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The Clean Up Process
Site remediation at Yankee Rowe consists of two components. The radiological component will be conducted under the terms of the License Termination Plan
which in being developed under the guidance of the federal Nuclear Regulatory
Commission. The second, non-radiological restoration, will take place under
the supervision of a licensed site professional in conformity with a range of
local, state and federal regulations.
Radiological Remediation
The Nuclear Regulatory Commission’s compliance procedures that specifically address radiological substances or impacts are well defined. Since 1992, Yankee Atomic has followed the process prescribed by the Nuclear Regulatory Commission (NRC) to decommission the facility, release the site and terminate the NRC license. Throughout each of these steps, Yankee has maintained its goal to involve stakeholders.
One of the objectives for decommissioning the Yankee Atomic site is to reduce the remaining radioactivity to levels that allow the release of the site for unrestricted use and for termination of the Nuclear Regulatory Commission license. To accomplish this objective, Yankee Atomic developed and submitted a License Termination Plan (LTP) The LTP describes the site characterization and the remaining decommissioning activities that will be performed. It also describes any remediation activities that may be necessary to meet unrestricted use cleanup criteria and the process for performing the Final Status Survey.
Pursuant to the License Termination Plan, Yankee Atomic is conducting the necessary remedial actions to ensure that outstanding radioactivity levels are reduced below 25 mrem/yr and will also meet the “As Low As Reasonably Achievable” (ALARA) requirements established by the Nuclear Regulatory Commission.
Non-radiological Remediation
Non-radiological activities can be divided by:
Polychlorinated biphenyls
One environmental remediation project that was completed involved the investigation and removal of soil and sediments on the site that contained polychlorinated biphenyls (PCBs). This PCB contamination resulted from the chipping of paint used to coat a portion of building surfaces at the Yankee Atomic plant. Yankee Atomic began its investigation and remediation in 2000 to address the presence of PCBs in the site’s soils and sediments following the procedures of the Massachusetts Contingency Plan (MCP) requirements. In order for the material to be considered “remediated” it just be removed from the site and transferred to a certified disposal facility.
The steps adhered to by Yankee Atomic for materials preparation and release that were required by the Massachusetts Contingency Plan (MCP) in its Phase I Initial Site Investigation and Tier Classification were as follows:
The Phase IV Remedy Implementation Plan describes the specific remedial actions proposed to abate PCBs in soil and sediment to satisfy the requirements of the MCP. These activities consisted of remediation of sediments and soils with the potential to impact storm drain outfalls into the Sherman Reservoir and the Deerfield River. Final permitting to authorize Yankee Atomic to conduct this Phase IV activity was received in October 2004 with an Order of Conditions, Water Quality Certification, Waterways Permit, and Category 2 Programmatic General Permit.
The soil and sediment remediation were conducted and completed in 2005 for the Sherman Reservoir and the West Storm Drain. Target cleanup levels were authorized through state permitting proceedings to enable Yankee Atomic to achieve a level of no significant risk to human health, welfare, public safety and the environment under current and reasonably foreseeable future land uses.
Structures
Another clean-up activity at the site is the demolition of structures and relocation of remaining debris. Demolition of all above-ground site buildings and structures and all below-grade structures has been completed. The demolition and excavation of subsurface utilities and structures was also completed. The demolition material from above-ground structures was characterized and sorted for beneficial reuse as fill or grading material or for off-site disposal consistent with the conditions imposed by several required permits for the management of demolition materials. The industrial portion of the site consists of excavation material, clean fill, and topsoil that are being graded to meet the final site configuration consistent with approved plans.
Fill Material
In 1999, Yankee began its characterization of potential environmental impacts to the Southeast Construction Fill Area (SCFA). The SCFA is a former construction debris fill area. Yankee Atomic submitted a Corrective Action Design (CAD) to DEP in July 2004 that was based upon this characterization of potential environmental impact. This submitted document combined important findings from the Initial Site Assessment (March 2000), a Comprehensive Site Assessment (September 2001) and a Corrective Action Alternatives Analysis (April 2004). The Corrective Action Design proposed a process to excavate, characterize and remove soils from the Southeast Construction Fill Area (SCFA). This document also described the reuse of appropriate excavated landfill materials for on-site fill and grading activities and disposal methods for unacceptable soils and solid waste at off-site disposal locations.
The Order of Conditions that permitted Yankee to authorize the SCFA materials removal was completed in September 2004. Yankee Atomic submitted an application for a Beneficial Use Determination (BUD) to authorize its reuse of the landfill material. The final major permitting activity for environmental site closure activities was completed with the issuance of a Beneficial Use Determination (BUD) approved by the Massachusetts Department of Environmental Protection in July 2005, and amended in September 2005. This BUD specifies:
- Procedures for determining what materials from demolition of the site’s industrial structures
- Equipment eligible for reuse as fill for site grading
- Subsurface structures that may remain in place
- Characterization procedures for determining which demolition materials must be disposed off-site
- Conditions by which eligible material may be reused as fill
Under the terms of this BUD, only materials that have no plant-related radioactivity above background levels may be reused as fill. Any materials that exhibit radioactivity above background levels will be removed and disposed of at appropriate off-site facilities.
The BUD requires that any locations at which subsurface structures are to remain in place or at which soil or demolition materials from the Industrial Area or the Southeast Construction Fill Area (SCFA) are reused must be subject to an Activity and Use Limitation (AUL) under the Massachusetts Contingency Plan. The AUL will include deed notifications identifying the specific affected locations and the reused materials. It will also restrict future uses of those locations.
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