry Department monitor the circ water system chemistry.

CAUTION High levels of residual chlorine (>0.5 ppm) or low pH (<6.5) may kill fish.

6. If circ water residual chlorine approaches or exceeds 0.2 ppm, or circ water pH approaches or drops below 6.5, then shift to full closed cycle operation immediately per OP 2180.

H. Simultaneous Sulfuric Acid and Sodium Bromide Spill at the Intake Structure CAUTIONS

When mixed together, sulfuric acid and sodium bromide will generate bromine gas, which is lethal. SCBA gear must be worn to approach this spill.

No individual should perform any action for which they are not trained and qualified to perform, and then only if the action can be erformed safel .

1. Evacuate the chemical treatment shed area.

a. Barricade the area to prevent personnel entry .

.-. OP 2106 Rev. 35 Page 19 of23

NOTE Additional sand may be obtained from a local excavator or contractor such as the Vernon Town Garage, Brattleboro Sand and Gravel Co., or Lane Construction Co.

2. Obtain sand from the Vermont Yankee sand shed.

3. If possible, dike the spill to:

a. Obtain separation of the sodium bromide and sulfuric acid.

b. Contain them using sandbags and sand (sandbags are located in the Stockroom and will require filling).

4. Apply copious amounts of lime or soda bicarbonate to neutralize the acid. These

chemicals are stored in the Main Warehouse. A small amount of soda bicarbonate is stored at the Intake Structure.

5. Have the Chemistry Department monitor the circ water system chemistry.

CAUTION If H in the river dro s below 6.5 fish ma be killed.

6. If the sodium bromide leak can not be isolated, or circ water pH approaches or drops below 6.5, then shift to full closed cycle operation immediately per OP 2180.

~ -~ ' t ~ **, *~: ***

OP 2106 Rev. 35 Page 20 of23

I. Nitrogen Leak CAUTIONS

Liquid nitrogen is a cryogenic liquid (substance with very low temperature). Do not approach liquid without proper protective equipment.

Do not approach a large nitrogen leak without SCBA gear. A nitro en atmos here will not su ort life.

1. Nitrogen is not a hazard once gasified and dissipated in the air.

a. If the leak cannot be safely isolated, keep all personnel clear and allow tank to empty itself.

2. Alternate means of venting may be used to expedite tank draining to effect repairs.

J. Toxic Airborne Release

1. Upon notification of a toxic gas or chemical release on or offsite that may affect Control Room habit~bility, Control Room personnel shall:'

a. Place CONTROL ROOM HVAC RECIRC MODE SELECT switch to EMER.

b. Announce the condition over the Gai~Tronics, and if necessary order evacuation of affected areas.

c. Don Scott air packs.

2. Request RP personnel sample the Control Room atmosphere and other inhabited plant areas.

3. Notify one of the outside assistance contacts listed on Appendix A of the situation and, if required, request their assistance.

4. Make arrangements to have an adequate supply of bottled air available in the Control Room for the estimated duration of the release.

5. When conditions warrant notify the Control Room to:

a. Return CONTROL ROOM HVAC RECIRC MODE SELECT switch to NORMAL.

b. Remove Scott air packs.

OP 2106 Rev. 35 Page 21 of23

K. Mercury Spills CAUTION Use of a non-mercury rated vacuum or a broom may spread mercury contamination. Use mercury designated spill kits to cleanup mercury spill debris. Mercury spills should be cleaned up as soon as racticable to revent eva oration.

1. Broken Fluorescent Bulbs CAUTION

a. Carefully collect the broken bulb fragments.

b. Transfer of debris to a designated broken bulb accumulation container will be performed by the Chemistry Hazmat Group.

2. Small Mercury Spill {<2 Tablespoons)

NOTE Spill kits for cleanup of small mercury spills are located in the Hazmat Supply Trailer. Chemistry Technicians are trained in the use of the spill kit.

a. Consider ventilating enclosed or confined spill areas or use of respirators, as appropriate.

b. If mercury vapors are suspected to be present in the atmosphere, monitor the atmosphere in the spill area.

c. Don appropriate level of PPE. (Gloves, Tyvek suits, etc.)

d. Using a mercury spill kit or equivalent, carefully collect all the mercury beads. Beads may be picked up by collecting with a squeegee or cardboard, an eyedropper or a small mercury vacuum flask, or by tape press.

e. Place mercury into an unbreakable plastic container.

1r11..,i-i'~-*..,......_. .. . *I*

OP 2106 Rev. 35 Page 22 of23

f. Consider removal and disposal of mercury contaminated items like carpeting and clothing.

g. Collect mercury and spill cleanup residue for disposal by Chemistry Hazardous Waste group and label the materials as "Mercury Waste".

3. Large Mercury Spill (>2 Tablespoons)

a. Isolate area and contain spill.

b. Report spill to Vermont DEC Waste Management Division at 802.,241-3888 during working hours or call the 24 Hour Emergency Hotline at 802-244-8721.

c. Call Clean Harbors to assist with cleanup of the spill.

L. Hazardous Waste Spill Response Equipment The site Hazardous Waste Coordinator shall periodically:

1. Verify the location and accessibility of hazardous material spill response equipment. (CR-VTY-1995-00573 CA-04)

2. Verify the physical condition of the container and adequacy of supplies as listed on Appendix E.

FINAL CONDITIONS

1. All oil or hazardous material, once contained, is cleaned up and all contaminated soil or absorbent treated as waste per AP 0526.

2. Spill Report Record in Appendix F (or similar) to this procedure completed and routed.

3. Condition Report submitted per EN-LI-102.

4. Protective clothing (turnout gear) and equipment cleaned or replaced.

5. Responsibility assigned to inspect, replace, or repair as necessary, all emergency equipment for reuse.

6. Control Room HV AC returned to normal when conditions permit.

7. Provisions made to restock Scott air bottles.

8. After clean-up, return valves to *normal position.

OP 2106 Rev. 35 Page 23 of23

TABLE 1 MANHOLE/ISOLATION VALVE LOCATIONS Item Location DMHA Approximately 18 feet southwest of the main entrance leading to the pl:;int's Administration Building (26 inch manhole).

DMHA Approximately 4 feet northwest ofMH A (12 inch pipe w/orange cover).

discharge valve DMHB Approximately 6 feet southwest of the northwest comer of the Auxiliary Offgas Building (28 inch manhole),*

DMHB Approximately 4 feet southwest of the southwest comer of the Auxiliary Offgas discharge valve Building (7 inch pipe, cap stamped "WATER").

DMHC Approximately 4 feet east of Fire Hose House 7 (east of northeast comer of Administration Building) (28 inch manhole).

DMHC Approximately 6 feet southeast of MH C (8 inch pipe, cap stamped "WATER").

discharge valve DMH-33 Near 115KV Switchyard High Voltage Tower.

V-YARD-12 DMH-44 Near Low Level Radwaste Storage Facility Northeast.

V-YARD-10 DMH-45 Near Circ Water Discharge Structure North. Wall.

V-YARD-11 Table 1

. -* * ,--r:.J:~ * ..,,,. . * * ; -~~ . .,..: , ** ~. *._ - I"*V * '!

OP2106 Rev. 35 Page 1of1

J APPENDIX A OUTSIDE ASSISTANCE CONTACTS

1. Primary Contact Clean Harbors Environmental Services, Inc.

42 Longwater Drive P.O. Box 9149 Norwell, MA 02061-9149 781-792-5000 24-hour phone: 1-800-0ILTANK (1-800-645-8265)

2. For Chemical Emergency Information (Ingestion)

CHEMTREC 800-424-9300 (24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Number)

Appendix A

'""-**OP 2106 Rev. 35 Page 1of1

APPENDIXB HAZARDOUS WASTE AND SAFETY COORDINATOR CONTACT LIST

1. Hazardous Waste Coordinator

a. Primary:

LynnDeWald Cell: (802) 380-4493 Plant Ext: 5526

b. Alternate:

Kevan Whippie, Chemistry Supervisor Cell: (603) 852-3443 Home: (603) 239-6953 Pager: (802) 742-9053 Plant Ext: 5682

2. Safety Coordinator

a. Primary Larry Y oungless Cell: (207) 415-0677 Plant Ext.: 5702 Appendix B OP 2106 Rev. 35 Page l of l

APPENDIXC VAL VE LINEUP Valve Number Description Position Initial Northeast of Low Level Radwaste Storage Area V-YARD-10 North Storm Drain Discharge Isolation Valve atDMH-44 OPEN Near CW Discharge Structure V-YARD-11 South Storm Drain Discharge Isolation Valve atDMH-45 OPEN South of 115KV Switchyard V-YARD-12 Switchyard Storm Drain Discharge Isolation Valve at DMH-33 OPEN V-YARD-13 DMH-A Outlet Isolation Valve CLOSED V-YARD-14 DMH-B Outlet Isolation Valve CLOSED V-YARD-15 DMH-C Outlet Isolation Valve CLOSED Remarks:

Shift Manager (Print/Sign) Date AppendixC T 'l,r' '

~-

, ; ~ *, .. ~

. *_., OP 2106 Rev. 35 Page 1 of 1

APPENDIXD Vermont Yankee Nuclear Power Station Spill Prevention Control and Countermeasures (SPCC) Plan Revislon9 Professional En1lneer Certlf!qtlgg [40CFR112.3(d))

I hereby certify that I have examined the facility and being familiar with the provisions of 40CFR112, attest that this SPCC Plan has been prepared In accordance with good engineering practices, Including consideration of applicable Industry standards and with the requirements of these parts, that procedures for required Inspections and testing have been established and that the Plan fs adequate for the faclllty.

NAME: John B. Goodell TITLE: Professiond Engineer

'\

Reglstere Professional Engineer, State of Vermont Date: July 19, 2013 Certificate No.: B098 D~r.1;1~*11, be implemented as horein described:

Si ature/Date:

Name: V1ntmt Rular.<a.ra.

Title:

General Manager. Plant Onerations AppendixD OP2106 Rev. 35 Page 1 of51

APPENDIX D (Continued)

REGULATORY REFERENCE CROSS INDEX Topic Regulatory Citation SPCC Section SPCC Plan Purpose 40CFR112.1 1.1 Applicability (Containers/Tanks) 40CFR112.l(b) 1.2 General Plant Information None 2.0 P .E. Certification 40CFR112.3(d) Cover Page EPA SPCC Plan Amendments 40CFR112.4(a) 3.1.1 40CFR112.4(c) 3.1.2 40CFR112.4(e) 3.1.3 Facility SPCC Plan Amendments 40CFR112.5(a) 3.2 SPCC Plan Reviews 40CFR112.5(b) 3.3 Professional Engineer Certification 40CFR112.5(c) 3.4 SPCC GENERAL REQUIREMENTS 40CFR112.7 4.0

Facility Conformance 40CFR112.7(a)(l) 4.1 40CFR112.7(a)(2)

Facility Layout 40CFR112.7(a)(3) 4.2.1

Type of oil and gasoline containers 40CFR112.7(a)(3)(i) 4.2.2 and storage capacity

Discharge prevention measures for 40CFR112.7(a)(3)(ii) 4.2.3 loading/unloading _,.

Discharge and drainage controls 40CFR112.7(a)(3)(iii)

I 4.2.4

Countermeasures for discharge 40CFR112.7(a)(3)(iv) 4.2.5 discovery, response and cleanup

Disposal of recovered material 40CFR112.7(a)(3)(v) 4.2.6 c

Contact list and phone numbers 40CFR112.7(a)(3)(vi) 4.2.7

Reporting procedures 40CFR112.7(a)(4) 4.3.1

Response procedures 40CFR112.7(a)(5) 4.3.2

Equipment Failures 40CFR112.7(b) 4.4 Appendix D

- I I' " OP 2106 Rev. 35 Page 2 of51

APPENDIX D (Continued)

REGULATORY REFERENCE CROSS INDEX Topic Re2ulatory Citation SPCC Section

Containment/Diversionary Devices 40CFR112.7(c) 4.5.1

Demonstration of impracticability & 40CFR112.7(d) 4.5.2 contingency plan

Inspections, Tests & Records 40CFR112.7(e) 4.6 Personnel Training & Discharge 40CFR112.7(t) 4.7 Prevention Procedures

Personnel Training 40CFR112.7(t)(l) 4.7.1 & 4.7.2

Spill prevention designee 40CFR112.7(t)(2) 4.7.3

Spill prevention briefings 40CFR112.7(t)(3) 4.7.4 Security 40CFR112. 7(g) 4.8

Fencing and locked or guarded 40CFR112.7(g)(l) 4.8.1 entrance gates

Locked master flow and drain valves 40CFR112.7(g)(2) 4.8.2

Locked or secured oil pump starter 40CFR112.7(g)(3) 4.8.3 controls

Capped or flanged loading/unloading 40CFR112.7(g)(4) 4.8.4 connections

Facility lighting 40CFR112.7(g)(5) 4.8.5 Loading/Unloading Procedures 40CFR112.7(h) 4.9

Containment drainage for truck 40CFR112.7(h)(l) 4.9.1 loading/unloading

Prevention of vehicle departure 40CFR112.7(h)(2) 4.9.2 before complete disconnection

Examination of drain* and outlets 40CFR112.7(h)(3) 4:9.3 prior to filling and departure

Field-Constructed Aboveground 40CFR112.7(i) 4.10 Tanks

Compliance with State regulations 40CFR112.7G) 4.11 Appendix D OP 2106 Rev. 35 Page 3of51 .

APPENDIX D (Continued)

REGULATORY REFERENCE CROSS INDEX Topic Re2ulatory Citation SPCC Section Facility Drainage 40CFR112.8(b) 4.12

Inspection of retained storm water 40CFR112.8(b)(l) 4.12.1 prior to discharge

Drainage from diked areas 40CFR112.8(b)(2) 4.12.2

Drainage from undiked areas 40CFR112.8(b)(3) 4.12.3

Diversion system for final discharge 40CFR112.8(b)(4) 4.12.3

Use of lift pumps for facility drainage 40CFR112.8(b)(5) 4.12.4 system Bulk Storage Containers 40CFR112.8(c) 4.13

Compatib~lity of storage tank with oil 40CFR112.8(c)(l) , 4.13.1

Secondary containment 40CFR112.8(c)(2) 4.13.2

Rainwater or effluent bypass 40CFR112.8(c)(3) 4.13.3 (inspection and record keeping)

Underground tanks cathodic 40CFR112.8(c)(4) 4.13.4 protection an leak testing

Partially buried/bunkered tanks 40CFR112.8(c)(5) 4.13.4 cathodic protection

Testing and inspection of 40CFR112.8(c)(6) 4.13.5 aboveground tanks

Control of leakage through defective 40CFR112.8(c)(7) 4.13.6 internal heating coils

Tank overfill protection 40CFR112.8(c)(8) 4.13.7

Observation of effluent discharges to 40CFR112.8(c)(9) 4.13.8 waters

Correction of visible oil leaks 40CFR112.8(c)(10) 4.13.9

Positioning of mobile or portable oil 40CFR112.8(c)(l 1) 4.13.10 storage tanks Appendix D OP 2106 Rev. 35 Page 4of51

APPENDIX D (Continued)

REGULATORY REFERENCE CROSS INDEX Topic Re2ulatory Citation SPCC Section Transfer Operations 40CFR112.8(d) 4.14

Cathodic protection of buried piping 40CFR112.8(d)(l) 4.14.1

Capping of out-of-service pipeline 40CFR112.8(d)(2) 4.14.2

Design of pipe supports 40CFR112.8(d)(3) 4.14.3

Examination and testing of 40CFR112.8(d)(4) 4.14.4 aboveground valves and pipelines

Warnings for aboveground piping 40CFR112.8(d)(5) 4.14.5 Facility Response Plan Applicability 40CFR112.20(e) 6.0 Appendix D

' ' OP 2106 Rev. 35 Page 5 of SI

APPENDIX D (Continued)

TABLE OF CONTENTS Section Title Page 1.0 PURPOSE AND APPLICABILITY........................................................ 7 2.0 GENERAL PLANT INFORMATION.................................................... 7 3.0 SPCC PLAN AMENDMENTS AND REVIEWS................................... 8 3.1 EPA Amendments....................................................................................... 8 3.2 Facility Amendments................................................................................... 8 3.3 S.PCC Plan Reviews .................................................................................... 9 3.4 Professional Engineer Certification............................................................. 9 4.0 SPCC GENE~ REQUIREMENTS.................................................... 9 4.1 Facility Conformance.................................................................................. 9 4.2 VYNPS Facility Information....................................................................... 10 4.3 Reporting & Response Procedures.............................................................. 13 4.4 Equipment Failures...................................................................................... 14 4.5 Containment Measures ................................................................................ 14 4.6 Inspections, Tests & Records...................................................................... 14 4.7 Personnel Training ...................................................................................... 17 4.8 Security........................................................................................................ 19 4.9 Loading/Unloading Procedures................................................................... 20 4.10 Field-Constructed Aboveground Tanks...................................................... 20 4.11 Additional Prevention Standards................................................................. 21 4.12 Facility Drainage......................................................................................... 22 4.13 Bulk Storage Containers.............................................................................. 24 4.14 Facility Transfer Operations........................................................................ 27 5.0 PRODUCT STORAGE INFORMATION.............................................. 28 5.1 Tanks........................................................................................................... 28 5.2 Transformers ............................................................................................... 34 5.3 Hydraulic Devices....................................................................................... 41 5.4 Circuit Breakers........................................................................................... 41 5.5 Gearboxes.................................................................................................... 42 5.6 Miscellaneous Containers............................................................................ 42 6.0 FACILITY RESPONSE PLAN APPLICABILITY............................... 43 FIGURE 1, Facility Layout & Product Storage Locations (Oils)

FIGURE 2, Facility Layout & Product Storage Locations (Chemicals, Hazardous Wastes & Mixed Wastes)

FIGURE 3, Manhole Layout TABLE 1, Potential Discharge Volumes and Direction of Flow SPCC Plan Review Form Certification of Substantial Harm Certification Appendix D OP 2106 Rev. 35 Page 6of51

APPENDIX D (Continued) 1.0 PURPOSE AND APPLICABILITY 1.1. The purpose of this Spill Prevention, Control and Countermeasure (SPCC) Plan (also referred to as the Plan) is to identify and describe the procedures, materials, equipment and facilities that are utilized at the Vermont Yankee Nuclear Power Station (VYNPS) to minimize the frequency and severity of oil spills [40CFR112.1]

1.2. SPCC requirements are applicable to the following containers [40CFR112.l(b)]:

Aboveground containers that are 55 gallons or greater in capacity.

NOTE Per 40CFR112.2, Oil filled electrical operating or manufacturing equipment is not considered a bulk storage container, therefore 100%

s ill containment is not re uired.

Completely buried tanks not subject to ALL the technical requirements of 40CFR280 or a 40CFR28 l State program.

Containers used for standby storage, seasonal storage or temporary storage, or not otherwise "permanently closed"

Any "bunkered tank" or "partially buried tank, or any container in a vault, each of which. is considered an aboveground storage container.

2.0 GENERAL PLANT INFORMATION 2.1. General plant information is listed below:

A. Name of Facility: Vermont Yankee Nuclear Power Station B. Facility Owner: I Entergy Nuclear Vermont Yankee, LLC

c. Facility L.ocation: Governor Hunt Road Vernon, Vermont D. Facility

Description:

On-Shore Facility - Nuclear Fuel Steam Electrical Generation E. Initial Facility Operation: March 1972 F. Nearest Receiving Water: Connecticut River Appendix D

.. ' OP 2106 Rev. 35

, l,_.. /If Page 7 of51

APPENDIX D (Continued) 3.0 SPCC PLAN AMENDMENTS AND REVIEWS 3.1. EPA Amendments 3 .1.1. If VYNPS discharges more than 1,000 U.S. gallons of oil in a single discharge or discharged more than 42 U.S. gallons of oil in each of two discharges occurring within any twelve month period, submit the following information to the EPA within 60 days: [40CFR112.4(a)]

Name of facility.

Your name.

Location of facility.

Maximum storage or handling capacity of facility and normal daily throughput.

Corrective action and countermeasures taken, including description of equipment repairs and replacements.

Adequate description of facility, including maps, flow diagrams, and topographical maps, as necessary.

Cause of discharge, including a failure analysis of system or subsystem in which failure occurred.

Additional preventive measures taken or contemplated to minimize possibility of recurrence.

Such other information as the EPA may reasonably require pertinent to Plan or discharge.

3.1.2. State agency or agencies in charge of oil pollution control activities should be on copy for all information provided to the EPA. [40CFR112.4(c)]

3.1.3. IfEPA notifies the facility that an amendment is necessary, the SPCC Plan must be amended within 30 days after the notice, unless otherwise specified, and implemented no later than six months after the amendment. [40CFR112.4(e)]

3.2. Facility Amendments [40CFR112.5(a)]

3 .2.1. VYNPS must amend the SPCC Plan whenever there is a change in facility design, construction, operation or maintenance that materially affects it potential for a discharge. The amendment must be prepared within six months and implemented as soon as possible but no later than six months following preparation of the amendment.

Appendix D OP 2106 Rev. 35 Page 8 of51

APPENDIX D (Continued) 3.3. SPCC Plan Reviews [40CFR112.5(b)]

3.3.1. VYNPS must review and evaluate the SPCC at least once every five years and if necessary, amended within six months of the review to include more effective prevention and control technology ifthe technology has been field-proven at the time of the review and will significantly reduce the likelihood of a discharge.

Amendments must be implemented as soon as possible, but not later than six months.

3.3.2. SPCC Plan reviews and evaluations must be documented on a SPCC Plan Review Form similar to that shown in the Appendix to this Plan. This review form must be maintained on file and made available for review if requested by the appropriate regulatory agency.

3.4. Professional Engineer Certification [40CFR112.5(c)]

3.4.1. Professional Engineer must certify any technical amendments to the SPCC Plan after conducting a site visit to review controls implemented.

4.0 SPCC GENERAL REQUIREMENTS [40CFR112.7]

4.1. Facility Conformance [40CFR112.7(a)(l) and 40CFR112.7 (a)(2)]

4.1.1. The VYNPS SPCC Plan has been developed in accordance with the requirements and guidelines for preparation of SPCC Plans described in 40CFR112 (as amended July 17, 2002). The purpose of this Plan is to establish procedures and methods that will prevent and control, and define countermeasures to be implemented for the spillage from oil-filled equipment or oil bulk storage tanks. The ultimate goal of this Plan is to minimize the risk of a discharge into navigable waters of the United States and waters of the State of Vermont. This Plan has the approval of Management at a level of authority necessary to commit the required resources for proper implementation and has been prepared in accordance with good engineering practices. This Plan meets the guidelines described in 40CFR112. Although not required, VYNPS has identified some selected bulk chemical locations on Figure 2 to supplement the implementation of OP 2106, "Oil and Hazardous Materials Spill Prevention and Control".

Appendix D

,_, ' . '., ... *-c* ~ W ~OJ_ ,, * ~ *"* * .- * ~

OP 2106 Rev. 35 Page 9of51

APPENDIX D (Continued) 4.2. VYNPS Facility Information 4.2.1. Layout of the VYNPS facility is shown in Figure 1 to this Plan.

[40CFR112. 7(a)(3)]

4.2.2. Oil and gasoline storage locations present on the VYNPS site are identified in Figure 1 to this Plan. Storage capacities for these locations are discussed in Section 5.0 to this Plan. [40CFR112.7(a)(3)(i)]

4.2.3. Discharge prevention measures including procedures for routine handling of oil and gasoline products are incorporated into overall plant operations and are administratively controlled by the site procedures listed below:

[40CFR112.7(a)(3)(ii)]

VYNPS Procedure OPOP-F0-2195, "Fuel Oil Transfer System" which requires Operations personnel to be present during the diesel fuel oil transfer, verification of delivery receipts, ensuring that the storage tank can accept the delivered volume, covering of nearby storm drains, proper alignment of valves, and proper connecting and disconnecting of fill pipe.

VYNPS Procedure AP 4801, "Management of Underground Storage Tanks" which requires Maintenance department personnel to be present during diesel fuel oil and gasoline filling or transfer operations involving the underground storage tanks to ensure that there are no overflows, spills or leaks to the environment and that the operation complies with the Vermont Yankee Safety Manual.

VYNPS Procedure RP 2163, "Lube Oil Purification" which requires Operations department personnel to be present during the lube oil transfer operations, establishment of communication between tanker and lube oil

' room, proper alignment of valves and proper operation of transfer pump.

Additional prevention measures include the following:

Tank Overfill - The diesel fuel oil tanks are equipped with alarms that alert personnel to potential overfilling conditions. In addition, visual level gauges are utilized.

Appendix D c* _,_ * .,OP 2106 Rev. 35 Page 10 of51

APPENDIX D (Continued)

Mobile/Portable Tanks (2::55 gallons)- VYNPS has one 500 gallon double walled portable tank that remains on-site at all times and one 1000 gallon double walled portable tank that is stationed by the salt shed in the North parking lot. The tanks are self contained and designed for towing behind a vehicle. ERCN 001 to ER 05-517 replaced a single walled mobile oil tank in Fall 2005. A second 120 gallon double walled portable diesel tank is available for use on special projects. When not in use, this diesel tank is stored empty. Additional portable tanks may be utilized on-site for purposes of refueling operations or* temporary storage of oil but shall be stored empty. Although these tanks are staged at locations where a discharge could be promptly addressed utilizing absorbents available at the site to prevent a discharge to water, preventative measures such as blocking off drains, situating tank on concrete or blacktop surfaces, installing temporary containment measures and monitoring daily for leakage are implemented.

Permanent Check Dams, Spill Kits, and Manhole Covers Permanent check dams have been installed at manholes.DMH-I and DMH-32, located in the Northern V-ditch surrounding the 345KV Switchyard. The check dams consist of rebar and concrete .reinforced cinderblock with two layers of a geotextile fabric installed around the perimeter that absorbs oil while allowing water to flow through to the drain. In addition, a spill kit resides in the area between the two outfalls.

In addition, two appropriately sized manhole covers, located in bright yellow plastic carrying/storage cases, hang in the vicinity of the manholes and would be place over them if oil threatens to reach either or both manholes.

A permanent check dam has been installed at manhole DMH-20A2 located between the Vernon Hydro Tie Transformer and the West Cooling Tower Transformer. The check dam consists of concrete reinforced cinderblock with two layers of geotextile fabric installed around the perimeter that absorbs oil while allowing water to flow through to the drain. A spill kit resides between these two transformers and a manhole cover, located in a bright yellow plastic carrying/storage case, hangs in the vicinity, and would be place over DMH-20A2 if oil threatens to enter the manhole.

Discovery of Leaks - If leaks are discovered that results in oil accumulation, the accumulated material is removed and disposed of appropriately. A Condition Report is initiated in accordance with NMM Procedure EN-LI-102, "Corrective Action Process" to correct and track the condition.

Appendix D OP 2106 Rev. 35 Page 11 of 51

APPENDIX D (Continued) 4.2.4. Discharge and drainage controls that exist for oil and gasoline storage containers located on the VYNPS site are discussed in Section 5 .0 to this Plan. As already stated in Section 4.2.3 of this Plan, spill prevention measures are established for unloading of oils and gasoline in accordance with site procedures. In the event of a discharge, spill response supply locations are identified in VYNPS Procedure OP 2106, "Oil and Hazardous Materials Spill Prevention and Control" and response personnel are briefed on their locations.

[40CFR112.7(a)(3)(iii)]

4.2.5. Countermeasures for discharge discovery, response and cleanup are incorporated into overall plant operations and are administratively controlled by VYNPS Procedure OP 2106, "Oil and Hazardous Materials Spill Prevention and Control". This procedure prescribes the steps to be taken in the event of a spill, and outlines notification, response and cleanup actions. [40CFR112.7(a)(3)(iv)]

4.2.6. Disposal of recovered spill materials is managed in accordance with Entergy Nuclear Procedure EN-EV-106, "Waste Management Program", as guidance.

This procedure prescribes the requirements that the site must follow when managing and disposing of generated waste. [40CFR112.7(a)(3)(v)]

4.2.7. Contact list and phone numbers for site spills are as follows:

[40CFR112.7(a)(3)(vi)]

Facility Response Coordinator - At VYNPS, all spills are reported to the Shift Manager via the Gai-Tronics System on Line 4 or by phone (Extension 5270) in accordance with Section A. I of VYNPS Procedure OP 2106, "Oil and Hazardous Materials Spill Prevention and Control".

The Shift Manager then notifies the Hazardous Waste Coordinator and Safety Coordinator utilizing the contact list in Appendix B of VYNPS Procedure OP 2106 (Oil and Hazardous Materials Spill Prevention and Control).

I

National Response Center - Refer to Section A. 7 of VYNPS Procedure OP 2106 (Oil and Hazardous Materials Spill Prevention and Control) for this number..

Other Federal, State and Local Agencies - Refer to Sections A.7 and A.8 ofVYNPS Procedure OP 2106 (Oil and Hazardous Materials Spill Prevention and Control) for these numbers.

Cleanup Contracto'rs-Refer to Appendix A ofVYNPS Procedure OP 2106 (Oil and Hazardous Materials Spill Prevention and Control) for these numbers.

Appendix D

. 1 ;.~

OP 2106 Rev. 35 Page 12of51

APPENDIX D (Continued) 4.3. Reporting and Response Procedures 4.3.1. Reporting related to spills is procedurally controlled in accordance with VYNPS Procedures OP 2106, "Oil and Hazardous Materials Spill Prevention and Control" and AP 0010, "Situational Reporting Requirements". These procedures specify the process for required reporting to offsite regulatory agencies in the event of a spill. [40CFR112.7(a)(4)]

4.3.2. Spill responses are procedurally controlled in accordance with VYNPS Procedure OP 2106 (Oil and Hazardous Materials Spill Prevention and Control).

This procedure outlines the notification and response actions to be taken in the event of a spill. [40CFR112.7(a)(5)]

4.4. Equipment Failures [40CFR112.7(b)]

4.4.1. The anticipated quantity of oil and gasoline that could o'ccur in the event of a spill and the predicted flow direction is described Section 5.0 and Figures 1 and

. 3 to this Plan.

4.5. Containment Measures 4.5.1. Oil and gasoline containers at the VYNPS site are equipped with containment devices or other diversionary structures as described in Section 5.0 to this Plan.

In addition, response personnel are briefed on the locations of spill response materials that are identified in Appendix E to VYNPS Procedure OP 2106, "Oil and Hazardous Materials Spill Prevention and Control" should a spill event occur. [40CFR112.7(c)]

4.5.2. If containment or diversionary structures are not practicable for containers, then VYNPS will: [40CFR112.7(d)]

Follow the contingency plan outlined in VYNPS Procedure OP 2106 (Oil and Hazardous Materials Spill Prevention and Control).

Commit the required manpower, equipment and materials to expeditiously control and remove harmful quantities of spilled materials should a spill event occur.

Appendix D OP2106 Rev. 35 Page 13of51

APPENDIX D (Continued) 4.6. Inspections, Tests & Records [40CFR112.7(e)]

4.6.1. Plant Tours

Plant tours are conducted periodically to visually identify abnormal plant conditions (i.e., drums, tanks, valves, leakage and deterioration of .

containment structure) in accordance with VYNPS Procedure OP 0150, "Conduct of Operations and Operator Rounds". If abnormal conditions are observed, a Condition Report is initiated in accordance with NMM Procedure EN-LI-102, "Corrective Action Process" to correct and track the condition.

4.6.2. Aboveground Tanks

Although the 75,000 gallon Diesel Fuel Oil Storage Tank is located partially below *grade in a containment berm and the 12,000 gallon House Heating Boiler Fuel Tank and 1,000 gallon Gatehouse 1 gasoline tank are double-walled, preventive maintenance inspections are conducted on these tanks in accordance with VYNPS Procedure AP 0310, "I&C Surveillance, Preventive and Corrective Maintenance Program". These inspections involve draining, cleaning and inspecting the tank internals. Inspections of the 75,000 gallon Diesel Oil Storage Tank occur on a IO-year interval and for the House Heating Boiler Fuel Oil Storage Tank and 1,000 gallon gasoline tank at Gatehouse 1 inspection intervals vary since these tanks are double-walled with interstitial monitoring.

VYNPS has several other stationary oil tanks located inside buildings and covered structures that act as a back-up spill containment mechanism and that are not exposed to weather conditions. Any leaks associated with these tanks would be promptly identified in accordance with VYNPS Procedure OP 0150 (Conduct of Operations and Operator Rounds) and corrective actions taken as needed in accordance with NMM Procedure EN-LI-102 (Corrective Action Process). As a result of the location of these tanks, it is highly unlikely that a tank failure would result in oil reaching navigable waters. Therefore based on best professional engineering judgment, VYNPS will continue to rely on visual observations to verify the integrity of these tanks in accordance with the process described in Section 4.6.1 above to this Plan and VYNPS Procedures WMAP-4000 (Surveillance Testing Program), OP 4105 (Fire Protection Systems Surveillance), OP 4152 (Equipment and Floor Drain Sump and Totalizer Surveillance), OP 4195 (Fuel Oil Transfer System Surveillance) and RP 2163 (Lube Oil Purificatiop.) listed in Section 4.6.4 below to this Plan.

AppendixD

41.

OP 2106 Rev. 35 Page 14 of51

APPENDIX D (Continued)

55 gallon containers are placed on pallets and typically stored under covered areas. Container storage areas are periodically vis~ally inspected during the plant tours in accordance with the process described in Section 4.6.1 above to this Plan and EN-EV-112, "Chemical Control Program".

4.6.3. Underground Tanks

There are four double-walled fiberglass underground tanks located on the plant site that are equipped with leak detection devices. Three of the tanks are regulated by the Vermont Agency of Natural Resources underground storage tank regulations program (Chapter 8} as discussed in Section 4.11.1 below.

There are also two metallic buried Number 2 diesel fuel oil tanks located at the offsite Corporate Office in Brattleboro. These tanks are 10,000 gallon capacity each, are single-walled, ,and of metallic construction. Neither tank is equipped with corrosion protection; as such, tank tightness tests are performed every three years on these two tanks.

There is one 550 gallon underground tank at the Brattleboro corporate office. The tank is fiberglass, double-walled, and monitored by the Veeder-root system and is regulated by the Vermont Agency of Natural Resources underground storage tank regulations program.

4.6.4. Miscellaneous Inspections 4.6.4.1. Additional practices utilized in conjunction with other site activities that would identify plant equipment malfunctions or deteriorations are included in the following site procedures:

4.6.4.1.1. VYNPS Procedure WMAP-4000, "Surveillance Testing Program" for periodic testing/inspection of plant systems, components and structures to ensure continued operability 4.6.4.1.2. VYNPS Procedure OP 2501, "Used Oil Management & Furnace Operation" for used oil drums stored at the Containment Access Building and the North Warehouse 4.6.4.1.3. VYNPS Procedure OP 4105, "Fire Protection Systems Surveillance" for periodic monitoring of the fuel tank level and inspection of the general area Appendix D

. -' ~.. .. ..*....

OP 2106 Rev. 35 Page 15 of51

APPENDIX D (Continued) 4.6.4.1.4. VYNPS Procedure OP 4152, "Equipment and Floor Drain Sump and Totalizer Surveillance" for providing early detection of abnormal sump operation \.

4.6.4.1.5. VYNPS Procedure OP 4195, "Fuel Oil Transfer System Surveillance" for periodic testing of the fuel transfer system associated with the 75,000 gallon Diesel Fuel Oil Storage Tank 4.6.4.1.6. VYNPS Procedure RP 2163, "Lube Oil Purification" for periodic inspections associated with the lube oil system 4.6.5. Spill Supplies

Spill response supplies are periodically inventoried in accordance with VYNPS Procedure OP 2106, "Oil and Hazardous Materials Spill Prevention and Control" and replenished as necessary.

4.6.6. Aboveground Valve and Piping

Periodic inspections are conducted on aboveground valves and piping to identify potential deteriorating conditions in accordance with VYNPS Procedure OP 0150 (Conduct of Operations and Operator Rounds). If abnormal conditions are observed, a Condition Report is initiated in accordance with NMM Procedure EN-LI-102 (Corrective Actiori Process) to correct and track the condition.

4.6.7. Records

Records of inspections and testing of tanks at the VYNPS site are maintained in accordance with VYNPS Procedure AP 6805, "Document Control" for a minimum' of three years.

Appendix D OP 2106 Rev. 35 Page 16 of51

APPENDIX D (Continued) 4.7. Personnel Training [40CFR112.7(t)]

4.7.1. Site-Wide Personnel Training [40CFR112.7(t)(l)]

All site employees are trained to the "First Responder- Awareness Level" annually during the General Employee Training process, which also includes a written test. This training instructs personnel to immediately notify the Control Room upon discovering a leak or spill and to report improper operating practices and deteriorating storage conditions that could lead to a spill.

In addition, as part of the annual General Employee Training, employees and contractors are required to complete an Environmental Awareness training computer based module. This module addresses the SPCC program, including discharges prevention briefings, and satisfies the regulatory training requirements associated with this program.

4.7.2. Site-Specific Personnel Training [40CFR112.7(t)(l)]

Plant procedures, including OP 2106, Oil and Hazardous Materials Spill Prevention and Control", are utilized at the VYNPS site for the operation and maintenance of oil-related equipment. Department personnel involved with these type act,ivities receive training on the procedures.

Fire Brigade members at VYNPS are qualified at "First Responder -

Operations Level" and receive annual refresher training.

Site-specific VYNPS employees are qualified at "Hazardous Materials -

Technician Level" and receive annual refresher training.

Personnel acting as the Hazardous Waste Coordinator and who may be involved in an emergency response to a hazardous substance release receive more in-depth training.

I .

4.7.3. Spill Prevention Designee [40CFR112.7(t)(2)]

The General Manager, Plant Operations is designated as having the responsibility for oil spill prevention at VYNPS.

Appendix D OP 2106 Rev. 35 Page 17 of51

APPENDIX D (Continued) 4.7.4. Spill Prevention Briefings [40CFR112.7(f)(3)]

Spill prevention briefings consisting of SPCC Plan revisions, spill events or failures, or malfunctioning components when applicable, are included as part of the Environmental Awareness training module discussed in Step 4.7.l above to this plan.

Additional spill prevention briefings may also be conducted by any of the following methods:

4.7.4.1. During the arinual General Employee Training.

4.7.4.2. Departmental briefings for personnel involved with oil handling activities. This may be accomplished by sending out a memo with a discussion of the issue and an employee sign-up sheet to the department lead. After the lead briefs his employees on the issue, the sign-up sheet would then be returned to Radiation Protection and placed in records.

4.7.4.3. Distribution of newsletter briefings to site employees via Inside Entergy outlining spill events and spill prevention requirements.

4.7.4.4. Documented spill events utilizing the Condition Reporting system with plant management/department reviews.

4. 7.4.5. During focus group meetings consisting of environmental representatives from different nuclear sites.

4.8. Security [40CFR112.7(g)]

4.8.1. Tanks [40CFR112.7(g)(l)]

Chain link fences, with one of the fences topped with barbed wire, enclose the operating plant.

Access into the plant is controlled through gates by security officer's 24-hours per day.

The owner controlled area is patrolled routinely by plant security.

Appendix D

OP 2106 Rev. 35 -

Page 18of51

APPENDIX D (Continued) 4.8.2. Valves [40CFR112.7(g)(2)]

VYNPS Procedure OP 4321, "Instrument Valve Lineup, Tagging and Control" ensures that master flow and drain valves and other valves that will permit direct outward flow of a tank's content to the surface are either securely locked in the closed position or restrained by other positive means when in non-operating or non-standby conditions.

4.8.3. Oil Pumps [40CFR112.7(g)(3)]

VYNPS plant procedures OP 4195 (Fuel Oil Transfer System Surveillance) and RP 2163 (Lube Oil Purification) shown in Section 4.6.4 above to this Plan ensure that starter control on oil pumps are either locked in the off position or located at a site accessible only to authorized personnel when the pumps are in a non-operating or non-standby status.

4,8.4. Loading/Unloading Connections [40CFR112.7(g)(4)]

Should a piping system be out of service for an extended period of time, VYNPS would ensure that the terminal connections at the transfer point (fill point) be blank flanged and capped, as well as have the piping marked as to its origin and its "out of service" status in accordance with NMM Procedure EN-OP-102, "Protective and Caution Tagging". ~

Unloading and tank transfers are performed in accordance with Section 4.2.3 above to this Plan.

4.8.5. Facility Lighting [40CFR112.7(g)(5)]

The VYNPS site is provided with numerous floodlights and other lighting fixtures, which provide satisfactory illumination for visual detection of significant releases during hours of darkness.

The lighting described above, along with 24-hours per day security surveillance, discourages any attempts of vandalism.

Apperidix D

, . _ .. f ;- -,.- * .,:,

OP 2106 Rev. 35 Page 19of51

APPENDIX D (Continued) 4.9. Loading/Unloading Procedures [40CFR112.7(h)]

4.9.1. The management practices identified in Section 4.2.3 above to this Plan are followed during unloading activities and includes site personnel in attendance during loading/unloading and covering nearby storm drains.

[40CFR112.7(h)(l)]

4.9.2. During unloading activities, the wheels are chocked as required by Vermont Yankee's Safety Standard 309, "Vehicle Safety" to prevent premature departure of the truck. In addition, Safety Standard 307, "Barricades, Safety Signs and Tags" provides an additional means of preventing premature departure of the truck through the use of barricades. [40CFR112.7(h)(2)]

4.9.3. Prior to filling and departure, the fill pipe of the truck is verified to be disconnected and not leaking as discussed in Section 4~2.3 above to this Plan. In addition, truck drivers are required to comply with the unloading requirements specified in Section 4.2.3 above to this Plan [40CFR112.7(h)(3)]

4.10. Field Constructed Aboveground Tanks [40CFR112.7(i)]

4.10.1. VYNPS does not have any field-constructed tanks on-site. Therefore, this issue is not applicable.

4.11. Additional Prevention Standards [40CFR112. 7(j)]

4.11.1. There are no additional prevention standards since the State of Vermont relies on the 40CFR112 federal standards for the SPCC Plan preparation and implementation. Vermont Yankee has three underground diesel fuel oil storage tanks located offsite (Brattleboro Corporate Office). The emergency diesel generator storage tank is regulated by the Vermont Agency of Natural Resources. There are four onsite underground diesel fuel oil storage tanks.

Three of the four onsite underground storage tanks (John Deere Diesel and two Vehicle Diesel tanks) are regulated by the Vermont Agency ofNatural Resources underground storage tank regulations program (Chapter 8). Since this a 40CFR281 State program and the state regulated underground tanks are subject to all technical requirements of this program, 40CFR112 requirements do not apply other than marking the location of the tanks on the facility diagram to this Plan. The remaining underground tanks (Plant Support Building and Brattleboro Corporate Office) are utilized for heating purposes and are exempted from Vermont's underground storage regulations. However, these tanks are subject to 40CFR112 requirements. As a note, the Brattleboro Corporate Office tanks (and transformers) are not within the scope of this plan but are being included as a best management practice.

AppendixD

- .J~, , .,_,OP*2106 Rev. 35 Page 20 of51

APPENDIX D (Continued)

(

4.11.2. Due to security concerns associated with a nuclear facility, diagrams for-tank piping are not shown in this Plan. However, this information can be provided upon request.

4.12. Facility Drainage [40CFR112.8(b)]

4.12.1. Diked Storage Areas [40CFR112.8(b)(l)]

The 75,000 gallon diesel fuel oil storage tank is the only bulk storage container (as defined in 40CFR112.2) with a secondary containment structure exposed to rainwater. All other bulk storage containers are either double-walled or are located inside buildings and covered structures that are not exposed to rainwater and therefore do not collect rainwater.

Rainwater from the secondary containment area around the 75,000 gallon diesel fuel oil storage tank is transferred via a manually activated pump to an oil water separator. However, a Chemistry Department permit is required prior to this activity occurring. A log of these drainage events is maintained in accordance with plant recordkeeping procedures.

Although not bulk storage containers (as defined in 40CFR112.2), areas associated with the transformers are designed such that oil discharges would either be retained in the containment structure, absorbed by the crushed rocks or discharged to an oil water separator. Permanent check dams have been installed and heavy urethane manhole covers are staged in specific locations around the 115 and 345KV Switchyards and the West Cooling Tower TransformerNernon Tie Transformer, where the grade is more likely to support the drainage of oil toward nearby stormwater manholes. Additionally, each of these three systems supply alarms to the Control Room or 115KV Relay House on low oil level and would bring an oil spill to the attention of site personnel.

Secondary containment drainage associated with the 75,000 gallon diesel fuel oil storage tank and transformers is controlled in accordance with VYNPS Procedure OP 2610, "Liquid Waste Disposal" to ensure that it meets appropriate water quality standards prior to discharging.

Appendix D OP 2106 Rev. 35 Page 21 of51

APPENDIX D (Continued) 4.12.2. Drainage Valves [40CFR112.8(b)(2)]

Where applicable, only ball valves of manual and open-and-closed design are used for drainage of diked areas.

As discussed in Section 5.0 to this Plan, drainage from secondary containment associated with transformers and the 75,000 gallon diesel fuel oil storage tank either flows through an oil water separator prior to final discharge or is contained within the containment and checked prior to final discharge in accordance with VYNPS Procedure OP 2610 (Liquid Waste Disposal) as discussed in Section 4.12.1 above to this Plan.

For transformer secondary containment areas that do not drain into a separator prior to discharge, the contents are checked in accordance with VYNPS Procedure OP 2610 (Liquid Waste Disposal) to ensure water quality standards are met as discussed in Section 4.12.1 above to this Plan.

4.12.3. Undiked Areas

There is no aboveground piping located outside secondary containment as it relates to bulk storage containers and spill prevention measures are implemented during unloading activities as discussed in Section 4.2.3 above to this Plan. [40CFR112.8(b)(3)]

For those undiked areas associated with the transformers, drainage would either flow through an oil water separator or be absorbed by crushed rocks, except as noted herein in this Plan. For additional information regarding the transformers, refer to Section 5.0 to this Plan.

[40CFR112.8(b )(4)]

4.12.4. Facility Drainage System Treatment [40CFR112.8(b)(5)]

VYNPS has several onsite oil water separators that receive facility drainage. However, no pump transfer operations are associated with these systems.

Appendix D 1

- OP 2106 Rev. 35 Page 22 of51

APPENDIX D (Continued) 4.13. Bulk Storage Containers [40CFR112.8(c)]

4.13.1. Tank Construction [40CFR112.8(c)(l)]

\

Bulk storage containers used at the Vermont Yankee facility are compatible with the materials stored within them and with the conditions of storage, such* as pressure and temperature. 55 gallon containers are DOT approved and rated for storage of petroleum derived oils.

4.13.2. Secondary Containment Structures [40CFR112.8(c)(2)]

The secondary containment structure for the 75,000 gallon diesel fuel oil storage tank is designed to provide containment for the entire tank contents plus sufficient free board for rainfall.

4.13.3. Secondary Containment Drainage [40CFR112.8(c)(3)]

Management of drainage from secondary structures is discussed Section 4.12 above to this Plan.

VYNPS personnel examine diked areas prior to draining to ensure that it meets appropriate water quality standards prior to discharging in accordance with VYNPS Procedure OP 2610, "Liquid Waste Disposal".

Records of these discharges are retained in accordance with the criteria specified in VYNPS Procedure OP 2610 (Liquid Waste Disposal).

4.13.4. Buried or Partially Buried Tanks [40CFR112.8(c)(4)-40CFR112.8(c)(5)]

VYNPS has no buried or partially buried metallic tanks at the Plant site

. (corrosion protection and tank testing). However, there are two metallic buried number 2 fuel oil tanks located at the Corporate Office in Brattleboro. These tanks have a 10,000 gallon capacity each, are single walled, and or metallic construction. Neither tank is equipped with corrosion protection; as such, tank tightness tests are performed every three years on these two tanks. The Plant Support Building underground tank is double-walled fiberglass. The remaining three underground storage tanks located on-site are also double-walled fiberglass tanks and are regulated by the Vermont Agency of Natural Resources underground storage tank regulations program (Chapter 8).

Appendix D OP 21~6 Rev. 35 Page 23 of51

APPENDIX D (Continued) 4.13.5. Aboveground Tank Testing [40CFR112.8(c)(6)]

Tanks are periodically inspected as discussed in Section 4.6 above to this Plan. As discussed in Section 4.6.2, preventive maintenance inspections are conducted on the 75,000 gallon Diesel Fuel Oil Storage Tank and the 12,000 gallon House Heating Boiler Fuel Oil Storage Tank, and the 1,000 gallon gasoline tank at Gatehouse 1, - in accordance with VYNPS Procedure AP 0310, "I&C Surveillance, Preventive and Corrective Maintenance Program". These inspections involve draining, cleaning and inspecting the tank internals at set intervals.

Other stationary aboveground bulk storage containers at VYNPS are located inside buildings and covered structures that act as a back-up spill containment mechanism and that are not exposed to weather conditions.

Any leaks associated with these tanks would be promptly identified in accordance with VYNPS Procedure OP 0150, "Conduct of Operations and Operator Rounds" and corrective actions tak~n as needed in accordance with NMM Procedure EN-LI-102, Corrective Action Process. As a result of the location of these tanks, it is highly unlikely that a tank failure would result in oil reaching navigable waters. Therefore based on best professional engineering judgment, VYNPS will continue to rely on visual observations to verify the integrity of these tanks in accordance with the processes described in Sections 4.6.1 and 4.6.4 above to this Plan.

55 gallon containers are periodically visually inspected during the plant tours in accordance with the process described in Section 4.6. l above to this Plan and EN-EV-112, "Chemical Control Program".

4.13.6. Internal Heating Coils [40CFR112.8(c)(7)]

There are no internal heating coils at the VYNPS facility.

4.13.7. Fail-Safe Engineering [40CFR112.8(c)(8)]

As discussed in Section 4.2.3 above to this Plan, diesel fuel oil bulk storage containers and the l ,000 gallon gasoline tank are equipped with alarms that alert personnel to potential overfilling conditions. In addition, visual level gauges are utilized.

Liquid level sensing devices are periodically tested to ensure operability in accordance with VYNPS Procedures OPOP-F0-2195 (Fuel Oil Transfer System) AP 4801 (Management of Underground Storage Tanks) and RP 2163 (Lube Oil Purification) listed in Section 4.2.3 above to this Plan.

Appendix D OP 2106 Rev. 35 Page 24 of51

APPENDIX D (Continued) 4.13.8. Effluent Treatment Facilities [40CFR112.8(c)(9)]

Plant design is such that leaks or spills from the bulk storage containers are contained within the containment structure or sump.

Onsite oil water separators are on a periodic maintenance schedule and VYNPS personnel periodically conducts visual observations of the permitted NPDES outfalls as a means to detect possible system upsets that could cause a discharge.

4.13.9. Visible Oil Leaks [40CFR112.8(c)(10)]

Visible leaks that result in a loss of material from tank seams, gaskets, rivets or bolts would be corrected in accordance with VYNPS Procedure AP 0021, "Work Orders" and the condition documented in accordance with NMM Procedure EN-LI-102 (Corrective Action Process).

Any accumulation of waste material should be managed in accordance with Entergy Nuclear Procedure EN-EV-106, "Waste Management Pro grain", as guidance.

4.13.10. Mobile Diesel Fuel Oil Storage Tank [40CFR112.8(c)(ll)]

VYNPS has one 500 gallon and one 1000 gallon double-walled mobile diesel fuel oil tank located on-site that is utilized for fueling operations.

When these tanks are utilized for onsite fueling operations, spill prevention measures are established and nearby stormwater drains are blocked, as necessary.

Additional portable tanks may also be present on-site during outage activities for purposes of temporarily storing oil while maintenance is being performed on equipment, but shall be stored empty. These tanks are staged at locations where any leakage could be promptly addressed by using absorbents to prevent any discharge to plant outfalls. Preventative measures such as blocking off drains or installing temporary containment measures are also used as needed.

Appendix D OP 2106 Rev. 35 Page 25of51

APPENDIX D (Continued) 4.14. Facility Transfer Operations [40CFR112.8(d)]

4.14.1. Buried Piping [40CFR112.8(d)(l)]

There has been no underground piping installed or replaced after August 16, 2002 at the VYNPS site. Only the 12,000 gallon House Heating Boiler Tank and piping (installed in 1995) has cathodic protection.

4.14.2. Out-of-Service Pipeline [40CFR112.8(d)(2)]

Whenever an oil piping system is out of service for an extended period of time, VYNPS would ensure that the terminal connections at the transfer point (fill point) are blank flanged and capped in accordance with VYNPS Procedure OPOP-F0-2195, "Fuel Oil Transfer System", and/or if necessary tagged in accordance with NMM Procedure EN-OP-102, Protective Tagging.

4.14.3. Pipe Supports [40CFR112.8(d)(3)]

With the exception of the 75,000 gallon fuel oil storage tank (POST),

VYNPS pipe supports are limited to indoor locations and are designed to minimize abrasion and corrosion and allow for expansion and contraction.

A minimal amount of the POST piping is external to the building. Bollard columns protect the piping from vehicles and there is a pipe support attached to the building. In addition, any potential problems associated with abrasion or corrosion of all piping would be identified during the plant tour process described in Section 4.6.1 of this Plan that is conducted in accordance with VYNPS Procedure OP 0150, "Conduct of Operations and Operator Rounds".

4.14.4. Aboveground Valves and Pipelines [40CFR112.8(d)(4)]

The primary method for inspecting valves and pipelines occur during .the plant tours that are conducted in accordance with VYNPS Procedure OP 0150, "Conduct of Operations and Operator Rounds". Also, the procedures listed in Sections 4.2.3 and 4.6.4 above to this Plan provides additional means of verifying the int~grity of valves and pipelines. As a note, the majority of aboveground valves and pipelines associated with transporting petroleum products are located indoors.

4.14.5. Vehicular Traffic [40CFR112.8(d)(5)]

All oil transfer lines are protected from vehicular traffic due to their location or via protective Bollard columns.

Appendix D OP 2106 Rev. 35 Page 26 ofSl

APPENDIX D (Continued) 5.0 PRODUCT STORAGE INFORMATION 5.1. Tanks*

5.1.1. Diesel Fuel Oil Storage Tank: 75,000 Gallon capacity. (Fig. l-Item 1)

The Diesel Fuel Oil Storage Tank is located adjacent to and south of the Advanced Off-Gas (AOG) Building. It is surrounded by a concrete containment structure consisting of l' thick concrete walls and a concrete bottom slab.

Inside dimensions measure 33' x 33' x 11'. A storm water and oil sump pit is located in the southwest corner of this containment facility. A Chemistry Department permit is required to allow storm water to be drained after verification of oil-free water.

Storm water is transferred via a manually activated pump from the containment sump pit area, and discharged via the storm drain system to the stations discharge structure and to the river.

A small room attached to this containment facility houses pumps and piping connections associated with tank operation and also functions as a part of the containment facility. An empty sump pit will contain a spill from this area.

There are no sump pump provisions for returning oil to the Yard Drainage System.

In the event of a spill, the entire contents of the tank can be held within the containment facility. The sump pump is left in an off position.

5.1.2. Lube Oil Pump Room: -9,500 - 11,000 Gallon capacity. (Fig. 1- Item 2)

The Lube Oil Pump Room is located in the northwest corner of the Turbine Building basement. The room has a concrete floor, concrete walls, and a concrete berm across the threshold area of the access door. All floor drains in the room drain to an oil sump located in the southwest comer of the room. In the event of a tank rupture or spill, approximately 5,000 gallons of oil would be contained in the room itself while the total volume of oil stored in the room would be contained within the building.

A Lube Oil Intake/Discharge Box is located outside the Turbine Building and south of the entrance leading to the Administrative Building. This box allows for both filling and draining of oil. Any spill within this box will drain via a 2" diameter drain line to Oil Separator No. OSMH-A, which has a capacity of 1,500 gallons (VY drawing G-191609) .

~. '

AppendixD OP 2106 Rev. 35 Page 27 of51

APPENDIX D (Continued) 5.1.3. Diesel Generator Day Tanks (2): 800 Gallon capacity each. (Fig. 1- Item 3)

Two Diesel Generator Day Tanks each containing up to 800 gallons of fuel/diesel oil is located in the Turbine Building. Each tank is contained within its own locked concrete block room. A concrete berm is located across the entrance door threshold area of these rooms. ./

Any oil spilled in the containment area of the Diesel Generator Day Tanks is purposely directed to the floor drains within each Tank Room via a 4" diameter pipe and then to Oil Separator No. OSMH-B. The capacity ofOSMH-B is approximately 1,500 gallons (See VY drawing G-191609). Any oil discharged through this line would be retained at the separator behind a baffle located within the lower tank. If the combination of water and oil exceeded 1,500 gallons, the oil would back up in the drains and into the Emergency Diesel Rooms and potentially the House Heating Boiler Room, as these three rooms share a common drain line. If oil backed up into any of these rooms, it would be contained within the room since each room has a concrete berm located across the entrance door threshold.

At some time in the past, OSMH-B was radiologiC'ally contaminated and since that time, any water drained from the oil separator is pumped to the. Condensate Storage Tank (CST) moat, which drains to Radwaste. No water from this oil separator is discharged to the river. If oil was present in the oil separator, it would be transferred to 55 gallon drums and disposed of as radiological waste.

The discharge valve from OSMH-B is maintained in the closed position.

5.1.4. Diesel Generator Lube Oil Storage Tanks (2): 275 Gallon capacity each.

(Fig. 1-Item 4)

Two Diesel Generator Lube Oil Storage Tanks each containing up to 275 gallons of lubricating oil is located in the Turbine Building. Each tank is contained within an enclosed concrete and concrete block room (Diesel Generator Room). A concrete berm is located across the threshold of each entrance to the room.

Any oil spilled in the containment area of the Lube Oil Storage Tank is purposely directed to the floor drains within each Tank Room via a 4" diameter pipe and then to Oil Separator No. OSMH-B. The capacity ofOSMH-B is approximately 1,500 gallons. Any oil discharged through this line would be retained at the separator behind a baffle located within the lower tank. In the unlikely event that the combination of water and oil exceeded 1,500 gallons, the oil would back up in the drains and into the Emergency Diesel Rooms and potentially the House Heating Boiler Room, as these three rooms share a common drain line. If oil backed up into any of these rooms, it would be contained within the room since each room has a concrete berm located across the entrance door threshold. *

_-,* :*_ *- *~:.:*.,. ,* ** c **

Appendix D OP 2106 Rev. 35 Page 28of51

APPENDIX D (Continued)

At some time in the past, OSMH-B was radiologically contaminated and since that time, any water drained from the oil separator is pumped to the Condensate Storage Tank (CST) moat, which drains to Radwaste. No water from this oil separator is discharged to the river. If oil was present in the oil separator, it would be transferred to 55 gallon drums and disposed of as radiological waste.

The discharge valve from OSMH-B is maintained in the closed position.

5.1.5. Diesel Generator Lube Oil Sumps (2): 250 Gallon capacity each.

(Fig. 1 -Item 4)

Two Diesel Generator Lube Oil Sumps each containing up to 250 gallons of lubricating oil is located in the Turbine Building. Each sump is contained within an enclosed concrete block room (Diesel Generator Room). A concrete berm is located across the threshold of each entrance to the room.

Any oil spilled in the containment area of the Diesel Generator Lube Oil Sumps 1

is purposely directed to the floor drains within each Tank Room via a 4" diameter pipe and then to Oil Separator No. OSMH-B. The capacity of OSMH-B is approximately 1,500 gallons. Any oil discharged through this line would be retained at the separator behind a baffle located within the lower tank.

In the unlikely event that the combination of water and oil exceeded 1,500 gallons, the oil would back up in the drains and into the Emergency Diesel Rooms and potentially the House Heating Boiler Room, as these three rooms share a common drain line. If oil backed up into any of these rooms, it would be contained within the room since each room has a concrete berm located across the entrance door threshold.

At some time in the past, OSMH-B was radiologically contaminated and since that time, any water drained from the oil separator is pumped to the Condensate Storage Tank (CST) moat, which drains to Radwaste. No water from this oil separator is discharged to the river. If oil was present in the oil separator, it would be transferred to 55 gallon drums and disposed of as radiological waste.

The discharge valve from OSMH-B is maintained in the closed position.

Appendix D OP 2106 Rev. 35 Page 29 of51

APPENDIX D (Continued) 5.1.6. Underground Storage Tanks (7): Capacity, see below.

There are four (4) underground storage tanks (USTs) at the Plant facility and three at the Corporate Office in Brattleboro which contain petroleum. All underground storage tanks are compatible with their contents. Three of the four tanks located at the plant are managed under the provisions of the Vermont Underground Storage Tank Regulations. The facility is registered in the Vermont UST program as ID No. 806. One of the tanks located at the Brattleboro Corporate*Office is managed under the provisions of the Vermont Underground Storage Tank regulations. The facility is registered in the Vermont UST program as ID No. 1885.

The plant facility tanks and piping have interstitial monitoring with alarms, tank level indication, and spill and overfill protection as well as vapor recovery.

1,000 gallon double-walled fiberglass tank. Contains diesel fuel for vehicles.

Located north of the northeast comer of.the South Warehouse. (Fig. 1-Item 5) 550 gallon double-walled fiberglass tank. Contains diesel fuel for vehicles.

Located north of the northeast comer of the South Warehouse. (Fig. 1-Item 6) 550 gallon double-walled fiberglass John Deere diesel tank. Contains diesel fuel for operating a small emergency diesel generator. The tank is located south of the southwest end of the North Warehouse. The tank is filled using the Mobile Diesel Fuel Oil Tank. (Fig. 1-Item 7) 3,000 gallon double-walled fiberglass tank. Contains Number 2 fuel oil for heating purposes. The tank is located west of the Plant Support Building (PSB).

(Fig. 1-Item 8) 10,000 gallon single walled Number 2 fuel oil underground storage tank. The tank is located at the Brattleboro corporate office along the edge of the macadam driveway between the Administration and Training Buildings .and to the West of the sidewalk leading from that macadam driveway to the entrance of the Training Building.

10,000 gallon single walled Number 2 fuel oil underground storage tank. The tank is buried beneath the macadam parking lot and specifically is located immediately East of the front door of the Brattleboro corporate office building.

550 gallon double-walled fiberglass tank. Contains diesel fuel for Brattleboro Corporate Office emergency diesel. The tank is located on the East side of the

.Training Building, outside the emergency exit for the warehouse.

Appendix D OP 2106 Rev. 35 Page.30 _of 51

APPENDIX D (Continued) 5.1.7. Gasoline Tank (Vehicle): 1,000 Gallon capacity (Fig. 1-Item 9)

The gasoline tank utilized for fueling operations is located southeast of Gatehouse 1. This tank is double-walled for 110% capacity, UL approved, ballistic and certified for vehicle impact. The interior tank is steel and the containment tank is a reinforced concrete vault.

5.1.8. North Warehouse Waste Oil Burner: Burner restricted to 500 Gallon capacity.

(Fig. 1-Item 10)

The North Warehouse Waste Oil Burner is located in the central part of the North Warehouse. The tank has a capacity of 500 gallons and is constructed of heavy gauge steel. The tank is surrounded by a containment structure which will contain the entire contents of the tank in the event of a spill or leak. The tank is also protected by vertical steel posts embedded in the concrete floor to prevent damage to the tank in the event it is struck by a forklift.

5.1.9. House Heating Boiler Fuel Tank: 12,000 Gallon capacity. (Fig. 1-Item 12)

The house heating boiler fuel tank is an aboveground tank located west of the railroad door of the turbine building. The tank is steel with a 110% capacity concrete outer shell and is equipped with interstitial monitoring and overfill protection alarm and shutoff. This tank is UL and ballistic rated. The tank is filled locally from a delivery truck.

5.1.10. Diesel Fire Pump Fuel Tank: 350 Gallon capacity. (Fig. 1-Item 13)

The diesel fire pump fuel tank is located inside the intake structure building, in a diked, fire protected room designed to contain the contents of the fuel tank.

The tank is filled from the roof of the intake structure building using the mobile diesel fuel oil tank.

5.1.11. Mobile Diesel Fuel Oil Tank: 5,90/1000 Gallon capacity. (Fig.1-Item 14)

The mobile diesel fuel oil storage tanks are a UL rated 500/1000 gallon double-walled tank that is designed to be towed behind a vehicle. Although these tanks are shown on Figure 1, its location may vary since it is mobile.

5.1.12. Advanced Off-Gas Closed Cooling Water System (Ethylene Glycol):

150 Gallon capacity. (Fig. 1-Item 15)

The AOGCCW System is located in an enclosed structure on the roof of the Advanced Off-Gas Building. Ethylene glycol is added to the system to prevent freezing during winter time conditions. A leak or spill of ethylene glycol would be contained within the enclosed bermed structure.

Appendix D OP 2106 Rev. 35 Page 31of51

APPENDIX D (Continued) 5.1.13. Portable Diesel Tank A vented 120 gallon double walled portable diesel fuel tank with an integral secondary containment system is used for special projects as needed and when not in use, is stored empty. This tank is not always stored in the same location and is therefore not shown on Figure 1.

5.1.14. Shipping and Receiving Fuel Oil Tank: 275 Gallon capacity (Fig. 1-Item 37)

The Shipping and Receiving Building is located Southeast of Gatehouse 1.

There is one 275 gallon fuel oil tank inside the building that provides oil for heating. The fuel oil tank has adequate secondary containment around it to retain the contents of the tank.

5.1.15. Governor Hunt Road Fuel Oil Tanks: 275 Gallon capacity each (Fig. 1-ltem 38)

Vermont Yankee currently owns two residences on Governor Hunt Road, both of which have a 275 gallon fuel oil tank in the basement for house heating. Oil spilled from either tank would be contained within the basements of these homes and would have no direct path to the Connecticut River.

5.1.16. Station Blackout Diesel Fuel Tank: 9604 Gallon capacity (Fig.1 - Item 42)

A 3,000KW/3,750 kVA Diesel Generator (DG) and associated 4160V switchgear are mounted on a concrete foundation pad in the area west of the South Warehouse. The DG has an associated above ground double walled diesel fuel storage tank that can hold 9,604 gallons (8, 100 useable gallons). Oil spilled would quickly enter the Station's storm drain system and proceed to the River (DPOOl) without Operations intervention.

5 .1.17. B5B Portable Diesel Fire Pump Fuel Tank: 190 Gallon capacity (Fig. 1 - Item 43)

The B5B Fire Pump is a mobile diesel driven pump with a 190 gallon fuel tank.

The unit is housed within an enclosure building between the cooling towers, near the west cooling tower bank near Bay 8. This unit is an emergency unit which would supply water to the fire protection system if the installed plant fire pumps are unable to supply the fire main during an emergency. A berm is placed around the pump to contain fuel oil leaks, etc. (Reference CR-VTY-2015-001165 CA-02)

Appendix D

., '" * *OP 2106 Rev. 35 Page32of51

APPENDIX D (Continued) 5.2. Transformers NOTE Per 40CFR112.2, oil filled electrical operating or manufacturing e ui ment is not considered a bulk stora e container.

5.2.1. Main Transformer: 27,398 Gallon capacity of non-PCB oil. (Fig. 1-Item 19)

The Main Transformer is located adjacent to and west of the Turbine Building.

It is surrounded by a concrete containment structure with inside dimensions measuring 48' x 20' x 8.5' high. The walls consist of 9" concrete with a bottom concrete slab. This containment is filled to a depth of 8' with crushed stone. A 12" diameter perforated pipe is located in the southeast comer of this structure for inspection for oil spills or storm water. A 4" diameter pipe leads from this facility to Oil Separator No. MH-A. Any oil discharged would be retained at th~s separator behind a baffle located within the lower tank.

Two 12" diameter cast iron pipes penetrate the containment wall of the Main Transformer 4' above the floor slab and terminate into the containment facility of the Auxiliary Transformer. A major spill could utilize both containment facilities. A postulated spill combined with the effects of free board precipitation would utilize both containment facilities as well as the containment structures of the Startup Transformers T-3A and T-3B (described below) and Oil Separator No. MH-A, all of which are interconnected by a 4" diameter pipe.

In the event of a spill, all oil would be held within the containment facility and the oil separator. The 4" oil separator line has a closed valve on its outlet pipe during normal operati~g conditions.

Operating experience has demonstrated that, for example, during a transformer fire, overspray from firefighting measures can result in fire foam, water, and oil entering nearby storm drains and the Connecticut River. To prevent this from occurring, the North Storm Drain Discharge Isolation Valve at MH-44 (V-Yard 10) would be closed immediately when an oil spill occurs. To further discourage oil from entering the nearby manholes, manhole covers are staged nearby and are placed over the manholes if oil threatens to enter.

Appendix D OP 2106 Rev. 35 Page 33 of51

APPENDIX D (Continued) 5.2.2. Spare Main Transformer: 26,500 Gallon capacity of non-PCB oil.

(Fig. 1-Item 20)

The Spare Main Transformer was sold to an outside organization in late 2006.

The oil from the spare main transformer was removed December 2006. The transformer was dismantled and removed in 2007:

5.2.3. Auto Transformer: 17,200 Gallon capacity of non-PCB oil. (Fig. 1-Item 21)

The Auto transformer is located in the 345KV Switchyard.

Three French drains, (21" inside diameter concrete pipe, placed at the bottom of a 4' deep trench and back-filled with crushed rock), are located north of the Automatic Control Breaker control structures. These drains contain vents arid a pipe to facilitate pumping when filled. One pipe is located approximately 23' north and 60' west of the Auto transformer. The Switchyard area contains 188,360 square feet of relatively permeable soil with 6" of crushed stone for finish surface.

The high point for the 345KV Switchyard drainage is located at the center of the Switchyard, and crosses the yard in an east/west direction. All Switchyard drainage south of this east/west mound drains via stone-filled V-ditches surrounding the perimeter to an 18" diameter culvert located under the access road leading to the 345KV Switchyards. From this point, drainage proceeds via a stone-filled V-ditch (grass swale) on the north side of the North Warehouse to catch basin No. MH-12A. The catch basin at MH-12A is downstream of the Isolation Valve V-Yard-10 on Figure 3. Switchyard drainage north of the east/west mound flows to several catch basins and then to Isolation Valve V-Yard-12 at MH-33:

In the event of an oil spill within the 345KV Switchyard, an inspection is performed to ensure the oil has not entered V-ditches surrounding the Switchyard. If discharged oil reaches the V-ditches on the north side of the Switchyard, it could be blocked by closing Isolation Valve V-Yard-12. If discharged oil reaches the V -ditches on the south side of the Switchyard, it would flow overland to catch basin MH12A and then to the Connecticut River.

Appendix D

- OP 2106 Rev. 35 Page 34of51

APPENDIX D (Continued)

Containment of potential oil spill relies on the sorbent properties of the crushed stone and underlying soil in the Switchyard and storage in the French drains. In addition, permanent check dams have been installed at two of the manholes in the North V-ditch (DMH I and DMH 32) and manhole covers are staged nearby .

which can be placed over the manholes if oil threatens to enter. Two layers of oil absorbing geotextile fabric have been installed around the two manholes in the North V-ditch. The Auto Transformer provides alarms in the VY Control Room under various signals, including low oil level. As such, any oil leak will be noticed by Control Room personnel and Operators would be dispatched to the 345KV yard. This Switchyard configuration complies with 40CFR112.7(c).

5.2.4. Startup Transformers (2): 3,720 Gallon capacity each of non-PCB oil.

(Fig. 1-Items 22 & 23)

The north Startup Transformer (T-3A) is located southwest of the entrance to the Administration Office Building. Its' containment facility is an excavated pit measuring 15' x 8' at the base with walls sloping to a top dimension of29' x 20' at finish grade. This pit contains 6' of crushed stone and has a 12' x 8' x 1' thick concrete slab at its base to support the transformer. A concrete perimeter wall encloses an area of 630 square feet. A 12" diameter perforated pipe is located in the north end for inspection of storm water. One 4" diameter pipe leads from this containment structure to Oil Separator No. MH-A. Any oil discharged would be retained at this separator behind a baffle located within the lower tank.

The south Startup Transformer (T-3B) is located southwest of the entrance to the Administration Office Building next to the north Startup Transformer. Its containment facility is an excavated pit measuring 17' x 7' at the base, with walls sloping to a top dimension 'of 29' x 20' at finish grade. This pit contains 6' of crushed stone and has a 12' x 8' x 1' thick concrete slab at its base to support the bus housing from the isolated phase bus work, and 12' x 8' x 2' thick concrete slab at finish grade to support the transformer. A concrete perimeter wall encloses an area of 757 square feet. A 12" diameter perforated pipe is located in the north end for inspection of storm water. One 4" diameter pipe leads from this containment structure to Oil Separator No. MH-A. Any oil discharged would be retained at this separator behind a baffle located within the lower tank.

In the event of an oil spill from these transformers, all oil would be held within the containment facility and the oil separator. The 4" oil separator line has a closed valve on the outlet pipe of the oil separator during normal operating conditions.

Appendix D OP 2106 Rev. 35 Page 35 of51

APPENDIX D (Continued) 5.2.5. Auxiliary Transformer: 4,920 Gallon capacity of non-PCB oil.

(Fig. 1-Item 24)

The Auxiliary Transformer is located between the Turbine Building and the Main Transformer. Its' containment facility is an excavated earth pit measuring 9 .5' x 6.5' at the base, with side walls sloping to top dimension of 22.5' x 19 .5' at finish grade. This pit contains 6' of crushed stone and a 9.5' x 1' thick concrete floor slab at its base to support the transformer.

A concrete perimeter wall 2' deep and 6" above finish grade surrounds this pit area. A 12" diameter perforated pipe is located in the southeast comer for the inspection of storm water. One 4" diameter pipe leads from this containment structure to Oil Separator No. MH-A. Any oil discharged would be retained at this separator behind a baffle within the lower tank.

Two 12" diameter cast iron pipes penetrate the earth containment wall of the facility 2' above the floor slab and terminate into the containment facility of the Main Transformer. An oil spill would utilize both containment structures.

The containment facility is regularly inspected for oil. If there is no evidence of oil through inspection at the 12" diameter inspection pipe and the oil separator, the valve is opened to allow storm water to enter the Storm Drain System.

5.2.6. West and East Switchgear Room Transformers (2) - Floor Elevation 248:

215 Gallon capacity of non-PCB oil each. (Fig. 1-Items 25 & 26)

The West Switchgear Room contains a lOOOKVA ABB Transformer: No.

T-8-lA. It contains 215 gallons of Silicone (non-PCB) oil. It is surrounded by a 1' high concrete containment dike designed to contain the entire liquid contents of the transformer in the event of a spill or leak.

The East Switchgear Room contains a lOOOKVA ABB Transformer: No.

T-9-lA. It contains 215 gallons of Silicone non-PCB oil. It is surrounded by a 1' high concrete containment dike designed to contain the entire liquid contents of the transformer in the event of a spill or leak.

I Access to both Switchgear Rooms is controlled. A leak of oil would remain within the rooms. Both rooms are protected with an automatic carbon dioxide fire detection and suppression system. The suppression system alarm annunciates in the Control Room. The transformers are observed at least once each shift by an Auxiliary Operator and more thoroughly once a week by Maintenance Department personnel.

Appendix D

- - t*\ ....

OP 2106 Rev. 35 Page 36 of51

APPENDIX D (Continued) 5.2.7. Cooling Tower Transformers (2): 545 Gallon capacity each of non-PCB oil.

(Fig. 1-Item 27)

A 2500KVA Cutler-Hammer transformer is located at the north end of each of the two Cooling Towers: Numbers T-5Bl-1A and T-5B2-1A. Each Cooling Tower Transformer is surrounded by a concrete containment dike designed to contain the majority of the liquid contents of each transformer plus rain water in the event of a spill or leak. Additionally, the containment dike for each transformer is equipped with a drainage port and valve to allow draining of storm water and snow will be removed from the containment during the winter.

The valve number for T-5B-1A is V-OCA026 and for T-5B2-1A is V-OCA-27.

Both Cooling Tower Transformers are alarmed in the Station's Control Room and as such, any leak would be responded to quickly. A spill kit resides in the vicinity of each transfomier and a heavy urethane manhole cover is stored in a bright yellow case near manhole DMH 20A2 located roughly between the West Cooling Tower Transformer and the Vernon Hydro Tie Transformer. Two layers of oil absorbing geotextile fabric have been added to the permanent check dam added around DMH 20A2.

5.2.8. Construction Office Building (COB) Transformer: 210 Gallon capacity of non-PCB oil. (Fig. 1-ltem 28)

The Construction Office Building (COB) Transformer (T-12) (Westinghouse, 2000KVA) is located north of the Construction Office Building (COB). It is secured to an 11.5' x 21.5' concrete pad with a 2.5" high concrete lip around the perimeter which would contain all leaked or spill oil. ER 05-517, Nuclear Change Number 2 implemented repairs to sections of the brick containment and added an isolation drain valve V-PR0-25 on the South side of the berm. A second drain line with a threaded cap is located on the East side of the containment. The valve can be opened to drain stormwater. Weekly Operator rounds provide inspection of this transformer and berm. This is in a high traffic area and any oil leaks would be quickly identified.

5.2.9. Administration Building Transformer: 375 Gallon capacity of non- PCB oil.

(Fig. 1-ltem 29)

The Administration Building Transformer (T-11) (General Electric, 1500KVA) is located east of the Administration Building. The transformer sits on a 6' x 6.5' pad of concrete and crushed stone. The transformer sits atop a concrete slab within an U-shaped concrete containment basin filled with crushed rock.

The rock basin would contain the entire liquid contents in the event of a spill or leak.

Appendix D OP 2106 Rev. 35 Page 37.of 51

APPENDIX D (Continued)

A 6 inch perforated PVC pipe for monitoring was installed vertically in the Northeast comer of the containment in 2005. This pipe will facilitate oil removal from the sump in the event a leak occurs. This transformer is located in a high traffic area and any oil leaks would be quickly identified.

5.2.10. Turbine Building Transformers: Capacity, see below.

The Turbine Building contains three transformers:

No. T-6-lA, ABB, 1OOOKV A, 215 gallons of silicone (non-PCB) oil. Location:

Sample Panel Area. It is surrounded by a 1' high concrete containment dike designed to contain all of the liquid contents of the transformer in the event of a spill or leak. (Fig. 1-Item 30)

No. T-7-lA, ABB, lOOOKVA, 215 gallons of silicone (non-PCB) oil. Location:

Laundry/MUD area. It is surrounded by a l' high concrete containment dike designed to contain all of the liquid contents of the transformer in the event of a spill or leak. (Fig. 1-Item 31)

No. T-10-lA, ABB, 1500KVA, 367 gallons of Silicone (non-PCB) oil.

Location: Instrument Air Dryer area, elevation 232'. It is surrounded by a 1' high concrete containment dike designed to contain the entire liquid contents of the transformer in the event of a spill or leak. (Fig. 1-Item 32)

The floors are constructed on a slight incline to prevent oil leaving the room in the event of a spill or leak. Each transformer is observed at least once each shift by an Auxiliary Operator and more thoroughly once a week by Maintenance Department personnel.

5.2.11. Generator Neutral Grounding Transformer: 44 Gallon capacity of non-PCB oil.

(Fig. 1-Item 33)

This is a IOOKVA Westinghouse unit located beneath the generator in the turbine building. It is totally enclosed in a*metal electrical cabinet. It is a few feet north of transformer T-7-lA in the Turbine Building. This transformer is normally not energized; hence the fire risk is virtually non-existent. The metal cabinet is surrounded by a fire resistant wooden containment dike

designed to contain all of the liquid contents of the transformer in the event of a spill or leak.

Appendix D OP 2106 Rev. 35 Page 38 of51

APPENDIX D (Continued) 5.2.12. Vernon Hydro Tie Line Transformer: 788 Gallon capacity of non-PCB oil.

(Fig. 1-Item 34)

Transformer "T-Vemon Hydro" is a 3,750KVA Powell Esco unit located Northwest of the West cooling tower. It contains 788 gallons of Silicone (non-PCB) oil. Drain valves were added and a capacity calculation for this containment was completed in 2003 per ER 04-1418. This transformer is surrounded by a concrete containment dike designed to contain the entire liquid contents of the unit. However, the containment has been observed to be substantially full ofrainwater. Two drain lines with isolation valves V-OCA-22 and V-OCA-24 allows water drainage and draining is routinely performed. This transformer is subject to the same weekly inspection regime as the other transformers.

5.2.13. Peebles Transformer: -20,000 Gallon capacity of non-PCB oil.

(Fig. 1-Item 35)

The Peebles Transformer has been removed from the Station.

5.2.14. Spare Cooling Tower Transformers (2): 425 Gallon capacity each of non'."PCB oil (Fig. 1-ltem 39)

Two 1500KVA Westinghouse transformers which were located temporarily between the cooling towers in portable berms were sold to an outside organization in 2006 and removed from the plant site in early 2007.

5.2.15. Plant Support Building Transformer (248 Gallon non-PCB oil)

(Fig. 1-Item 40)

This transformer is owned by Green Mountain Power. The volume of oil in the transformer is 248 gallons. The transformer sits atop a containment vault that is designed to contain the entire contents of the transformer.

5.2.16. Corporate Office Transformer (245 Gallon non-PCB oil)

The transformer is located on Vermont Yankee property at the comer of the driveway located between the Training and Administrative Buildings and Glen Om Drive. Containment of leaked oil relies on the sorbent properties of the landscaping wood chips around the transformer and the fact that the grade would lead leaked oil away from any stormwater manholes. This transformer is located in a high traffic area and any leak would be quickly identified.

Appendix D OP 2106 Rev. 35 Page 39 of51

APPENDIX D (Continued) 5 .2.17. 69KV Distribution Transformer for 115 Yard Power This transformer is located in the 115KV yard, NW of the Relay House. The volume of oil contained inside the transformer is 80 gallons. The transformer has a secondary containment structure surrounding it, with a drain valve for draining oil free water. Weekly operator rounds provide inspection of this transformer the berm is drained as needed. There is no requirement for snow removal from this berm during winter.

5.3. Hydraulic Devices 5.3.1. Intake and Discharge Structure Hydraulic Gate Operator Systems (2):

Discharge System - 2 i 0 Gallon capacity of hydraulic oil; Intake System -

210 Gallon capacity of hydraulic oil. (Fig.1-Item 17)

These two systems are located at the intake and discharge structures. There are no oil containment structures for the piping or the hydraulic cylinders. Piping

containing oil is constructed of high integrity stainless steel with welded fittings. Each system contains non-PCB hydraulic oil in a sump tank contained within a moated fiberglass building designed to retain the entire contents of the*

system.

5.4. Circuit Breakers 5.4.1. Oil Circuit Breaker (1): Capacity, see below. (Fig. 1-Item 36)

K-186 Line Breaker OCB-K-186, 1,680 gallons of non-PCB oil.

This breaker is located in the 115KV Switchyard. The 115KV Switchyard contains 28,500 square feet of relatively permeable soil with 6" of crushed stone for finish surface. There are V-ditches surrounding the Switchyards. Two p~rmanent check dams were installed in the East V-ditch. A single spill kit is I*, staged between the two stormwater outlets on the eastern side of the yard.

All Switchyard drainage is via open V-ditches surrounding the perimeter of the yard to a 12" diameter pipe located under the outer security fence by the northeast comer of the Switchyard. From this point, drainage proceeds 450' toward the Connecticut River, approximately 800' north of the stack.

Appendix D

*OP 2106 Rev. 35 Page 40of51

APPENDIX D (Continued)

In the event of an oil spill within the 115KV Switchyard, alarms sound in the 115 Relay House and an inspection is performed to ensure that oil has not entered the V-Ditches surrounding the Switchyard. If discharged oil reaches the V-ditches surrounding the Switchyard, the sorbent properties of the crushed stone and the two permanent check dams and spill kit should provide first responders with an adequate ability to prevent oil from reaching the stormwater outlets.

5.5. Gearboxes 5.5.1. Cooling Tower Fan Gearboxes (22): 12.5 Gallon capacity each gearbox, total capacity 275 Gallons. (Fig. 1-Item 18)

. There are 22 fan gearboxes on the top of the two cooling towers: 11 per tower.

Each gearbox contains approximately 12.5 gallons of (non-PCB) oil. Major preventive maintenance is performed on them each spring by the Maintenance Department. There are no oil containment devices for the gearboxes. There is less than 55 gallons of non-PCB oil stored on top of each Cooling Tower that is used to replenish the gear box oil as neces~ary. -*

During cooling tower operation in the summer, oil levels are checked weekly and visual inspections are performed to identify any leaks or other deficiencies.

Deficiencies are trended and corrected as necessary. In the event of a significant leak, Operations should close the hydraulic gates at the discharge and intake structures to prevent oil from entering the river.

5.6. Miscellaneous Containers 5.6.1. South Warehouse: (Fig. 1-Item 16)

Approximately 2,000 gallons of new oil in 55 gallon drums are stored in the South Warehouse. The building is structural steel supported, metal sheathed and built over a concrete slab. There is a containment berm around the new oil drum storage zone at the east end of the building. A locked battery work cage is located in the southwest comer of the building for purposes of charging and storing useable lead-acid batteries. The battery cage is surrounded by a berm designed to contain the contents. The original two floor drains are plugged with concrete. The building is equipped with a sprinkler system for fire suppression and a Gai-Tronics communications station.

In the event of a HAZMAT spill or leak in the South Warehouse, the oil would be retained within the containment facility.

Appendix D

. ,.,_.,. .'\

OP 2106 Rev. 35 Page 41 of51

APPENDIX D (Continued) 5.6.2. North Warehouse: (Fig. 1-Item 10)

The North warehouse building is structural steel supported, metal sheathed and built over a concrete slab. The area is 47 ft x 80 ft (3 ,760 square feet) with a minimum berm height of2.5 inches (790 cubic ft). Subtracting 15% of the floor space which is occupied by equipment, nets a total oil storage capacity of this building is therefore 4,980 gallons. Existing storage of oil filled containers shall not exceed the capacity of the building. A concrete berm at the West rollup door was installed in June 2005 per ER 04-1418. A capacity calculation is provided in Nuclear Change l to this ER. The berm is 3.5 inches high and covers the width of the entire roll up door opening. A solid rubber ramp installed with five star structural concrete and rebar on either side of the berm allows easy vehicle travel over the berm. Floor drains are plugged with concrete. There is a 3" concrete berm around the inside perimeter of the building. In the event of a spill or leak, the hazardous materials located in the building would be retained within the containment facility. The 500 gallon waste oil barrier tank in the North Warehouse has its own containment, as described in Section 5.1.8 above.

I 6.0 FACILITY RESPONSE PLAN APPLICABILITY [40CFR112.20]

' 6.1. Based on the screening criteria shown in the attached "Certification of Substantial Harm Certification" form , VYNPS does not represent a substantial harm to the environment by discharging oil into or upon navigable waters or adjoining shorelines, and therefore, is not required to develop a facility response plan.

Appendix D OP 2106 Rev . 35 Page 42 of5 I

APPENDIX D (Continued)

FIGURE 1 FACILITY LAYOUT & PRODUCT STORAGE LOCATIONS (Oils)

'*-----Gif_&_

i.i... OI-~

. __T__

.,, _ _ _.........,. _ llfl 42 Station Blackout Diesel Fuel Tilllk 43 BSB Diesel Fire Pump

~~----

IOl-a--*1111-1*.*~q.,~

- EJ EJ Appendix D OP 2106 Rev. 35 Page43of51

APPENDIX D (Continued)

FIGURE 2 FACILITY LAYOUT & PRODUCT STORAGE LOCATIONS (Chemicals, Hazardous Wastes & Mixed Wastes)

~: :=!=::.ww.&lWMef l~)

E ~ L-f'" SW..WatthouM

~~-~--=:

--F-y l :::.~Tri D "*°'""Wai:~(Ha.uw~lldWaSMIJ K ~lllMdGuea L.

\Ramowed}

M. TIMirteluikHng t~WMUIJ a-1

HAZJMT RE.SPQNSE SPiL.lKfT / ITEM l.OCATK>HS D

D DD G. ..................... - , , .

Appendix D OP 2106 Rev. 35 Page 44 of51

APPENDIX D (Continued)

FIGURE 3 MANHOLE LAYOUT SEP TIC SYS TEM I SP.-l'tE MAIN ~ f$\ '

l<.F MR L__,-r" \:I D

'-~~~~~~~~,l

~l

g IV 3 e.<.'I 1V 3lr.f'llTCH1'AA:O 1V e STORM CRAii'~

i~

'*ov

- MAHl1C\.ZC(We't V-OI TQ-1 !~

~INS TO Mk-12A !It'

V VVV VY YVYV VV VVVV V 6 '.Alf3..DEOl4Al..0.ES ISCIL.ATIOH VAlVE M,t. l :jHQ e f!IO! ["j ;

MH C* I IS t...00\EO MH-lA IS COVERED W ITH ROCKS

@ e!~;~~~j MH -34 IS A ~ e OR"1hl At<.l H O T #1 CCES6ABl.E MK- 10. M M- 1 IF ""'1* 11 H HAVE STEEL CAGES lt.£$CETMEM " '~ARE uor ACCE SSA.BL E Appendix D OP 2106 Rev. 35 Page 45 of5 l

APPENDIX D (Continued)

TABLE 1 Potential Discharge Volumes and Direction of Flow Maximum Maximum Volume Direction of Tank Potential Event Discharge Containment Released Flow Rate (Gallons)

Berm, absorbent Tank Failure (below Gradual to Containment booms and Diesel Fuel Storage Tank product level) 1to40000 instantaneous berm pads Absorbent Tank Truck leak or Gradual to West to storm booms and failure 1to3,000 instantaneous drain & DP001 pads Absorbent Gradual to West to storm booms and Hose leak or failure 1 to 300 instantaneous drain & DP001 pads Berm, absorbent Tank Failure (below Gradual to Contained in booms and Lube Oil Pump Room product level) 1 to 11000 instantaneous Building pads Absorbent*

Tank Truck leak or Gradual to West to storm booms and failure 1to1,000 instantaneous drain & DP010 pads Absorbent Gradual to West to storm booms and Hose leak or failure 1to300 instantaneous drain & DP010 pads Contained in Tank Failure (below Gradual to Contained in bermed internal

EOG Dav Tanks-ASTs product level) 1 to 800 instantaneous BuildinQ room Contained in EOG Lube Oil Storage Tank Failure (below Gradual to Contained in bermed internal Tanks product level)

1 to 600 instantaneous Buildina room Contained in Sump Failure (below Gradual to Contained in bermed internal EOG Lube Oil Sumps product level) 1 to 250 instantaneous Building room Tank Failure (below Gradual to Double Walled To interstitial U-T - John Deere Diesel product level} 1 to 550 instantaneous Tank space Absorbent Gradual to West to storm booms and Fill Tank leak or failure 1 to 300 instantaneous drain & DP010 pads

- ~. :-:* *: ..

Appendix D OP 2106 Rev. 35 Page 46 of51

APPENDIX D (Continued)

TABLE 1 Potential Discharge Volumes and Direction of Flow Maximum Maximum Volume Direction of Tank Potential Event Discharge Containment Released Flow Rate (Gallons)

U-T - South Warehouse Tank Failure (below Gradual to Double Walled To interstitial (2) product level) 1 to 971 instantaneous Tank space Absorbent Tank Truck leak or Gradual to West to storm booms and failure 1to1,000 instantaneous drain & DP010 pads Absorbent Gradual to West to storm booms and Hose leak or failure 1to300 instantaneous drain & DP010 pads Tank Failure {below Gradual to Double Walled To interstitial*

A-T - Gasoline Tank product level) 1 to 1000 instantaneous Tank space Absorbent Tank Truck leak or Gradual to West to storm booms and failure 1to1,000 instantaneous drain & DP010 pads Absorbent Gradual to West to storm booms and Hose leak or failure 1to300 instantaneous drain & DP010 oads Berm, absorbent North Warehouse Oil Tank Failure (below Gradual to To impervious booms and Burner oroduct level) 1 to 500 instantaneous surface oads Tank Failure {below Gradual to Double Walled To interstial House Heating Boiler product level) 1 to 10000 instantaneous Tank space Tank Truck leak or Gradual to South to storm failure 1to5,000 instantaneous drain & DP001 None Gradual to South to storm Hose leak or failure 1 to 300 instantaneous drain & DP001 None Diesel Fire Pump Day Tank Failure {below Gradual to Contained in Berm in building Tank-AST product level) 1to350 instantaneous Building Absorbent Gradual to To impervious booms and Hose leak or failure 1 to 10 instantaneous surface pads AppendixD OP.2106 Rev. 35 Page 47 of51

APPENDIX D (Continued)

TABLE 1 Potential Discharge Volumes and Direction of Flow Maximum Maximum Volume Direction of Tank Potential Event Discharge Containment Released Flow Rate (Gallons)

Mobile Diesel Fuel Tank Failure (below Gradual to Double Walled To instersitial I

Tank(s) product level) 1 to 500 instantaneous Tank space

Variable *Variab-e-Gradual to depending on storm drains Hose leak or failure 1 to 10 instantaneous location are hiQhest risk Shipping & Receiving Tank Failure (below Gradual to Adequate Fuel Oil Tank product level) 1 to 275 instantaneous NA containment Governor Hunt House Tank Failure (below Gradual to Adequate Fuel Oil Tank product level) 1 to 275 instantaneous NA containment Drainblocker, Tank Failure (below Gradual to North to storm operations SBO Diesel Tanks~ASTs product level) 1 to 8100 instantaneous drain & DP001 actions Drainblocker, absorbent Tank Truck leak or Gradual to North to storm booms and failure 1 to 1,000 instantaneous drain & DP001 pads Drainblocker, absorbent Gradual to North to storim booms and Hose leak or failure 1to300 instantaneous drain & DP001 pads To trap rock 1to27500 under depending transformers Drainblocker, on which with little or no absorbent .

transformer Gradual to horizontal booms and Active Transformers Transformer failure fails instantaneous migration pads Gradual to Berm placed 8.5.b Pump Tank leak or failure 1 to 190 instantaneous N/A around fuel tank

- ~

Appendix D t ..-.. , I ' *'"' **.*.;*":*.--*.':=-"""""*:-****".' '* .,_. *. OP 2106 Rev. 35 ..... *-: ..... **;; ..

Page 48of51

APPENDIX D (Continued)

SPCC PLAN REVIEW FORM [40CFR112.5(b)]

Revision Nc:cdcd Revision Type

Signature (Yes or No) (Technb.~111 or Noa-Technical)

Tg~ !\;'"' \ ~A)ili~ +a t\W. T- 1S r"t*f v* reel 7/19/13 Yes

Technical

P. E. certiftcatfoo Is only needed for techDlcal amendments to the SPCC Plan.

Appendix D OP 2106 Rev. 35 Page 49 of51

APPENDIX D (Continued)

CERTIFICATION OF SUBSTANTIAL HARM CERTIFICATION [40CFR112.20(e)]

Facility Name: Vermont Yankee Nuclear Power Station Facility Address: Governor Hunt Road

. Vernon, Vermont 05354

1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons?

Yes D No IZJ Although VYNPS has an oil storage capacity of 42,000 gallons, the facility does not transfer oil over water to or from vessels.

2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of 1the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation within any aboveground oil storage tank area?

Yes D No IZJ Based on the quantities identified in Section 5.0 of the VYNPS, onsite oil storage capacity is less than

~228,000 gallons. Therefore maximum storage capacity is less than 1 million gallons. Although the second part ofltem 2 does not apply since* maximum storage capacity is less than 1 milliori gallons, secondary containment is provided for each aboveground tank and is large enough to contain the capacity of the largest tank within the storage area plus sufficient free board for rainfall (where

. applicable).

3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C-III of Appendix C to 40CFR112 or a 9omparable formula) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments?

Yes D No IZJ As discussed in Item 2 above, the maximum storage capacity at VYNPS is less than 1 million gallons.

Therefore, the second part ofltem 3 does not apply .

Appendix D r,.,~ .... a.--:-.. . '

11 OP 2106 Rev. 35 Page 50of51

APPENDIX D (Continued)

CERTIFICATION OF SUBSTANTIAL HARM CERTIFICATION [40CFR112.20(e)] (Continued)

4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C-III of Appendix C to 40CFRI 12 or a comparable formula) such that a discharge from the facility would shut down a public drinking water intake?

Yes D No fZI As discussed in Item 2 above, the maximum storage capacity at VYNPS is less than 1 million gallons.

Therefore, the second part ofltem 3 does not apply.

5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil spill in an amount greater than or equal to 10,000 gallons within the last 5 years?

Yes D No fZI As discusseq in Item 2, the maximum storage capacity at VYNPS is less than 1 million gallons.

Therefore the second part ofltem 5 is not applicable. However based on review of past spill records, no reportable spills greater than or equal to 10,000 gallons have occurred within the past five years.

CERTIFICATION I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate and complete.

Signature ~ N* ~

Name: Ricky N. Buckley, CHMM

Title:

Sr. Project Manager - Entergy Nuclear Date: June 1, 2004 Appendix D OP 2106 Rev. 35 Page 51 of51

APPENDIXE SPILL RESPONSE EQUIPMENT INSPECTION Kit/Item Minimum Verified Location Items Quantity (Initials/Date) 65 Gallon Oil Kit Sealed?

Lighting Diesel (JDDG) South 48" Socks 10 YES/NO Wall Outside lO'Socks 6 Building Pillows 6 Wipers 50 "

Pads 40 Disposal Bags 10 Emergency Response Guidebook 1 I

Neoprene Gloves 4 pair Goggles 2 I 20 Gallon Aggressive Kit Sealed?

North Warehouse 46" Socks 3 YES/NO Inside East End Pillows 3 Pads* 36 Shaker bottle of Spill-X-A 1 Disposal Bags 10 Neoprene Gloves 4 pair Goggles 2 Sodium Bicarbonate (in buckets) 25 pounds I 30 Gallon Oil Kit Sealed?

North Warehouse lO'Socks 4 YES/NO Inside East End Pillows 4 Pads 25 Speedy-Dry 2Bags Disposal Bags 5 Emergency Response Book 1 I Appendix E OP 2106 Rev. 35 Page 1of10

APPENDIX E (Continued)

Kit/Item Minimum Verified Location Items Quantity (Initials/Date) 30 Gallon Oil Kit Sealed?

Intake Structure IO' Socks 4 YES/NO Top of Building ..

Pillows 4 Pads 25 Disposal Bags 5 Emergency Response Guidebook 1 Neoprene Gloves 4 pair Goggles 2 I 65 Gallon Aggressive Kit Sealed?

Intake Structure 46" Socks 8 YES/NO Chemical Shed lO'Socks 6 By Deluge Shower Pillows 5 Mats 40 Disposal Bags 10 Neoprene Gloves 4 pair Goggles 2 Sodium Bicarbonate (in separate container) 25 pounds I 30 Gallon Oil Kit Sealed?

Containment Access Building IO' Socks 4 YES/NO Near Used Oil Pillows 4 Burner Pads 25 Speedy-Dri J 2 bags Disposal Bags 5 Emergency Response Guidebook 1 Speedy-Dri (near kit) 5 gallons I AppendixE t , ' ~- ,. ' ~

OP 2106 Rev. 35 Page 2of10

APPENDIX E (Continued)

Kit/Item Minimum Verified Location Items Quantity (Initials/Date) 65 Gallon Oil Kit Sealed?

Vehicle Fueling 48" Socks 10 YES/NO Area By lO'Socks 6 Gas/Diesel Fuel Pumps Pillows 6 Wipers 50 Pads 40 Disposal Bags 10 Emergency Response Guidebook. 1 Neoprene Gloves 4 pair Goggles 2 I Oil Kit Sealed?

House Heating Boiler Tank 48" Socks 10 YES/NO Outside Near lO'Socks 6 Tank Pillows 6 Wipers 50 Pads 40 Drain blockers (by kit) Emergency Use 2 Drain blockers (in H2 shed) Routine Use 2 Disposal Bags 10 Emergency Response Guidebook 1 Neoprene Gloves 4 pair Goggles 2 I Miscellaneous Sum2lies Main Warehouse Lime 10 bags on Pallet Racks Sodium Bicarbonate 10 bags Speedy-Ori 6 bags I Aggressive Kit Sealed?

South Warehouse on West Wall Absorbent Mats 10 YES/NO Near Battery Absorbent Pillows (Hydrofluoric Acid) 2 Cage Absorbent Pillows 4 Gloves 1 Faceshield/Goggles 1 Emergency Response Book 1 I Appendix E OP 2106 Rev. 35 Page 3of10

APPENDIX E (Continued)

Kit/Item Minimum Verified Location ' Items Quantity (Initials/Date)

Oil Kit Sealed?

South Warehouse Absorbent Mats 20 YES/NO in Cage Area East Side Absorbent Socks 4 Absorbent Pillows 5 Disposal Bags 2 Putty 1 Gloves 1 Wipes 20 Goggles 1 Emergency Response Book 1 I 65 Gallon Oil Kit Sealed?

South Warehouse 48" Socks 10 YES/NO Overpack Drum West Side lO'Socks 6 Pillows 6 Wipers 50 Pads 40 Disposal Bags 10 Emergency Response Guidebook 1 Neoprene Gloves 4 pair Goggles 2 I 20 Gallon Aggressive Kit Seal~d?

Cable Vault Outside 103 46" Socks 3 YES/NO Door Pillows 3 Pads 36 Shaker bottle of Spill-X-A 1 Disposal Bags 10 Neoprene Gloves 4 pair Goggles 2 I AppendixE

'{ ai-*

OP 2106 Rev. 35 Page 4of10

APPENDIX E (Continued)

Kit/Item Minimum Verified Location Items Quantity (Initials/Date)

Containment Oil Kits (2) Sealed?

Access Building (on wheels)

Drain Blockers 1 YES/NO Boots 1 Gloves 1 Toolbox containing at least one of each of 1 the following:

Hammer Mallet Pliers Pry Bar Flathead Screwdriver Philips Screwdriver Adjustable Wrench Plumbers Wrench Steel Brush Channel Locks Air Pressure Gauge Air Hose 1 Rope/Air Tube 1 Absorbent Mats 20 Absorbent Socks 6 Absorbent Pillows 6 Absorbent Booms 2 Disposable Bags 10 Tyvek Suits 2 Large and Small Inflatable Pipe Plug 1 Scott Air Regulator Assembly 1 20 gallon Empty Bucket 1 Package of Loose Absorbent 1 Emergency Response Book 1 Package of Spaghetti Strips 1 Fuel Solidifier 1 Goggles 5 I AppendixE

j :.:.-c *<( , *. , , _

_.... ***.,OP 2106 Rev. 35 Page 5of10

APPENDIX E (Continued)

Kit/Item Minimum Verified Location Items Quantity (Initials/Date)

Miscellaneous. Supplies Stockroom Upstairs, Shelf Y4+5-2 Empty Sandbags 50 I Greenlee Box Sealed?

Turbine Hallway East Side of Absorbent Mats 20 YES/NO Ramp Absorbent Socks 4 Absorbent Booms 2 Gloves 2 Speedy-Dri 25 pounds Drain Blockers 1 Disposal Bags 2 Goggles 1 Emergency Response Book 1 I 20 Gallon Aggressive Kit Sealed?

318' Reactor 46" Socks 3 YES/NO Building East Pillows 3 Side by Crane Bay Pads 36 Shaker bottle of Spill-X-A 1 Disposal Bags 10 Neoprene Gloves 4 pair Goggles 2 I Main Parking 30 Gallon Oil Kit Sealed?

Lot on Concrete lO'Socks 4 YES/NO Berm behind 410 Pillows 4 Gate Search Equipment Pads 25 Storage Shed Pipe Repair Tape Wrap 3 Sealant Putty 6 Disp.osal Bags 5 Emergency Response Guidebook 1 Neoprene Gloves 4 pair Goggles 2 I Appendix E OP 2106 Rev. 35 Page 6of10

APPENDIX E (Continued)

/

Kit/Item Minimum Verified Location Items Quantity (Initials/Date) 30 Gallon Oil Kit Sealed?

lO'Socks 4 YES/NO PSB by UST Pillows 4 Pads 25 Disposal Bags 5 Emergency Response Guidebook 1 Neoprene Gloves 4 pair Goggles 2 I 20 Gallon Aggressive Kit Sealed?

345KV Relay 46" Socks 3 YES/NO House Pillows 3 Pads 36 Shaker bottle of Spill-X-A 1 Disposal Bags 10 Neoprene Gloves 4 pair Goggles 2 I 345KV 95 Gallon Ovemak Salvage Drum Switchyard North V-Ditch Sealed?

5" x 10' oil-only booms 3 YES/No 3" x 1O' oil-only booms 10 Absorbent Pads 10 Disposal Bags 1 Neoprene Gloves 4 pair I 115KV Relay 20 Gallon Aggressive Kit House Sealed?

46" Socks 3 YES/NO Pillows 3 Pads 36 Shaker bottle of Spill-X-A 1 Disposal Bags 10 Neoprene Gloves 4 pair I Appendix E

. . ~ *. ~-

.. '** .. . ~

OP 2106 Rev. 35 Page 7of10

APPENDIX E (Continued)

Kit/Item Minimum Verified Location Items Quantity (Initials/Date) 115KV 95 Gallon Ovemak Salvage Drum Switchyard East V-Ditch Sealed?

5" x 10' oil-only booms 3 YES/NO 3" x 1O' oil-only booms 10 Absorbent Pads 10 Disposal Bags 1 Neoprene Gloves 4 pair I 20 Gallon Aggressive Kit Sealed?

Discharge Structure on IO' Socks 4 YES/NO Structure South Pillows 4 Side Pads 25 Disposal Bags 5 Emergency Response Guidebo,ok 1 Neoprene Gloves 4 pair Goggles 2 I Rope 2 x25' Sealed?

Oil Boom Trailer Absorbent Mats 20 YES/NO East Side of OSSC Pad Oil & Debris Containment Boom 3 x 100' Oil & Debris Containment Boom 1x50' Lubricant for Hardware 1 Bottle I Cooling Tower 95 Gallon Ovemak Salvage Drum Transformers (2 Kits) Sealed?

5" x 10' oil-only booms 3 YES/NO 3" x 10' oil-only booms 10 Absorbent Pads 10 Disposal Bags 1 Neoprene Gloves r 4 pair I Appendix E OP 2106 Rev. 35 Page 8of10

APPENDIX E (Continued)

Kit/Item Minimum Verified Location Items Quantity (Initials/Date)

Oil Kit Sealed?

Lube Oil Room Absorbent Mats (on 248') 20 YES/NO on 248' Elevation Absorbent Socks 4 Absorbent Pillows 4 Gloves 2 Repair Putty Tables 2 Goggles 1 Emergency Response Book 1 I B-UPS-2A 20 Gallon Aggressive Kit Sealed?

Outside Room in 46" Socks 3 YES/NO Men's Clean Pillows 3 Locker Room West Side Pads 36 Shaker bottle of Spill-X-A 1 Disposal Bags 10 Neoprene Gloves 4 pair Goggles 2 Sodium Bicarbonate (in buckets) 25 pounds I Wall Mount Aggressive Kit Sealed?

Training Center Outside Absorbent Mats 20 YES/NO Chemistry Lab Absorbent Pillows 5 on Hallway Wall Gloves 1 Disposal Bags 2 F aceshield/Goggles 1 Emergency Response Book 1 I Appendix E

. *, ' ' ,..,

r ,,. ....., .

OP 2106 Rev. 35 Page 9of10

APPENDIX E (Continued)

Kit/Item Minimum Verified Location Items Quantity (Initials/Date)

Oil Kit Sealed?

Training Center Absorbent Mats 20 YES/NO in Warehouse Absorbent Socks 4 Absorbent Pillows 5 Disposal Bags 2 Putty 1 Wipes 20 Gloves 1 Goggles 1 Fuel Solidifier 1 Emergency Response Book 1 I Discrepancies (such as: kits not easily accessible, supplies inadequate, poor physical condition, etc):

(Print/Sign) Date Hazardous Waste Coordinator (Print/Sign) Date Appendix E OP 2I06 Rev. 35 Page IO of IO

APPENDIXF VYNPS SPILL REPORT RECORD (TYPICAL)

(320 Governor Hunt Road - Vernon, Vermont 05354)

A. Initial Spill Description (Completed by Control Room)

1. Date/Time of Release: I

2. Name of Employee Reporting Release:

3. Release Location:

4. Material Released (if known):

5. Evacuation Procedures Implemented: D Yes D No

6. Incident Triggered a Nuclear Regulatory Commission Notification: D Yes D No

7. Condition Report Number:

B. Initial Spill Response (Completed by HAZMAT Team Member)

1. Type of Material Released:

2. Hazards of Released Material Known: D Yes 0No

3. Personal Protective Equipment Required: D Yes 0No

4. Incident Type:

D Explosion D PipeNalve Leak or Rupture D Fire D Loading/Unloading D Container Leak or Rupture D Vehicle Leak D Tank Leak or Rupture D Other:

5. Release .Classification: D Incidental D HAZMAT Emergency

6. Source of Release:

7. Estimated Quantity Released:

8. Affected Media(s):

D Air D Water D Soil D Other: _ _ _ _ _ _ c _ __ __

9. Affected or Potentially Affected Waters:

D River D Stream D Drainage Ditch D None Appendix F OP 2106 Rev. 35 Page 1of4

APPENDIX F (Continued)

10. Estimated Quantity Released to Waters (if applicable): ~~~~~~~~~~~~-

11. Immediate actions taken:

D Containment D System Shutdown D Dilution D Diversion of Release

D Evacuation D Personnel or Equipment Decontamination D Hazard Removal D Monitoring D Neutralization D Other:

12. Damages or injuries caused by release: D Yes D No If yes, briefly explain:

13. Date!fime Incident Ended: I C. Reportability Determination (Completed by Chemistry and RP)

1. Release exceeded State or Federal Reportable Quantity: D Yes D No

2. Entergy Duty Manager notified: D Yes D No

3. National Response Center notified: D Yes D No

4. State Regulatory Agencies notified: D Yes D No

5. Notifications documented on Section D and E of this report (as applicable): D Verified

6. Notifications to the State of Vermont completed within 10 days per Vermont, Agency of Natural Resources, Hazardous Waste Management Regulations. 0Yes 0No Name of person completing form:

Signature of person completing form: I Date AppendixF OP 2106 Rev. 35 Page 2 of4

APPENDIX F (Continued)

AND COMMITMENTS ..*..*......*.**............*...*.*********.......*...*..**............*....**...... 9 6.0 FINAL CONDITIONS ................................................................................................................ 10 7.0 ATTACHMENTS ............. ~**********************************************************************************************~***********10 8.0 QA REQUIREMEN:TS CROSS REFERENCE ........................................................................ 10

'*' * * ** : ..... ~0'1, PP 7503 Rev. 8 Page 2of10

1.0 PURPOSE, SCOPE, AND DISCUSSION 1.1. Purpose To establish program guidance and hazardous waste handling procedures in order to:

Ensure Vermont Yankee is in full compliance with all applicable State and Federal Environmental Regulations at the Vernon Station and Brattleboro Corporate Office and Training Facility.

Provide assurance that work performed at Vermont Yankee does not adversely affect employees and contractors, the general public or the environment.

Technical Specifications are not addressed in this procedure.

1.2. Scope This program applies to personnel who and all activities which generate waste materials at Vermont Yankee.

The objective of the Hazardous Waste Program is to maintain an effective program for identifying, minimizing and handling of waste materials generated at VY to eliminate the hazards to personnel, the general public and the environment. Specifically:

To ensure personnel safety and minimize exposures to hazardous wastes through personnel knowledge and awareness and proper material and waste handling techniques and practices;

To promote good planning practices which minimize the generation of waste materials and provide less hazardous alternatives;

To properly identify and classify waste streams generated as a result of ongoing work and maintenance activities at VY;

To properly track and handle waste materials generated as part of the ongoing work and ma}ntenance activities at the VY Plant;

To ensure the availability of adequately trained personnel who handle and store wastes providing assurances that wastes are properly labeled and stored properly as it relates to compatibility;

To ensure wastes are properly manifested and transported to approved facilities for treatment and disposal;

To ensure adequate contingency planning and the availability of appropriately trained response personnel to mitigate the consequences of spills or leaks or fires involving hazardous materials and wastes;

To monitor and assess VY performance relative to industry standards and initiatives and modify the VY Hazardous Waste Program to optimize manpower efficiency and reduce costs; and

To conduct all waste activities in compliance with pertinent regulations, permits, and licenses.

"' *" PP 7503 Rev. 8 Page 3of10

1.3. Discussion This procedure functions as the single controlling umbrella document for all of the Hazardous Waste regulations and statutes thaf apply to Vermont Yankee. This procedure:

y

Lists all of the current Hazardous Waste regulations with which Vermont Yankee must comply in accordance with state and federal statutes; and

Designates responsibility of departments and individuals for developing and

'implementing procedures or programs to assure compliance with each regulation.

Steps of the procedure may be performed out of sequence or concurrently.

The applicable Vermont Regulations fall under the jurisdiction of the Vermont Agency of Natural Resources (VANR) or the Vermont Department of Health, VOSHA Division.

Generally, management approval and direction for hazardous waste activities is demonstrated in the review and approval process for plant procedures, and more subtly through specific position descriptions and standing and night orders. Specific key elements of the program are outlined and described below with a basic philosophy or approach provided. Although redundant to other documents in some cases, these particular items are of significant importance to a successful, cost effective program to warrant specific Hazardous Waste Program management direction.

Appendix B describes the administrative controls and actions necessary to prevent or. respond to a discharge of hazardous waste into the environment.

2.0 DEFINITIONS 2.1. Hazardous Waste: Any waste or combination of wastes of a solid, liquid, contained gaseous, or semi-solid form, including but not limited to those which are toxic, corrosive, ignitable, reactive, strong sensitizers, or which generate pressure through decomposition, heat or other means, which in the judgment of the Secretary of the VANR or his or her duly authorized representative may cause or contribute to, an increase in mortality or an increase in serious irreversible or incapacitating reversible illness, taking into account the toxicity of such waste, its persistence and degradability in nature, and its potential for assimilation, or concentration in tissue, and other factors that may otherwise cause or contribute to adverse acute or chronic effects on the health of persons or other living organisms, or any matter which may have an unusually destructive effect on water quality if discharged to ground or surface waters of the state. All special nuclear, source, or by-product material, as defined by the Atomic Energy Act of 1954 and amendments thereto, codified in 42 U.S.C. Section 2014, are specifically excluded from this definition.

PP 7503 Rev. 8 Page 4of10

3.0 PRIMARY RESPONSIBILITIES 3 .1. Organization 3 .1.1. Radiation Protection and Chemistry Department personnel are identified on the Vermont Yankee Organizational Chart. Specific individuals within the departments have varying degrees of involvement depending on their level and scope of training.

3.1.2. The size of the organization can expand temporarily as special.needs arise or additional support or expertise is required. Permanent modifications to the organizational chart or increases in support personnel numbers beyond authorized resources require additional management approvals and shall be controlled by the appropriate corporate policies.

3.2. Responsibilities A brief description of management level responsibilities is outlined below. More detailed responsibilities and specific authorities are defined in individual position descriptions or identified in approved policies, procedures or management directives.

3.2.1. Decommissioning Director- Maintains overall responsibility for corporate oversight of VY Plant and Corporate facilities.

3.2.2. Senior Manager, Production - Responsible for safe, orderly and efficient routine work and special projects at the VY Plant and therefore maintains control of any and all hazardous waste operations.

3.2.3. Manager, RP Chemistry- Responsible for managing hazardous waste to ensure the health and safety of Plant personnel, the general public and the environment, and to ensure that any and all hazardous waste activities are performed in support of the objectives of this program.

Responsible for minimizing quantities and varieties of hazardous materials on site, ensuring personnel training and awareness of hazardous materials and discussing disposal options of new hazardous materials with the Hazardous Waste Coordinator (HWC).

3.2.4 .. Superintendent (not specifically listed by title) - Responsible for identifying to the HWC those materials, which when used by personnel under their cognizance, create a potential hazardous waste stream source.

These positions report to their respective superintendent as indicated on the company organizational chart.

3.2.5. Hazardous Waste Coordinator- Responsible for administration and development and implementation of the hazardous waste program to ensure compliance with all regulatory requirements. The HWC shall keep abreast of amendments to existing hazardous waste regulations and proposed new state and federal regulations that could apply to VY.

- - I;*',.!

PP 7503 Rev. 8 Page 5of10

This position is 3: designated responsibility and reports to the RP/(:hemistry Manager.

3.2.6. Chemistry Technician - Perform duties and responsibilities, as qualifications and training permit, outlined in position job description.

This position, when performing hazardous waste activities, reports to the HWC.

4.0 PROCEDURE 4.1. Procedures 4.1.1. Controls for hazardous waste activities are written in the form of administrative procedures or are contained in Entergy site specific fleet procedure V-EN-EV-106, Waste Management Program.

4.1.2. Procedures are to be considered as management directives and are expected to be followed. Procedure, users are considered to be trained professionals and therefore rigid compliance through known errors is not an acceptable approach. Deficiencies or deviations shall be resolved by formalized change processes per plant procedures.

4.1.3. Written procedures shall contain sufficient detail to ensure satisfactory compliance with the work effort, but need not delineate basic skills normally possessed by qualified personnel as determined and described in the Training and Qualification Section of this procedure. '

4.1.4. Vendor technical information shall be used as reference material in the preparation of procedures and should be used as guidance in conjunction with specific tasks, if appropriate.

.. ,.* .. PP 7503 Rev. 8 Page 6of10

4.2. Work Descriptions and Required Personnel Training (ER98002012_01)

NOTE If not listed below, worker responsibilities are addressed through initial Gener~! Employee Training (GET), GET Annual Requalification and Em lo ee Continuin Trainin Pro rams.

4.2.1. Emergency Responders to a Hazardous Substance Release 4.2.1.1. Fire Brigade members at VY are qualified as "first responder operations level" as described in VOSHA 1910.120(q)(6)(ii) and 40CFR265. This training qualifies the fire brigade to respond in a defensive manner without actually trying to stop a release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures. Annual refresher training is required.

4.2.1.2. Selected employees at Vermont Yankee are qualified at the "hazardous materials technician" level as per VOSHA 1910.120(q)(6)(iii) and 40CFR265.

These individuals are qualified to respond to releases or potential releases for the purpose of stopping the release. Annual refresher training is required.

4.2.1.3. Personnel acting as the Hazardous Waste Coordinator and who may be involved in an emergency response to a hazardous substance release must attend a course as specified in VOSHA 1910.120 and 40CFR265.

4.2.1.4. The offsite Medical Response Team member(s) called to respond to a personnel medical emergency at a hazardous substance release area boundary are trained at the First Responder Awareness level. This training requires annual refresher (GET).

4.2.2. Technicians performing general Hazardous Waste Operations including collection and labeling of waste, ownership of satellite accumulation areas; and inspection of hazardous waste storage areas.

NOTE Qualified members of the Chemistry Department are designated owners of all satellite accumulation areas on site.

4.2.2.1. Complete Vermont Yankee's General Employee Training Program annually.

4.2.2.2. Complete Hazardous Waste training as required.

4.2.2.3. Attend 49CFR172.704 training at least once every three years. .. ~-. J~ _.,:. ~: " **.**. ' .

.~ )(

PP 7503 Rev. 8 Page 7of10

4.2.2.4. Complete on-the-job training as required to perform the task assigned.

4.2.3. Individuals Classifying, Managing and Directing Hazardous Waste Operations 4.2.3.1. Attend a course as specified in VOSHA 1910.120(e)(4).

4.2.3.2. Complete Hazardous Waste training as approved by the Hazardous Waste Coordinator.

4.2.3.3. Attend 49CFR172.704 training at least once every three years.

4.2.4. The Hazardous Waste Coordinator, integral with the Training Department, maintains and ensures the assignment of qualified technicians to perform duties in support of program objectives.

4.2.5. Contracted services, whether integrated with staff personnel or assigned specific tasks, are verified to have the necessary qualifications and training prior to commencement of work activities.

4.3. Performance Indicators 4.3 .1. Performance indicators are an important element of any program which enable the program owner to conduct timely assessments of the effectiveness of a program.

4.3.2. The HWC shall monitor the effectiveness of the program efforts by generating and trending the following performance indicator(s), as a minimum:

Total pounds of hazardous waste produced per month 4.4. General Implementation 4.4.1. Implementation of this program is generally controlled by approved procedures. This section does not supersede or eliminate the need for specific procedures when appropriate. The topics contained in this section illustrate management approval and direction for those areas which are generically applied and implicit to various positions and activities.

4.4.1.1. Pre-job briefings and post-job critiques shall be used to improve efficiency and response for complex tasks and, where applicable, increase personnel safety. The importance of including ALL parties involved in a particular work effort in the briefings and critiques cannot be over stressed.

4.4.1.2. Contract personnel performing or supporting a work effort shall report to a level of oversight as determined by the appropriate Department Manager.

.,.~ ~ . . .. - ~. '_; '. *",. ' L *

PP 7503 Rev. 8 Page 8of10

4.4.1.3. Personnel safety and compliance with the VY Safety Manual and Entergy Industrial Safety Procedures is each individual's responsibility. All levels of management shall ensure appropriate attention to safety and good housekeeping is included in the performance of hazardous waste activities.

4.4.1.4. Engineering support functions, when identified, are requested as needed within existing policies and procedures to ensure hazardous waste activities receive necessary technical support.

5.0 REFERENCES

AND COMMITMENTS 5.1. Technical Specifications and Site Documents 5.1.1. Vermont Yankee Emergency Plan and Implementing Procedures 5.2. Administrative Limits 5.2.1. None 5.3. Codes, Standards, and Regulations 0 .

5.3.1. VANR, Hazardous Waste Management Regulations 5.3.2. VANR, Air Pollution Control Regulations 5.3.3. VANR, Underground Storage Tank Regulation 5.3.4. 10CFR20 (Waste Oil Incineration) 5.3.5. 29CFR (OSHA and VOSHA) 5.3.6. 40CFR (EPA) 5.3.7. 49CFR (DOT) 5.3.8. ANSI 18.1 5.4. Commitments 5.4.1. None 5.5. Supplemental References 5.5.1. V-EN-AD-103, Document Control and Records Management Programs 5.5.2. V-EN-EV-106, Waste Management Program 5.5.3. V-EN-EV-112, Chemical Control Program 5.5.4. V-EN-EV-120, Polychlorinated Biphenyl Management Program 5.5.5. V-EN-IS-101, Industrial Safety and Health Program 5.5.6. V-EN-IS-111, General Industrial Safety Requirements 5.5.7. AP 0010, Situational Reporting Requirements 5.5.8. AP 0156, Notification of Significant Events 5.5.9. RPAP-ASB-0509, Working with Asbestos 5.5.10. OP 2106, Oil and Hazardous Materials Spill Prevention and Control.

..... ,~ *--.

- 1 ..... - . . . . *-*

5.5.11. AP 4801, .Management ofUndergro_t,md Stm;age Tanks (USTs) 5.5.12. AP 68.05, Document Process1rig.Lancfti1stribution *

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PP 7503 Rev. 8 Page 9 of IO

6.0 FINAL CONDITIONS 6.1. This procedure is retained per V-EN-AD-103.

7.0 ATTACHMENTS 7.1. Appendix A Deleted 7.2. Appendix B Vermont Yankee Nuclear Power Station l{azardous Waste Contingency Plan 7 .3. Appendix C Deleted 8.0 QA REQUIREMENTS CROSS REFERENCE 8.1. None

~ .;

~'i'-_,. I ~, * *<**~-..:....'( ** - * ".--c "'~r PP 7503 Rev. 8 Page 10of10

APPENDIXB VERMONT YANKEE NUCLEAR POWER STATION HAZARDOUS WASTE CONTINGENCY PLAN NOTE A hazardous waste contingency plan is only required if/when VY is a large quantity generator of hazardous waste, otherwise, this section does not a l .

1.0 Program Description The Hazardous Waste Contingency Plari (HWCP) identifies and describes the administrative controls and actions necessary to prevent or to respond to a discharge of hazardous waste into the environment.

As allowed by Vermont Hazardous Waste Regulations 7-308 (large quantity generator), if a facility already has a Spill Prevention, Control and Countermeasures (SPCC) Plan or some other emergency or contingency plan in place, the facility need only amend that plan to incorporate the provisions necessary to comply with the contingency plan requirements. Therefore, references to other existing site plans are included in the HWCP.

Vermont Yankee Procedure OP 2106 (Oil and Hazardous Materials Spill Prevention and Control) contains specific and detailed information on actions to be taken to respond to oil or hazmat incidents, including hazardous wastes, drawings, outside assistance, required notifications and detailed descriptions of emergency equipment and supplies.

A copy of this HWCP Plan is maintained in the Vermont Yankee Nuclear Power Station (VYNPS) plant procedure process and is submitted to response teams that may be called upon to provide emergency services such as local fire departments (Vernon and Brattleboro), the Vermont Hazardous Materials Response Team (VHMRT), and the Local Emergency Planning Committee (LEPC) Chairman.

2.0 References and Attachments (This Plan conforms to the following Vermont and federal regulations:)

2.1 Vermont Water Quality Standards, as amended.

2.2 Vermont Hazardou~ Waste Management Regulations Section 7-309, as amended.

2.3 Vermont Underground Storage Tanks Regulations, as amended.

2.4 40CFRI 10, "Discharge of Oil."

2.5 40CFRI 12, "Oil Pollution Prevention."

2.6 40CFR302, "Designation, Reportable Quantities, and Notification."

2.7 40CFR355, "Emergency Planning and Notification."

2:8 29CFR1910.120 P. 3, "Emergency Operations" under OSHA.

2.9-

..---Federal Oil Pollution-Act of 1990 ("OPA-90.") T'._._. -: ,_._, ._ ,, ~ *_*.: 0 ::::;-::*.-_\'t:~ *_c: :-:~:- 0 Appendix B

- PP 7503 Rev. 8 ~..> .-** **

Page 1 of8

APPENDIX B (Continued) 3.0 Facility Identification and General Information 3.1 Name: Vermont Yankee Nuclear Power Station

3.2 Location

320 Governor Hunt Road Vernon, Vermont 05354 3.3 EPA Identification Number: VTR000504167 3.4 Type of Facility: Large quantity generator of hazardous waste (90-Day Accumulation) or Small quantity generator of Hazardous waste,(180-Day Accumulation), or a conditionally exempt generator (no accumulation limit).

3.5 Facility Site Plan: Maintained in Figure 1 of Appendix B to VYNPS Procedure OP 2106, Oil and Hazardous Materials Spill Prevention and Control.

3.6 Description of Generator Activities: VYNPS is a shutdown nuclear station. Hazardous wastes are generated from routine plant maintenance activities and special projects. The type of hazardous wastes generated is identified in Appendix A to VYNPS Procedure

.I V-EN-EV-106, Waste Management Program.

4.0 Coordination Agreements 4.1 Written agreements with appropriate offsite authorities are maintained in Appendix E to Vermont Yankee's "Emergency Plan," except for the agreement with the Brattleboro Memorial Hospital which is maintained by the Hazardous Waste Coordinator and the open contract with Clean Harbors and Enpro Inc. which are maintained by the Purchasing Department.

5.0 Emergency Coordinators 5.1 The Shift Manager at Vermont Yankee is responsible for implementing site contingencies in the event of a hazardous wastes incident. A Certified Fuel Handler is on-site 24-hours a day. In addition, the Hazardous Waste Coordinator provides technical advice and support in the event of an incident. If the Hazardous Waste Coordinator cannot be reached, the next designated Alternate will assume the responsibilities of the Hazardous Waste Coordinator. The list of primary and alternate Emergency Coordinators, along with addresses and phone numbers, is maintained in Appendix B to VYNPS Procedure OP 2106, Oil and Hazardous Materials Spill Prevention and Control.

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Appendix B PP 7503 Rev. 8 Page 2 of8

APPENDIX B (Continued) 5.2 The onsite Operations personnel includes members assigned to each shift and is the designated first responder to hazmat spills, leaks, overflows or fire. The Certified Fuel Handler is responsible for incident command and control until the situation is ended, stabilized, or otherwise resolved, or if necessary, the incident is turned' over to a responding Southeastern Mutual Aid Fire Department and/or a commercial hazmat response company (i.e. Clean Harbors). Members of the Fire Brigade will be advised and supported by the Hazardous Waste Coordinator in the event of an incident.

6.0 Emergency Equipment 6.1 Communication System - VYNPS Procedure EPOP-COMM-3504, Emergency Communications, describes the available communications equipment, the location of this equipment, and the procedures for communicating with onsite and offsite groups, including Federal and State authorities. Communication systems are periodically tested for readiness in accordance with VYNPS Procedure EPOP-EQUIP-3506, Emergency Equipment Readiness Check. At the hazardous waste storage/shipping area, a Gaitronics and/or telephone is available for use in the event of an incident.

6.2 Fire Control Equipment - VYNPS Procedure OP 3020, Fire Emergency Response Procedure, establishes the fire emergency response plan for all fire incidents at the VY site. VYNPS Procedure OP 4103, Fire Protection Equipment Surveillance, lists the location of fire control equipment on-site such as fire extinguishers, foam equipment, fire hoses and other fire brigade gear. At the hazardous waste storage/shipping area, fire fighting equipment (fire extinguisher) is available, if needed.

6.3 Spill Control Equipment - Spill control equipment is available throughout the plant area for activities associated with response, containment and cleanup. The locations of these spill equipment stations are shown in Appendix E to VYNPS Procedure OP 2106,.

Hazardous Materials Spill Prevention and Control. The equipment is periodically inventoried in accordance with the frequency specified in the procedure.

6.4 Personal Protective Equipment - Personal protective equipment that is available to provide emergency crew members with protection when responding to emergency spills are listed in Appendix E to VYNPS Procedures OP 2106, Hazardous Materials Spill .

Prevention and Control and OP 4103, Fire Protection Equipment Surveillance.

Appendix A to VYNPS Procedure DP 4579, Respiratory Protection Equipment Inspection and Maintenance, lists locati6ns where self-contained breathing apparatus

\

(SCBA) can be obtained for the use of emergency crew members in extreme emergencies for rescue operations.

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Appendix B PP 7503 Rev .. g Page 3of8

APPENDIX B (Continued) 7.0 Evacuation Pian Depending on the severity of a hazardous waste incident, evacuation of personnel, routes of exit and signals to be used will occur by either:

7.1 Vermont Yankee's "Emergency Plan" or 7.2 As verbally directed by the Control Room via the site's communication system (Gaitronics) or at the scene as directed by Shift Manager.

8.0 HWCP Amendments and Reviews 8.1 The HWCP and/or supporting Plans will be reviewed and amended if:

Applicable regulations are revised that significantly impact the Plant, or l.

Lessons learned from an actual hazmat emergency warrant a change, or

The facility significantly changes in its hazmat facility design, construction, operation, maintenance, or other circumstances, in a way that significantly affects the potential for fires, explosions, or releases of hazardous wastes, or changes the response necessary in an emergency, or

The list of emergency coordinators or emergency equipment changes, or

Deemed necessary by the Hazardous Waste Coordinator.

8.2 Copies of the most recent revision will be maintained at the VYNPS facility and submitted to the Vernon and Brattleboro Fire Departments, the Vermont Hazardous Materials Response Team (VHMRT), and the Local Emergency Planning Committee (LEPC).

9.0 Emergency Response Procedures 9.1 Any person who discovers or suspects a hazardous waste spill, leak, overflow, release or fire, shall immediately notify the Control Room who in turn will implement OP 2106, Oil and Hazardous Materials Spill and Control, as appropriate.

9.2 Emergencies which call for the initiation of the Plan include hazardous waste spills, leaks, releases, overflows or fires which may or may not be contained and controlled within proper storage or containment areas with equipment and materials at hand on-site.

Appendix B PP 7503 Rev. 8 Page4 of8

I APPENDIX B (Continued) 10.0 Notification of State and Federal Regulatory Agencies 10.1 In the event of a spill, leak, release or fire to the environment, notifications and reporting to federal and state regulatory agencies wql be made in accordance with VYNPS Procedures OP 2106, Oil and Hazardous Materials Spill Prevention and Control, and AP 0010, Situational Reporting Requirements.

11.0 Inspection Procedure 11.1 Facilities storing or accumulating hazardous wastes are regularly inspected for malfunctions, deterioration, and conditions that could cause or lead to a release of a hazardous waste into the environment or a threat to human health in accordance with V-EN-EV-106, Waste Management Program.

11.2 Inspection records and requirements are defined in the above applicable Procedures.

12.0 Personnel Training 12.1 All site employees are trained to the "First Responder, Awareness Level" by participating in an annual review of their initial General Employee Training (GET). The annual review includes a presentation of pertinent amendments, updates, or changes in the Plan, implementation procedures, and regulations.

12.2 Fire Brigade members at VY are qualified as "flrst responder operations level" as described in VOSHA 1910.120(q)(6)(ii) and 40CFR265. This training qualifies the fire brigade to respond in a defensive manner without actually trying to stop a release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures. Annual refresher training is required.

12.3 Selected employees at Vermont Yankee are qualified at the "hazardous materials technician" level as per VOSHA 1910.120(q)(6)(iii) and 40CFR265. These individuals are qualified to respond to releases or potential releases for the purpose of stopping the release. Annual refresher training is required.

12.4 Personnel acting as the Hazardous Waste Coordinator and who may be involved in an emergency response to a hazardous substance release must attend a forty-hour course as specified in VOSHA 1910.120 and 40CFR265.

12.5 Documentation of the type and extent of both initial and continuing training for each employee at the facility is maintained. Training records are kept until closure of the facility for current employees.

13.0 Management of Cleanup Materials 13 .1 Any waste generated as a result of a spill, leak, overflow or release will be managed in accordance with V-EN-EV-106, Waste Management Program. ~**-.* ,_ .. ,,'.,_._._.

Appendix B

' *' * *"r*P-P 7503 Rev. 8 Page 5 of8

APPENDIX B (Continued)

Oil Storage Locations El*

1. 01e. .1Fl.Mi Oii Storage Tank

>. DELETED

3. OCLETEO

10. DELDEO

17. DELETED

MA.ZMA. 1 RESPO'ISE SPILL Kff / ITEM LOCATIONS

. DELDEO 18. DELDEO JO . TurbiM Buiding Tran~ (T*<<HA)

5. Di9HI Fwel UST {V*hlde) 1s. M-'n nnlionnet 31. Tu rbine Buldlng T,..MlorTMl(T*1* 1A)

I . DleHI Fllltl UST [Vehlde) 20 580 Diesel * -4 2 (2106 APPENDIX 0) 32. TufCiM Bulding Trant.ronn.t(T-10-lA)

1. John o..t. Dleeel Fu.I UST 21 . AutoTr~ '3 . a.r..raV'~ Grounding Tranafonnlr I . Pl8 Dieeel F.- UST 22. S&a-tup T,.r.IOfiner(f-3A) 3" . V*mon 1-i)dro Ti9 l!M T,.nstairm.r I. ~aoUM Tank (Vehkh) 23. $Ur1'.lplt~rnl r( T-38) 3~ . P..bln Tran.W on*

10. DELETED 2* . Auitibry T ~ r Je . Oil CiroJit B'9111k.,. Bold =Fuel Unloading Araa

25. We* SWitc:hg.<< Room TtlnalOllMr 31 . Shipping & ~n; No. 2 Fuel Oil T.,k

11. DELETED 21. E.U ~..,Room Trenatonnner 31 . (A a. 8 ) Go.' Hunt Rei No. 2 Fuel Oil hnq

12. HouM MN.tln11 lohr F...a Tank 21. Cooing T°""* Trar"*>mWI 31. s.p.r. Cooling lO'#er Trendom-.,.

1J. Diael l'h """1p Fwl TaM 28. COB fr11rwform.r 40. PS8 Tl'aNformer i4. lloblle Fu.I Oii Tank 29. AdnWl;onW.llui"'"'<IT"'"""'- '1 . 6i k¥ Ol&lrt:luion Tt9rldot'l\1t Appendix B PP 7503 Rev. 8 Page 6 of8

APPENDIX B (Continued)

Bulk Chemical Locations tO S ~ f'AIJI D

j Olf ice Troiter* I c:::::J D*

HAZMAT RESPONSE SPILL KIT I ITEM LC>CATIONS D@l H. Cwbon Dioxide T-*{Fft6upp1--">n)

A DELETED 8 . 1"'811.eSlnKU*T...._rtN...,T,..tmWIC) 1. DELETED J. ConlprMMCS GaMa

c. DELETED K. BU6t HydrQgen Fac:iMy

o. North Warehouse (EMPTY)

L. TurtMne Buldlng (Hu.wdoua Wea.II!!)

E . Chofni*Y l

bur.tor)'

DD F. Storn War.hOUM G. New Oil Storage Building Appendix B PP 7503 Rev. 8 Page 7 of8

APPENDIX B (Continued)

Storm Drain Locations

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Mloo-M*~'WITWMIOO<S

~M)9A~,*~N&JI~~

-.1c.,....,.,W\...,..,!IHt<AVlt9TO\.Col'4ill*w-=:cst~, AUO"IM""°1~

Appendix B PP 7503 Rev . 8 Page 8 of8