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Delivering sustainable solutions in a more competitive world Southeast Construction Fill Area - Corrective Action Design DEP File 01-253-008 Yankee Nuclear Power Station Site Closure Project Rowe, Massachusetts 26 July 2004 ERM 399 Boylston St. Boston, MA 02116 (617) 267-8377 www.erm.com

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Page 1: Southeast Construction Fill Area - Corrective Action · PDF fileSoutheast Construction Fill Area - Corrective Action Design ... Massachusetts Department of Environmental Protection

Delivering sustainable solutions in a more competitive world

Southeast Construction Fill Area - Corrective Action Design DEP File 01-253-008 Yankee Nuclear Power Station Site Closure Project Rowe, Massachusetts 26 July 2004 ERM 399 Boylston St. Boston, MA 02116 (617) 267-8377 www.erm.com

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1.0 INTRODUCTION 1

1.1 BACKGROUND 1

1.2 PURPOSE AND SCOPE 1

1.3 REPORT ORGANIZATION 2

2.0 SITE CHARACTERIZATION 3

2.1 SITE DESCRIPTION 3

2.2 SITE GEOLOGY 3

2.3 SITE TOPOGRAPHY 4

2.4 SITE HYDROLOGY 4

2.5 SUMMARY OF EXISTING SCFA CHARACTERIZATION DATA 5 2.5.1 Non-Radiological Characterization Data 5 2.5.2 Radiological Characterization Data 5

3.0 DESIGN BASIS 7

3.1 CORRECTIVE ACTION OBJECTIVES 7

3.2 ALTERNATIVE EVALUATION 7

3.3 SELECTED ALTERNATIVE OVERVIEW 8

3.4 MANAGEMENT OF RECENT FILL 9

4.0 CONCEPTUAL DESIGN 10

4.1 OVERVIEW AND PERMITTING STATUS 10 4.1.1 Beneficial Use Determination 10 4.1.2 Order of Conditions 10

4.2 DESIGN AND CONSTRUCTION 11 4.2.1 Pre-Characterization of SCFA Soils 11 4.2.2 Protection Of Wetland Resource Areas 11 4.2.3 Well Closure 11 4.2.4 Site Clearing and Access 12

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4.2.5 Establishment of Staging, Stockpile and Construction Zones 12 4.2.6 Excavation and Segregation 12 4.2.7 Disposition of Excavated Materials 14 4.2.8 Backfill and Site Grading 14 4.2.9 Site Restoration and Planting 14

4.3 IMPLEMENATION PARAMETERS 15 4.3.1 Health and Safety Plan 15 4.3.2 Access and Security 15 4.3.3 Dust Control 15 4.3.4 Hazardous Waste Contingency Plan 15 4.3.5 Spill Control and Response 16

4.4 ENVIRONMENTAL MONITORING 17 4.4.1 Groundwater Monitoring 17 4.4.2 Surface Water Monitoring 18

4.5 COMPLETION REPORT 18

5.0 IMPLEMENTATION SCHEDULE 19

6.0 REFERENCES 20

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FIGURES

Figure 1 Site Locus

Figure 2 Aerial Photo Overview

Figure 3 Plant Layout

Figure 4a Landfill Area Existing Cross-Section

Figure 4b Landfill Area Proposed Cross-Section

Figure 5 Proposed SCFA Construction Layout

Figure 6 SCFA Groundwater Contour Map (August 2003)

Figure 7 SCFA Removal Process Flow Chart

Figure 8 Proposed Grading Plan

Figure 9 Proposed Implementation Schedule

APPENDICES Appendix A Transmittal and Application Forms Appendix B Health & Safety Plan

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LIST OF ACRONYMS bgs Below Ground Surface BUD Beneficial Use Determination BVW Bordering Vegetated Wetlands C&D Construction and Demolition CAAA Corrective Action Alternative Analysis CAD Corrective Action Design CFR Code of Federal Regulations CMR Code of Massachusetts Regulations CSA Comprehensive Site Assessment DCGL Derived Concentration Guideline Limit DEP Massachusetts Department of Environmental Protection DPH Massachusetts Department of Public Health EPA Environmental Protection Agency ERM Environmental Resources Management FID Flame Ionization Detector ISA Initial Site Assessment ISFSI Independent Spent Fuel Storage Installation MCP Massachusetts Contingency Plan NOI Notice of Intent NRC Nuclear Regulatory Commission OSHA Occupational Safety and Health Administration PID Photoionization Detector RCRA Resources Conservation and Recovery Act USCS Unified Soil Classification System VOCs Volatile Organic Compounds YAEC Yankee Atomic Electric Company YNPS Yankee Nuclear Power Station

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1.0 INTRODUCTION

1.1 BACKGROUND

This report documents the Corrective Action Design (CAD) for the Southeast Construction Fill Area (SCFA), located at the Yankee Nuclear Power Station (YNPS) in Rowe, Massachusetts. This area has been classified as a construction and demolition (C&D) landfill by the Massachusetts Department of Environmental Protection (DEP). However, this area is believed to contain less than five percent C&D waste, as defined in 310 CMR 19.006. It is predominantly composed of native soil and boulders that were excavated to facilitate construction of the YNPS facility in the late 1950s. The YNPS is owned by Yankee Atomic Electric Company (YAEC) and was shut down permanently in 1992 and is in the process of being decommissioned.

The CAD constitutes the fourth phase of the landfill assessment and closure program. An Initial Site Assessment (ISA), dated 10 March 2000, a Comprehensive Site Assessment (CSA), dated 14 September 2001, and a Corrective Action Alternative Analysis (CAAA), dated 18 December 2003, have been prepared for the SCFA. The CAAA was approved by the DEP in a letter dated 13 April 2004.

The DEP Transmittal Form and the application for landfill closure (BWP SW 25) are included in Appendix A. This report was prepared by Environmental Resources Management (ERM) acting as a consultant to YAEC.

1.2 PURPOSE AND SCOPE

The purpose of the CAD is to describe plans for closure of the SCFA. The CAD is intended to ensure that the information, plans and reports related to the design, construction and implementation of the selected closure alternative are sufficiently developed and documented to support closure of the SCFA. Removal of the landfill was selected as the preferred closure method in the CAAA.

The CAD was prepared in accordance with 310 CMR 19.151(2)(a), DEP’s CAAA approval letter, dated 13 April 2004, and the DEP Landfill Technical Guidance Manual, dated May 1997.

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1.3 REPORT ORGANIZATION

This report is organized into the following sections:

Section 1.0 Introduction - describes the background, purpose and scope of the CAD document.

Section 2.0 Site Characterization - includes a description of the SCFA, along with information regarding the SCFA site geology, topography and hydrology.

Section 3.0 Design Basis – describes the corrective action objectives, includes a summary of the alternatives evaluation provided previously in the CAAA, and provides an overview of the selected SCFA closure alternative.

Section 4.0 Conceptual Design – includes a description of closure activities; schematic construction plans and specifications; characterization sampling; protection of wetland resource areas; site restoration plan; post-closure monitoring plans; health and safety plan; contingency plan; list of necessary permits; and property access issues pertaining to the landfill closure.

Section 5.0 Implementation Schedule - includes a proposed schedule to complete implementation of the landfill closure.

Section 6.0 References

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2.0 SITE CHARACTERIZATION

2.1 SITE DESCRIPTION

The SCFA is located on a portion of the YNPS facility located at 49 Yankee Road, Rowe, Massachusetts (see Figure 1). The YNPS is situated on a 1,800-acre parcel that has been owned by YAEC since plant construction in the late 1950s. The YNPS ceased operation in February 1992. YAEC owns all property within a 500-foot radius of the SCFA footprint. The YNPS is the only industrial complex within 500 feet of the SCFA footprint. All other areas within 500 feet of the SCFA are forested and undeveloped. Figure 2 is an aerial photo of the YNPS site identifying physical site features.

The SCFA consists of 1.2 acres of native fill and C&D fill material (i.e., concrete, asphalt, wood and metal debris). The layout of the YNPS and associated SCFA is shown in Figure 3.

2.2 SITE GEOLOGY

Existing and proposed cross-sections showing the geology of the SCFA are provided as Figures 4a and 4b, respectively. Site geology consists of the following five overburden deposits (from ground surface):

• Recent Fill – consisting of brown silty sand with some gravel. The recent fill was placed in September and October 2000. Approximately 10,000 cubic yards of soil were excavated for the construction of the Independent Spent Fuel Storage Installation (ISFSI) and were placed on top and to the north of the SCFA (up to 15 feet in thickness). This work was conducted in accordance with DEP’s approval letter, dated 13 July 2000. This material is not considered part of the landfill, and therefore is not subject to the BUD being developed for the landfill materials.

• Historic Fill - consisting of poorly sorted sands, cobbles and boulders, with some C&D debris; up to 30 feet in thickness, with an average thickness of 15 feet. The estimated quantity of historic fill in the SCFA is 30,000 cubic yards.

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• Native Soils

• Glaciofluvial Deposits - consisting of brown, stratified, medium to fine sands and silts with some medium to coarse gravel; estimated to be up to 27 feet in thickness.

• Ablation Till - consisting of a grey, dense, poorly sorted, medium to fine sand, some medium to coarse gravel clasts; estimated to be up to 12 feet in thickness.

• Lodgement Till - consisting of brown, highly dense, poorly sorted, fine sand and silt, some cobbles; estimated to be greater than 17 feet in thickness.

Based on drilling performed at the YNPS plant, bedrock below the till is likely a dark gray to black, strongly foliated gneiss dominated by white to light pink albite feldspar crystals.

2.3 SITE TOPOGRAPHY

Site topography consists of moderate hills with steep slopes east and south of the SCFA and gentle sloping toward the Deerfield River north and west of the SCFA. Elevation contours for the SCFA are shown in Figure 5. The SCFA rises gently from the west to the east with steep slopes along a tributary to Wheeler Brook and Wheeler Brook Divertment to the east.

2.4 SITE HYDROLOGY

Locally, groundwater flows northeast to a tributary to Wheeler Brook and southeast to the Wheeler Brook Divertment (see Figure 6). The Wheeler Brook Divertment is a man-made channel that directs surface water into Wheeler Brook, which flows into Sherman Reservoir, an impoundment of the Deerfield River. The divertment was constructed in the mid-1980s to divert water from running as sheet flow across the YNPS site. Depth to groundwater is estimated to range from 25 to 35 feet below existing grade in the vicinity of the SCFA.

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2.5 SUMMARY OF EXISTING SCFA CHARACTERIZATION DATA

2.5.1 Non-Radiological Data

Soil

Soil sampling for non-radiological parameters was conducted in 1998, during a test pit and debris removal program. During the test pit program, 12 soil samples were collected from areas adjacent to or beneath areas where C&D debris had been removed. Tetrachlorethene was detected in one of 10 samples analyzed for volatile organic compounds (VOCs) at concentrations below Massachusetts Contingency Plan (MCP) Reportable Concentrations. No other VOCs were detected. Metals were also detected in the soil samples, but at concentrations that were also below MCP Reportable Concentrations.

Lead-impacted sandblast grit was removed from the SCFA under a Limited Removal Action in October 1998. The source of the sandblast grit and the date in which it was deposited within the SCFA is unknown. Site investigations revealed it to be at a depth of two feet in an excavation at the southern edge of the SCFA. The Limited Removal Action involved the removal of 16 cubic yards of sandblast grit and adjacent contact soil.

During installation of monitoring wells in the SCFA in 1999 and 2001 soil samples were field screened for VOC. Based on a lack of visual or field screening evidence of impact, no soil samples were submitted for laboratory analysis.

More detail regarding the soil sampling activities can be found in the CSA Report (ERM, 2001).

Groundwater

Annual groundwater quality monitoring has been performed at the SCFA since 1999. Low levels of VOCs and petroleum have been detected periodically in groundwater samples, at concentrations below drinking water standards. Iron and manganese have been detected in many of the wells at concentrations higher than the background location.

More detail regarding the non-radiological groundwater sampling activities can be found in the 2003 Annual Landfill Monitoring Report (ERM, 2003a).

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2.5.2 Radiological Characterization Data

The Nuclear Regulatory Commission (NRC) license held by YAEC pursuant to Title 10 of the Code of Federal Regulations, regulates the radiological aspects of site closure. YAEC will follow the process prescribed by the NRC to decommission the facility, release the site and terminate the NRC license. In addition, the Massachusetts Department of Public Health (DPH) has established performance standards for closure of radiological facilities that, in some respects, differ from the NRC license and regulatory requirements. Consistent with its overall regulatory approach, YAEC intends to demonstrate compliance with both the NRC criteria and with the DPH standards. This will include the radiological monitoring of soils and any materials removed from the SCFA landfill.

The radiological survey data indicate that the area is minimally impacted by low levels of radioactivity present in soil deposited in the area. The area may contain residual radioactivity at a small fraction of the Derived Concentration Guideline Limit (DCGL). The primary radionuclides of concern in the SCFA are Co-60, Cs-137, Ag-108m, Sr-90, and tritium. However, to date only Co-60 at small fractions of the DCGL have been detected in several samples. The SCFA is classified as a Class 3 Area.

More detail regarding the radiological soil sampling activities can be found in the Historic Site Assessment, Volume II, OOL-09 (YAEC, 2004).

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3.0 DESIGN BASIS

3.1 CORRECTIVE ACTION OBJECTIVES

Based on information collected as part of the ISA, CSA, and a qualitative risk assessment conducted as part of the CSA, the SCFA does not pose a significant risk to the human health or the environment. There is evidence, however, of minor aesthetic impacts to surface water adjacent to the SCFA. Flocculated iron has been observed in the tributary to Wheeler Brook downstream of the SCFA. Iron and manganese concentrations are higher at the downstream sample location than at the upstream location.

The presence of flocculated iron is also evident at the west end of the Wheeler Brook Divertment at the base of the natural hillside, an area not associated with the SCFA. Similar iron deposits are observed elsewhere on site and regionally. Therefore, the degree to which the flocculated iron observed in the tributary to Wheeler Brook is attributable to the SCFA or to the disturbance of native soils containing iron deposits is not known. Nonetheless, the corrective action objective for the SCFA is to reduce the impacts to the tributary to Wheeler Brook.

3.2 ALTERNATIVE EVALUATION

The alternatives evaluation considered options to removal of the landfill. The evaluation and selection of a closure alternative for the landfill was completed as part of the CAAA, dated 18 December 2003, which was approved by the DEP in a letter dated 13 April 2004. The following alternatives to removal of the SCFA were considered, but not selected because they were not deemed to be the most effective alternative for the long-term.

• No Action – This alternative would leave the landfill in-place and include periodic groundwater and surface water monitoring.

• Standard Landfill Capping – This alternative would cap the landfill in full compliance with the Landfill Technical Guidance Manual, but, would likely impact Bordering Vegetated Wetlands and waters of the United States.

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• Modified Landfill Capping Option 1 – This option would cap the landfill with a new low permeability layer, but without modifying existing side-slopes and without a gas venting layer being established.

• Modified Landfill Capping Option 2 - This option would cap the landfill without modifying existing side-slopes, without a gas venting layer being established, and using existing soil cover as the low permeability layer.

The alternatives listed above were not selected because the no action and capping options would leave the non-native materials in-place and require long-term maintenance and monitoring. Removal of the landfill was selected as the preferred closure alternative because it is consistent with the basic project purpose of decommissioning the facility and restoring as much of the site as feasible to a natural and ecologically beneficial state (i.e., leachate impacts to the Tributary to Wheeler Brook would be eliminated). Furthermore, the feasibility of landfill removal is supported by the low proportion of debris in the landfill and the beneficial reuse of native soil on, and/or, off-site. Although the cost of removal is expected to be higher than the capping alternatives, the certainty of potential benefits to the environment is much greater because the landfill will no longer remain at the site. This would allow for unrestricted future use of the SCFA area, as well as restoration of natural habitat.

3.3 SELECTED ALTERNATIVE OVERVIEW

Removal of the C&D waste and subsequent closure of the SCFA is being integrated into the on-going demolition and grading activities at the YNPS site. Activities associated with the C&D waste removal and SCFA closure are grouped into the following four phases:

• Initial site preparation activities – includes pre-characterization of SCFA soils, establishment of erosion and sedimentation controls, and site clearing of wooded areas as necessary for access and materials management. Prior removal of those soils placed during the construction of the ISFSI pad will provide much of the area required for materials segregation, thus limiting the amount of site clearing activities.

• Excavation and segregation of SCFA soils and boulders, and C&D waste .

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• Backfilling with SCFA materials that have been characterized for use as backfill, grading of SCFA, final SCFA site restoration and planting, and erosion/sedimentation control removal.

• Five years of monitoring and inspection.

Detailed discussions regarding C&D waste removal and SCFA closure are presented in Section 4.0, Conceptual Design.

3.4 MANAGEMENT OF RECENT FILL

The fill material recently placed on top of the SCFA during construction of the ISFSI pad is not considered part of the SCFA. YAEC obtained approval from DEP to temporarily stockpile the soils on the SCFA in a letter dated 13 July 2000. YAEC anticipates that the recent fill will be relocated out of the SCFA area prior to initiation of the landfill removal. Topographic survey elevations obtained prior to and following the placement of the recent fill, data obtained through planned characterization of the SCFA fill material prior to excavation, as well as visual observations, will be used to determine the boundary between the recent fill and the SCFA.

In August 2000, YAEC conducted radiological and non-radiological testing to characterize the soils excavated during the construction of the ISFSI. Some of the soils were remediated in accordance with the Massachusetts Contingency Plan, 310 CMR 40.0000) to address the presence of polychlorinated biphenyls (Release Tracking Number 1-13623). A post-remedial risk characterization that was prepared to support the filing of a Class A-2 Response Action Outcome Statement, dated 9 November 2000, demonstrated that the remaining soils were suitable for unrestricted use.

YAEC is currently evaluating options for transporting some or all of the recent fill off-site to a municipal landfill. YAEC plans to provide DEP with a summary of the characterization data for the recent fill under separate cover.

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4.0 CONCEPTUAL DESIGN

4.1 OVERVIEW AND PERMITTING STATUS

4.1.1 Beneficial Use Determination

Concurrent with the submittal of the CAD, YAEC is submitting an application for a Beneficial Use Determination (BUD) to reuse the SCFA soils on-site to support regrading as part of the decommissioning activities. Approval of the BUD will allow for the on-site reuse of soil and non-native debris that pass the six-inch screen and that are deemed to be suitable for reuse on-site.

4.1.2 Order of Conditions

SCFA closure activities are subject to the issuance of an Order of Conditions from the Town of Rowe Conservation Commission, in compliance with regulations under 310 CMR 10 for the Massachusetts Wetlands and River Protection Acts. A Notice of Intent (NOI) was submitted to the Rowe Conservation Commission on 7 May 2004, as part of an Integrated Permit Package developed to address local, state, and federal wetlands and waterways permitting requirements for a series of site decommissioning activities, including removal of the SCFA. Issuance of an Order of Conditions from the Rowe Conservation Commission is currently expected to occur within the same timeframe as approval of the CAD and BUD.

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4.2 DESIGN AND CONSTRUCTION

4.2.1 Pre-Characterization of SCFA Soils

Sampling of the SCFA landfill soils will be performed, prior to initiation of SCFA excavation activities, in order to pre-characterize the soils for potential reuse on-site under the BUD approval process. As noted in Section 3.4, the recent fill was characterized prior to placement on the SCFA, and therefore will not require any further characterization. It is anticipated that the recent fill will be removed prior to removal of the SCFA. More detail regarding the pre-characterization program is provided in the BUD.

Results from the soil pre-characterization, along with currently available soil stratigraphy data, will be used to further identify and classify the aerial and vertical extent of native-historic fill soils and non-native historic fill materials in order to assist in the removal and proper management of excavated materials.

4.2.2 Protection Of Wetland Resource Areas

As shown on Figure 3, the SCFA is near the confluence of the Wheeler Brook Divertment and a tributary to Wheeler Brook. Grading of the landfill area will be required in the Buffer Zones of these resource areas. There will not be direct impacts to Bordering Vegetated Wetlands (BVW), the water body, or its associated Banks. Performance standards will be adhered to by employing Best Management Practices to minimize runoff into the streams and to prevent or minimize impacts to the Banks of the streams and the associated Bordering Vegetated Wetlands.

Siltation fence will be installed at the base of the landfill construction area, along the Wheeler Brook Divertment and along the tributary to Wheeler Brook, outside of the BVW prior to initiation of any excavation activities. During construction activities, exposed soils, such as stockpiles generated during construction, that are to be left unprotected for several days and subject to potential erosion, will be surrounded by erosion controls to prevent siltation during a storm event. Erosion controls will be left in place until such time as all work is completed, and remaining soils are fully stabilized and vegetated.

4.2.3 Well Closure

Prior to initiating the removal of the SCFA, the monitoring wells located within the SCFA will be closed in accordance with the requirements of

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DEP’s Standard References for Monitoring Wells (WSC-301-91), dated January 1991. At this time, it is anticipated that the following wells will be closed: CB-5, CFW-2, CFW-3, CFW-4, CFW-7, and OSR-1 (see Figure 6). The wells will be closed by removing the standpipe and filling the borehole with grout. To the extent possible, the casing will be removed prior to closing the well. In addition, the soil gas probes will be removed prior to site activities to facilitate the landfill removal activities.

4.2.4 Site Clearing and Access

The work area will encompass approximately two acres, including the SCFA. The proposed work area is shown on Figure 5. Prior to removal of the SCFA materials, existing fence lines that extend into the SCFA area will be relocated. In addition, a portion of the currently wooded area immediately north of the SCFA may be cleared. It is anticipated that less than one acre of land will be cleared to provide required access and staging areas for equipment, as well as excavated and segregated materials. YAEC intends to construct a temporary access roadway from the central portion of the site to the SCFA to facilitate materials movement. The exact alignment of the roadway will be selected based on the status of decommissioning activities and YNPS security requirements. Cleared brush and tree branches will be chipped and stockpiled for later use in the site restoration phase and tree stumps will be handled appropriately. Cut logs will be staged at the edge of the cleared area for later disposition.

4.2.5 Establishment of Staging, Stockpile and Construction Zones

The proposed equipment staging and stockpile locations are shown in Figure 5. These locations are approximate and may be modified based on space constraints, conditions and materials encountered during construction activities, safety concerns or other issues. Erosion controls will be used around material stockpiles, as noted in Section 4.2.2.

Excavated materials may also be stockpiled in other locations on the YNPS site, outside of wetland resource areas, should additional space be required. Additional stockpile areas will be staged, with appropriate erosion controls, to prevent soil pile washouts and erosion.

4.2.6 Excavation and Segregation

The contents of the SCFA will be excavated and segregated to remove non-native materials, such as concrete, metal and asphalt. The depth of excavation in the SCFA is not anticipated to extend further than 30 feet

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below current ground surface (bgs). To complete the work, the contractor will use conventional construction equipment such as long-reach track excavators, 25-ton articulated dump trucks, front-end loaders, and screening equipment, as appropriate.

Existing data regarding the SCFA historic fill materials will be utilized, in conjunction with information obtained during the material pre-removal characterization activities (as outlined in Section 3.3), to identify the aerial and vertical extent of the SCFA materials to be removed. A temporary vertical benchmark will be established by the contractor to track excavation depths, and as a means of establishing proper backfill depths and final grades. Benching may be required to access all of the materials in the SCFA.

A process control flow chart, summarizing soil removal activities, is presented in Figure 7. As soils are excavated from the SCFA, they will be segregated into one of the following types of stockpiles, pending pre-removal characterization, radiological and non-radiological screening during removal, and visual inspection:

• Native soils;

• Native soils mixed with non-native materials passing 6-inch screening process (if any paint or coatings are observed on the non-native material passing the screen, those materials will be segregated for further testing and/or off-site disposal);

• Non-native materials retained on 6-inch screen; and

• Boulders and large cobbles.

Soils being removed from the SCFA will have been pre-characterized (see Section 3.3). Materials will be visually inspected for the presence of non-native materials as they are excavated and before being loaded into dump trucks. The soils will be field screened with an FID or PID for VOCs during excavation and segregation. In addition, the soils will be screened for radiological constituents with field instrumentation.

If C&D debris is visible or suspected, the soils will be moved to a screening area for processing. These materials will be screened, as needed, to less than six inches. Boulders and large cobbles will be removed prior to screening. Materials passing the six-inch screen, such as soil mixed with small pieces of concrete and metal, will be staged in a segregated area for on-site reuse. Screening for non-radiological and

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radiological constituents will also be performed on the materials passing the screen, as described above. If any materials are suspected of being inconsistent with the pre-removal characterization data, they will be segregated and evaluated further to determine if they are suitable for reuse under the BUD. Non-native materials greater than six inches will be be separately staged for off-site disposal.

Contingency plans for addressing hazardous materials encountered during excavation activities are presented in Section 4.3.4.

4.2.7 Disposition of Excavated Materials

Soils and non-native materials from the SCFA that pass the six-inch screen will be used on-site as backfill material and for final site grading, pending approval of the BUD permit application by DEP. Non-native materials not passing the screening process, or not able to be reused on-site under the BUD, will be transported to an appropriate off-site disposal or recycling facility.

4.2.8 Backfill and Site Grading

It is anticipated that the native materials removed from the SCFA landfill area, as well as non-native materials passing the six-inch screen, will be utilized at YNPS for filling voids and for grading the industrial site. The materials will be compacted in one to two foot lifts, using excavation equipment to achieve compaction. The backfilled area will be roughly graded to stabilize working slopes in preparation for final grading. Once final grading is completed, exposed soils will be stabilized using mulch and seed mix.

4.2.9 SCFA Restoration and Planting

The conceptual final grading plan for the SCFA is shown in Figure 8. To complete the regrading of the SCFA, topsoil will be spread over the disturbed area to an average depth of 6 inches to establish a medium for vegetation growth. Native soils from the SCFA fill will be inspected and characterized for possible use as topsoil. Augmentation of native soils will be used, where needed, to provide the necessary medium for vegetation growth. In the event that sufficient quantities of topsoil are not available at the site, other sources of topsoil will be identified and utilized.

Once the final grade is achieved, slopes steeper than 4:1, as well as areas that slope in one direction for long distances, will be stabilized using staked/stapled erosion control blankets made of biodegradable material,

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immediately following seeding. Blankets will not be removed, but will be allowed to degrade in place, typically within three years.

Short-term revegetation (e.g., to stabilize stockpiles that are left in place for an extended period of time) will utilize seed mix appropriate for the conditions and time of year (e.g., winter rye for late-year stabilization or conservation seed mix for spring/summer seeding). The landfill area will be regraded to create more natural contours and seeded with native upland vegetation. The area will be allowed to naturally revegetate and will not be mowed.

4.3 IMPLEMENATION PARAMETERS

4.3.1 Health and Safety Plan

The site-specific Health and Safety plan was prepared as required by DEP’s CAAA approval letter and YAEC’s Job Hazard Assessment Program. A copy of the plan is included in Appendix B.

4.3.2 Access and Security

Site access into the SCFA landfill area will be gained from a temporary access roadway located north of the ISFSI area and/or the existing access road by the ISFSI area. Site security provides 24 hours per day, 7 days per week security coverage of the SCFA. Access into and out of the SCFA construction area will be coordinated with security requirements for the YNPS site.

Construction crews will require General Employee Training and MUST adhere to YNPS security and safety requirements.

4.3.3 Dust Control

A water tanker, or other suitable provisions, that can be used to control fugitive dust conditions that may arise from excavation, processing, or backfill operations, will be maintained at the site. Use of water to control dust will be utilized as needed to maintain a safe work environment and to prevent dispersion of the SCFA material outside of the work area.

4.3.4 Hazardous Waste Contingency Plan

Contractors performing the closure activities for the SCFA will be required to have the Occupational Safety and Health Administration

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(OSHA) training for work at hazardous waste sites. SCFA closure activities will also be performed under the oversight of ERM personnel to ensure compliance with MCP requirements, including the handling and management of any oil and hazardous material that may be encountered.

In the event that hazardous or suspicious waste is encountered during SCFA closure activities (i.e. drum, container, or area of unknown, hazardous, or radiological material), SCFA excavation activities will be halted until the condition is adequately secured or resolved. Material already excavated that was immediately adjacent to the unknown waste will be separately placed on poly-sheeting and secured.

YNPS personnel will be immediately notified that an unknown and potentially hazardous material has been encountered. YNPS or designated personnel will determine if the encountered material(s) are hazardous under local, state, or federal regulations. In the event that the materials are deemed to be hazardous, notifications will be made to local, state, and federal regulatory agencies as appropriate.

The contractor performing the SCFA removal will be capable of assisting YNPS in responding to the potentially hazardous condition. Emergency response equipment, including but not limited to over-pack and standard 55-gallon drums, spill booms, and absorbents, will be available on-site for use. Additional personnel will be brought in, as needed, to address the situation and prepare the materials for eventual shipment to a licensed treatment, storage and disposal (TSD) facility.

4.3.5 Spill Control and Response

YNPS maintains site procedures to identify potential hazards and to provide response actions as needed. Leaking equipment will not be allowed on-site, and must be repaired before use. All hazardous liquids or materials brought on site require prior approval from YNPS personnel. All equipment/vehicle fluids used on-site will be stored in proper containers and with adequate secondary containment.

In the event of a spill or threat of spill, YNPS procedures provide for immediate notification of the YNPS Control Room for coordination of all response actions. A determination is then made with onsite personnel as to whether additional resources or notifications are required to local, state and/or federal agencies. Impacted materials will be placed in approved containers for proper off-site disposal by a licensed TSD facility.

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4.4 ENVIRONMENTAL MONITORING

Following the removal of the landfill, YAEC will conduct monitoring of groundwater and surface water quality in the vicinity of the SCFA. The proposed monitoring program is described below.

4.4.1 Groundwater Monitoring

At this time, it is anticipated that post-removal monitoring will be conducted annually, for five years. Landfill removal activities are not expected to impact the following three wells: CFW-1, CFW-5, and CFW-6. Therefore, these three wells will be incorporated into the post-closure monitoring program. Monitoring well locations are shown in Figure 3.

The monitoring wells will be gauged prior to sampling. Water level measurements will be made using an electronic water level probe marked in 0.01-foot intervals. Groundwater samples will be collected utilizing low-flow sampling techniques. Conductivity, dissolved oxygen, oxidation-reduction potential, temperature and pH measurements will be recorded in the field during well stabilization. Water level measurements will be collected every five minutes. If water level drawdown is observed, the pumping rate will be reduced.

In accordance with 310 CMR 19.132, groundwater samples will be submitted for laboratory analysis of the following parameters:

• Total Metals: arsenic, barium, cadmium, chromium, copper, iron, lead, manganese, mercury, selenium, silver, and zinc

• Total Cyanide

• Chloride

• Sulfate

• Nitrate - Nitrogen

• Total Dissolved Solids

• Total Alkalinity

• Chemical Oxygen Demand

• VOCs by EPA Method 8260

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4.4.2 Surface Water Monitoring

Surface water samples will be collected at five locations along the tributary to Wheeler Brook and the Wheeler Brook Divertment, consistent with historic SCFA sampling activities. Surface water samples will be collected directly into the sample container by lowering the sample container into the stream without disturbing the stream bottom to minimize turbidity. In accordance with 310 CMR 19.132, surface water samples will be submitted for laboratory analysis for the same parameters as those submitted for groundwater. The frequency and length of post-closure monitoring of surface water will be consistent with requirements for groundwater monitoring, as previously noted.

4.5 COMPLETION REPORT

YAEC will prepare and submit a Closure Certification Report to DEP within 90 days following completion of the SCFA removal activities.

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5.0 IMPLEMENTATION SCHEDULE

It is currently anticipated that the removal of the C&D waste and SCFA closure activities will occur in Fall 2004 or early 2005, pending DEP approval of the SCFA CAD, associated BUD permit application and the schedule for decommissioning activities. The implementation schedule is included as Figure 9.

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6.0 REFERENCES

ERM, 2000, Initial Site Assessment Report, 10 March 2000.

ERM, 2001, Comprehensive Site Assessment Report, 14 September 2001.

ERM, 2003a, 2003 Annual Landfill Monitoring Letter Report, 15 October 2003.

ERM, 2003b, Corrective Action Alternative Analysis (CAAA), 18 December 2003.

ERM, 2004, Notice of Intent, Submitted to the Rowe Conservation Commission, 7 May 2004.

MA DEP, 1997, Landfill Technical Guidance Manual, May 1997.

MA DEP, 2000, Approval of ISFSI Soil Placement onto SCFA, Letter to Yankee, 13 July 2000.

MA DEP, 2002, Wetlands Protection Act Regulations, 310 CMR 10.00, 20 December 2002.

MA DEP, 2004a, Draft Interim Guidance Document for Beneficial Use Determination (BUD) Regulations, 310 CMR 19.060, 18 March 2004.

MA DEP, 2004b, Approval of CAAA, Letter to Yankee, 13 April 2004.

MA DEP, 2004c, Solid Waste Management Facility Regulations, 310 CMR 19.000, May 2004.

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Figures

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SITE

Reference: Topo! Interactive Maps. 1999, Wildflower Production, San Francisco, CA.

0 1,000 ft0.5 mi

0 500 m0.5 km

Scale 1:25,000

Figure 1 - Site LocationYankee Nuclear Power Station - Rowe, MA

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Excavation Area Pre-Characterized?

ConductCharacterization

ActivitiesNO

Excavate Soils

ISFSI Soils? NO

YES

Stockpile forUnrestricted Reuse

Perform Radiological+ Non-RadiologicalMonitoring During

Excavation

Visible Signs of C+DMaterial?

YES

Segregate forScreening

Stockpile Boulders forOn-Site Reuse

Pass 6" Screen? NO

YES

Stockpile for Off-SiteDisposal or Recycling

Suitable for Reuseunder BUD Approval?

YES

YES

Stockpile for On-SiteReuse under BUD

Stockpile for Off-SiteDisposal

NO

NO

Figure 7 - SCFA Removal Process Flow ChartYankee Nuclear Power Station - Rowe, MA

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Appendix A Transmittal and Application Forms

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Appendix B Health & Safety Plan

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Yankee Nuclear Power Station

Health and Safety Plan – Southeast Contruction Fill Area Removal 49 Yankee Road Rowe, Massachusetts

14 July 2004

0015181

DRAFT

Environmental Resources Management 399 Boylston Street, 6th Floor Boston, Massachusetts 02116

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ERM YANKEE ROWE-0015181-7/27/2004 i

1.0 INTRODUCTION 1

1.1 OVERVIEW 1

1.2 PURPOSE AND SCOPE 1

1.3 PROJECT HISTORY 2

1.4 DESCRIPTION OF SITE-SPECIFIC HEALTH AND SAFETY PLAN 2

2.0 ORGANIZATIONAL STRUCTURE 4

2.1 IDENTIFICATION OF RESPONSIBILITIES 4 2.1.1 Project Manager 4 2.1.2 Site Health and Safety Officer (SHSO) 5 2.1.3 Project Team/Field Activities Team 5

2.2 DISCIPLINARY POLICY 6

2.3 FIREARMS AND WEAPONS POLICY 6

2.4 DRUG AND ALCOHOL POLICY 6

3.0 HEALTH AND SAFETY TRAINING PROGRAM 7

3.1 HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE (HAZWOPER) TRAINING 7

3.2 SPECIALIZED TRAINING 7

3.3 CONTRACTOR RESPONSIBILITIES 7

3.4 MEDICAL SURVEILLANCE 8

3.5 SITE HEALTH AND SAFETY BRIEFING 8

4.0 HAZARD COMMUNICATION PROGRAM 9

4.1 PURPOSE 9

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4.2 PROGRAM REQUIREMENTS 9

4.2 JOB HAZARD ANALYSIS 9

5.0 EMERGENCY RESPONSE 10

5.1 EMERGENCY NOTIFICATION AND CONTACTS 10

5.2 EMERGENCY EVACUATION FROM IMPACTED AREAS 10

5.3 EVACUATION ROUTES 11

5.4 EVACUATION ASSEMBLY POINT 11

5.5 DIRECTIONS TO THE HOSPITAL 11

5.6 FIRES 12

5.7 MEDICAL EMERGENCIES/FIRST AID 12

5.8 NATURAL DISASTERS AND SEVERE WEATHER 13

5.9 INCIDENT REPORTING PROCEDURE 14

5.10 RESPONSIBILITIES 15

6.0 MONITORING 16

6.1 GENERAL 16

6.2 DUST MONITORING 16

6.3 NOISE MONITORING 17

6.4 HEAT STRESS 17

6.5 COLD EXPOSURE 18

7.0 SELECTION OF PPE AND SAFETY EQUIPMENT 20

7.1 SUMMARY OF PERSONAL PROTECTIVE EQUIPMENT 20

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7.2 PPE ACTION LEVELS 21

7.3 EQUIPMENT DECONTAMINATION 21

7.4 PPE DECONTAMINATION 22

8.0 SITE ACCESS AND CONTROL 24

8.1 OVERVIEW 24

8.2 SITE ACCESS 24

8.3 SITE CONTROL 25

9.0 POTENTIAL HEALTH AND SAFETY RISKS 26

9.1 OVERVIEW 26

9.2 GENERAL WORK HAZARDS 26

9.3 CHEMICAL HAZARDS 27

9.4 PHYSICAL HAZARDS 28 9.4.1 Heavy Equipment 30 9.4.2 Excavations / Test Pits 30 9.4.3 Logging Hazards 31 9.4.4 Fire/ /Explosion/ Electrical Hazards 31

9.5 BIOLOGICAL HAZARDS 32 9.5.1 Insects 32 9.5.2 Lyme Disease 32 9.5.3 Poisonous Plants 33

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FIGURES

FIGURE 1 LOCUS MAP

FIGURE 2 PLANT LAYOUT

FIGURE 3 EXCAVATION ROUTES

FIGURE 4 MAP TO HOSPITAL

APPENDICES

APPENDIX A HEALTH AND SAFETY PLAN SIGNATURE SHEET

APPENDIX B DAILY SAFETY MEETING FORM

APPENDIX C MATERIAL SAFETY DATA SHEETS

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LIST OF ACRONYMS ANSI American National Standards Institute BZTOV breathing zone total organic vapor C & D Construction & Demolition CFR Code of Federal Regulations CMR Code of Massachusetts Regulations CRZ contamination reduction zone dB(A) decibels on the A-weighted scale DEP Department of Environmental Protection ERM Environmental Resources Management EZ exclusion zone FID flame ionization detector HASP Health and Safety Plan HAZWOPER Hazardous Waste Operations and Emergency

Response HEPA high efficiency particulate air IDLH immediately dangerous to life and health l liter LEL lower explosive limit m3 cubic meter mg milligrams MSDS material safety data sheet OHM oil and/or hazardous material OSHA Occupational Safety and Health Administration PCB polychlorinated biphenyls PID photoionization detector PPE personal protective equipment ppm part per million SCBA self contained breathing apparatus SCFA Southeast Construction Fill Area SHSO Site Health and Safety Officer SVE soil vapor extraction SZ support zone TLV threshold limiting value TWA time weighted average UTM Universal Transverse Mercator VP vapor pressure YAEC Yankee Atomic Energy Commission YNPS Yankee Nuclear Power Station

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1.0 INTRODUCTION

1.1 OVERVIEW

This Health and Safety Plan (HASP) has been developed to establish the procedures necessary for protecting personnel from potential hazards resulting from Phase IV remedial activities at the Yankee Nuclear Power Station (YNPS). The property is located at 49 Yankee Road in the northwestern Massachusetts Town of Rowe, adjacent to the Vermont border (Figures 1 and 2). The property consists of an approximately 1,800-acre property owned by Yankee Atomic Energy Company (YAEC) (Figure 1) and portions of an adjacent property to the west owned by USGen New England, Inc. (USGen NE). The property abuts the eastern shore of the Deerfield River and Sherman Reservoir and is adjacent to Sherman Dam, one of several dams along the Deerfield River used for hydroelectric power generation.

1.2 PURPOSE AND SCOPE

Environmental Resources Management (ERM) developed this site-specific HASP for use by ERM personnel in connection with closure activities at the Southeast Construction Fill Area (SCFA) being performed by ERM for YAEC at the YNPS property. ERM personnel must adhere to the practices and procedures specified in the HASP. This HASP has been developed in fulfillment of the requirements of the Massachusetts Contingency Plan (310 Code of Massachusetts Regulations (CMR)) 40.0874. No third party shall rely on the HASP. Each third party should abide by its own site specific health and safety plan in accordance with its own professional judgment and established practices.

The procedures set forth in this plan are designed to avoid adverse exposure to chemical substances that may be present in the soil, water, sediment and air and to other physical and biological hazards associated with closure of the SCFA to be completed under Phase IV.

The procedures set forth in this HASP are in accordance with the provisions of 29 Code of Federal Regulations (CFR) Parts 1910.120 and 1926.65, Hazardous Waste Operations and Emergency Response (HAZWOPER), in addition to ERM’s experience in similar remedial operations. The procedures in this plan have been developed for use by

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ERM personnel engaged in remedial construction, implementation, investigation and monitoring.

The procedures and levels of personal protection specified in this plan are based on the best available information from reference documents and current site data. Therefore, these recommendations represent the minimum health and safety requirements to be observed by personnel engaged in this project. Unforeseeable site conditions may warrant reassessment of personal protection levels and the controls stated. Adjustments to the HASP must have prior approval by the Project Manager and the Site Health and Safety Officer (SHSO).

1.3 PROJECT HISTORY

The SCFA is located on a portion of the YNPS facility at 49 Yankee Road, Rowe, Massachusetts. The YNPS is situated on a 2,200-acre parcel that has been owned by the Yankee Atomic Electric Company (YAEC) since plant construction in the late 1950s. The entire YAEC property is zoned industrial. YAEC owns all property within a 500-foot radius of the SCFA footprint. The YNPS, which ceased operation in February 1992, is the only industrial complex within 500 feet of the SCFA footprint. All other areas within 500 feet of the SCFA are forested and undeveloped.

The SCFA consists of 1.2 acres of native fill and Construction & Demolition (C&D) fill material (i.e., concrete, asphalt, wood and metal debris) averaging 15 feet in thickness. The SCFA is part of the YNPS facility.

The parcel of land is identified by the Town of Rowe assessor’s office as parcel 1035/416, YAEC Tax Map 12.

1.4 DESCRIPTION OF SITE-SPECIFIC HEALTH AND SAFETY PLAN

The proposed activity in the SCFA is to close the C&D landfill by excavating the native and non-native fill material, disposing of the C&D waste off-site, and reusing the native materials on-site for grading purposes. The purpose of the landfill removal is to reduce the potential for long-term aesthetic impacts to the environment associated with potential leachate discharge from the non-native material in the landfill and to satisfy the requirements of the Massachusetts Solid Waste Regulations (310 CMR 19.00).

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The contents of the SCFA will be excavated and segregated/screened to remove non-native materials, such as concrete and asphalt. The non-native waste will be transported to an appropriate disposal or recycling facility. The native soil and rocks will be re-used on-site for grading purposes or transported off-site for reuse or disposal. The area will be restored following the completion of the grading activities.

This HASP is intended to support the following activities that are planned for implementation at the site:

• pre-excavation soil characterization

• installation of erosion controls

• clearing of wooded area and brush removal

• excavation of SCFA material

• loading, transport, and staging of excavated material

• screening/segregation of excavated materials

• crushing of concrete and asphalt (if necessary)

• backfill and compaction

• site restoration

This site-specific HASP includes information regarding the following:

• personnel organizational structure;

• health and safety training;

• hazard communication program;

• emergency response;

• monitoring;

• selection of personal protective equipment (PPE) and safety equipment;

• site access and control; and

• potential health and safety risks.

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2.0 ORGANIZATIONAL STRUCTURE

2.1 IDENTIFICATION OF RESPONSIBILITIES

The organization and responsibilities for implementing safe project activities, and more specifically the requirements contained in this HASP, are discussed in this section. The key ERM health and safety personnel for this project are:

• ERM Project Manager;

• ERM Site Health and Safety Officer (SHSO); and

• ERM Field Personnel.

Contractors to be used for this project for intrusive tasks such as drilling , excavation hauling excavated material, will be required to be certified in accordance with OSHA guidelines, 29 CFR 1910.120, applicable to work involving the potential for exposure to OHM. In addition, contractors to be used for this project for non-intrusive tasks such as surveying and site restoration, will be required to also be certified in accordance with OSHA guidelines, 29 CFR 1910.120, applicable to work not involving the potential for exposure to OHM. Each ERM Contractor must review the HASP and agree to abide by the HASP.

2.1.1 Project Manager

The ERM Project Manager is, by designation, the individual who has the primary responsibility for ensuring the overall safety and health of ERM personnel on this project and ensuring that ERM personnel and subcontractors comply with the requirements of this HASP. The Project Manager’s specific responsibilities include:

• ensuring that project personnel, including ERM staff and subcontractors, have received a copy of, have read, and have signed the HASP signature sheet (Appendix A);

• ensuring the attendance of ERM personnel and subcontractors at a tailgate briefing apprising them of the contents of this HASP and specific hazards identified to be present at the facility prior to performing work;

• ensuring that sufficient PPE, as required by this HASP, is available during the project;

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• obtaining subcontractor documentation of employee OSHA training prior to work commencement;

• maintaining a high level of health and safety consciousness among project personnel at the site; and

• coordinating compliance by ERM personnel and subcontractors with the HASP.

2.1.2 Site Health and Safety Officer (SHSO)

The SHSO will conduct periodic inspections of the remediation areas and activities to ensure compliance with, and the effectiveness of, the HASP. By design, the SHSO has the authority to immediately correct any situations where non-compliance with this HASP is noted or possible, and to immediately stop work in cases where an immediate danger is perceived. SHSO responsibilities include:

• procuring and distributing the PPE and air monitoring instrumentation needed for the project;

• verifying that PPE and health and safety equipment is in good working order;

• setting up and maintaining the personnel decontamination area;

• controlling remedial site entry for unauthorized personnel;

• supervising and monitoring the safety performance of ERM personnel and subcontractors to ensure that required safety and health procedures are followed and correcting any deficiencies;

• establishing and executing decontamination procedures;

• verifying communication systems are in place;

• initiating emergency response procedures; and

• conducting accident/incident investigations and preparing investigation reports.

2.1.3 Project Team/Field Activities Team

ERM field personnel and subcontractors are responsible for following the health and safety procedures specified in this HASP and for performing their work in a safe and responsible manner. Specific requirements include:

• obtaining a copy of this HASP and reading it, in its entirety, prior to the start of field activities;

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• signing the Health and Safety Signature Sheet (Appendix A) acknowl-edging receipt and understanding of this HASP;

• bringing forth any questions or concerns regarding the content of the HASP to the SHSO or Project Manager, prior to the start of work;

• reporting accidents/incidents and the presence of potentially hazardous working situations to the SHSO and Project Manager; and

• complying with the requests of the appointed SHSO.

2.2 DISCIPLINARY POLICY

It is the responsibility of all remedial site personnel to adhere to established safe work practices, procedures and safety policies. Site workers can be reprimanded and/or removed from the site for numerous reasons including, but not limited to the following:

• not wearing appropriate PPE;

• not following established safe work practices and/or procedures;

• committing an unsafe act resulting in destruction of property; or

• failing to immediately report a work related accident/incident.

2.3 FIREARMS AND WEAPONS POLICY

The possession, of any firearm or weapon including, but not limited to, handguns, rifles, shotguns, pellet guns, martial arts equipment, cross-bows and any other device manufactured for the purpose of causing injury on the YNPS site is prohibited.

2.4 DRUG AND ALCOHOL POLICY

ERM employees and remedial site workers will not be in possession of, or under the influence of, alcohol, illegal drugs or other illegal materials. All workers are subject to YAEC’s Fitness for Duty Policy (drug and alcohol screening).

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3.0 HEALTH AND SAFETY TRAINING PROGRAM

3.1 HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE (HAZWOPER) TRAINING

ERM personnel and all contractors working in areas with the potential for exposure to OHM will have successfully completed 40-hour HAZWOPER training and a minimum of 24 hours of field training under the direct supervision of a trained, experienced supervisor. ERM personnel and subcontractors will also attend an 8-hour HAZWOPER refresher course annually. Remedial site workers will be required to show proof of current training (less than one year since initial or refresher training) prior to field activities. Intended workers without current training documentation will be barred from remedial site activities or escorted by trained personnel.

3.2 SPECIALIZED TRAINING

All site workers associated with remedial activities must receive site-specific training (General Employee Training) for unescorted access. This training may include radiological worker training as needed. Visitors will not require this training but may be escorted during site visits. Additional task specific training will be provided to effectively and safely conduct each site task and adhere to the requirements of this HASP. Some of these topics, all of which are discussed in further detail in later sections of this HASP, include:

• site-specific emergency response;

• PPE selection and use;

• excavation and removal of construction debris;

• waste handling activities; and

• collection of soil samples.

3.3 CONTRACTOR RESPONSIBILITIES

All remedial contractors must be notified of the site-specific health and safety requirements and must acknowledge that they are familiar with and will abide by all health and safety rules before initiating site work.

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Contractors must provide certification of training requirements per the above sections.

This site-specific HASP will be distributed to all remedial contractors prior to the start of field activities. A pre-operation meeting will be held to discuss the contents of the HASP. Specialty training will be provided, as needed, based on task and responsibility. Task and any specific personnel training will be conducted under direct supervision of the SHSO or designee.

3.4 MEDICAL SURVEILLANCE

Although chemical contaminants are not anticipated for the SCFA closure work, if the pre-excavation soil characterization indicates contaminants are present, then ERM personnel actively involved in field activities associated with this project are required to be active participants in the medical monitoring program. This examination must include pulmonary function testing, as well as certification by the physician of the employee's ability to wear a negative-pressure respirator and perform strenuous work. If a person sustains an injury or contracts an illness related to work on site that results in lost work time, he/she must obtain written approval from a physician to regain access to the site.

3.5 SITE HEALTH AND SAFETY BRIEFING

Before the initiation of site activities, the SHSO, or designee, will conduct a daily safety meeting prior the start of work to review the day’s work plan, associated activities, and any anticipated hazards. A daily safety meeting form is provided in Appendix B. ERM personnel and remedial contractors authorized to enter the site are required to participate in this briefing. Additional safety meetings may occur at the start of a new task or phase of work. Visitors to the remedial areas will be escorted by appropriate personnel.

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4.0 HAZARD COMMUNICATION PROGRAM

4.1 PURPOSE

The Hazard Communication Program is designed to ensure that information necessary for the safe use, handling and storage of hazardous chemicals is provided and made available to site personnel.

4.2 PROGRAM REQUIREMENTS

The following summarizes the requirements of the hazard communication program:

• containers of chemicals used, handled, or stored in the field will minimally provide the identity of the hazardous chemical, appropriate hazard warnings which provide at least general information regarding the hazards, and manufacturer or supplier of the chemical;

• Material Safety Data Sheets (MSDSs) for all chemicals used or stored on-site will be posted; and

• MSDSs for all chemicals that are site constituents (i.e., are being remediated).

This information will be provided to ERM personnel and contractors. Remedial site personnel will be made aware of the location and dangers of chemicals that may be used or found on-site.

4.2 JOB HAZARD ANALYSIS

Prior to initiation of SCFA closure activities, ERM and YAEC will prepare a Job Hazard Analysis (JHA) for the planned activities, in accordance with plant procedures. A JHA is a procedure which helps integrate accepted safety and health principles and practices into a particular operation. In a JHA, each basic step of the job will be examined to identify potential hazards and to determine the safest way to do the job. Four basic stages in conducting a JHA will be: • selecting the job to be analyzed; • breaking the job down into a sequence of steps; • identifying potential hazards; and • determining preventive measures to overcome identified hazards.

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5.0 EMERGENCY RESPONSE

5.1 EMERGENCY NOTIFICATION AND CONTACTS

The SHSO will ensure that methods to communicate with local fire, police, ambulance services, hospital facilities and poison control centers are known by personnel.

In the event of an emergency, site personnel will contact the Control Room via telephone or radio. State the nature of the emergency and the Control Room will initiate emergency response by contacting the appropriate agency. This emergency contact summary table will be maintained at the remedial work site by the SHSO or designee, in a readily accessible location for use in case of an emergency. Company Name Project Title

/Assigned Role Phone Numbers

Yankee Nuclear Power Station

Ken Dow Environmental Site Supervisor

413-424-2245

Yankee Nuclear Power Station

YAEC Control Room Shift Supervisor

413-424-2336 x2335 or x2337

ERM John McTigue Licensed Site Professional

617-646-7842 617-285-6042 cell

ERM Gregg Demers Project Manager 617-646-7858 617-721-4847 cell Woodlot Alternatives

Michael Thompson

Wetlands Specialist

General Contractor

To be named

Franklin Medical Center - Emergency

Nearest Medical Facility

(413) 773-2263

Emergency 911

5.2 EMERGENCY EVACUATION FROM IMPACTED AREAS

Personnel will not enter an area to attempt a rescue if their own lives would be threatened. The SHSO will be responsible for evacuating any person and providing decontamination, and arranging for medical treatment or first aid for any injured person. Evacuation will occur

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immediately in the event of PPE failure. Site personnel will assist as directed by the SHSO in case of an emergency.

5.3 EVACUATION ROUTES

Personnel will use the evacuation routes shown on Figure 3 to convene at the evacuation assembly point described below unless they cannot because of physical injury, or if transport to the hospital is immediately required.

5.4 EVACUATION ASSEMBLY POINT

The primary evacuation assembly point is the parking area located southwest of the plant Gatehouse, shown on Figure 3. The SHSO or designee is responsible for post-evacuation personnel accounting at the evacuation point. Emergency responders will be notified of people believed to be missing and their approximate location in the workplace. Personnel are not considered missing until it can be verified that the person actually reported to work that day and was at the facility at the time of the emergency.

5.5 DIRECTIONS TO THE HOSPITAL

In the event of a serious injury to site personnel, an ambulance or helicopter shall be used for transportation to the nearest hospital. Due to the long distance from the site to the nearest hospital, evacuation by air may be required.

In the event of minor injuries or illness, the SHSO or designee may elect to have the injured transported to the nearest hospital by company vehicle. If there is any doubt about the severity of the injury, an ambulance shall be used. The location of the nearest medical facility is included as Figure 4. The nearest facility is the Franklin Medical Center, Greenfield, Massachusetts. The directions to this facility are provided with Figure 4.

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5.6 FIRES

Fire extinguishers will be located in temporary work trailers and will be available in company vehicles. Employees shall not attempt to extinguish large fires. Instead, they will proceed to emergency evacuation points and contact emergency personnel. Potential ignition sources are summarized in the following table.

5.7 MEDICAL EMERGENCIES/FIRST AID

In the event of a safety or health emergency at the site, appropriate emergency measures will immediately be taken to assist those who have been injured or exposed and to protect others from hazards. The SHSO or designee will be immediately notified and will respond according to the seriousness of the injury. Personnel trained in First Aid will be present during remedial site activities to provide administrative first aid as appropriate for injuries or illness incurred during operations. ERM personnel may use two-way radios to facilitate on-site communication where necessary.

For minor injuries, first-aid equipment will be provided in ERM vehicles and inside the site trailer. At a minimum, first aid equipment will include the following items:

• first aid kit with adhesive bandages, sterile gauze, adhesive tape, first aid cream and antiseptic wipes;

• sterile eye wash;

• insect repellent;

• cold pack; and

Potential Ignition Source Control Electrical fires Do not open electrical equipment panels; use

Class “C” fire extinguishers.

Methanol (sample equipment decontamination)

Put only what will be used in a day in a temporary storage container; use flammables cabinet for larger volumes.

Accumulation of combustible materials

Maintain good housekeeping using site dumpster; use Class “A” and “B” fire extinguishers

Cigarette smoking Not allowed except in designated areas outdoors.

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• ointment for insect bites.

For serious injuries, personnel will ensure the victim cannot be further injured, assess whether the victim is responsive, and contact emergency personnel if necessary.

5.8 NATURAL DISASTERS AND SEVERE WEATHER

It is possible that hurricanes, flooding and severe weather could occur at the site. In the event of a sudden severe weather event (i.e. thunder storms), stop all work and seek the nearest safe shelter (automobile, building, etc.). The following guidelines provided by the National Oceanic and Atmospheric Association (NOAA; http://www.lightningsafety.noaa.gov/) should be followed to provide the greatest protection against the hazards posed by electrical storms. Level-1: Obtain the weather forecast before planning outdoor activities. Schedule outdoor activities around the weather to avoid exposure to the lightning hazard. Know your local weather patterns.

Level-2: If you are planning to be outdoors, identify and stay within traveling range of a proper shelter. Employ the "30-30 Rule" to know when to seek a safer location. The "30-30 Rule" states that when you see lightning, count the time until you hear thunder. If this time is 30 seconds or less, go immediately to a safer place. If you can't see the lightning, just hearing the thunder means lightning is likely within striking range. After the storm has apparently dissipated or moved on, wait 30 minutes or more after hearing the last thunder before leaving the safer location.

The "30-30 Rule" is best suited for existing thunderstorms moving into the area. However, it cannot protect against the first lightning strike. Be alert to changes in sky conditions portending thunderstorm development directly overhead. Larger outdoor activities, with longer evacuation times, may require a longer lead-time than implied by the "30-30 Rule."

Level-3: When lightning threatens, go to a safer location. Do not hesitate. The safest place available during a lightning storm is a large, fully enclosed, substantially constructed building. Substantial construction also implies the building has wiring and plumbing, which can conduct lightning current safely to ground. However, any metal conductor exposed to the outside must not be touched precisely because it could become a lightning conduit. Once inside, stay away from corded telephones, electrical appliances, lighting fixtures, electric sockets and plumbing. Don't watch lightning from open windows or doorways. Inner rooms are generally preferable from a safety viewpoint.

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If you can't reach a substantial building, an enclosed vehicle with a solid metal roof and metal sides is a reasonable second choice. As with a building, avoid contact with conducting paths going outside. Close the windows, lean away from the door, put your hands in your lap and don't touch the steering wheel, ignition, gear shifter or radio. Convertibles, cars with fiberglass or plastic shells, and open-framed vehicles are not suitable lightning shelters.

Level-4: If you cannot flee to a safer location, take action to minimize the threat of being struck. Proceed from higher to lower elevations. Avoid wide-open areas. Avoid tall, isolated objects like trees, poles, cranes and light posts. Avoid water-related activities such as turbidity monitoring from a boat. Do not remain in open vehicles (i.e., cabless construction machinery). Avoid contact with metal fences or other long metal structures. And the cardinal rule remains: Do not take shelter under trees to keep dry during thunderstorms.

Level-5: If lightning is about to strike, it will sometimes provide a very few seconds of warning. Sometimes your hair may stand on end, your skin will tingle, light metal objects will vibrate or you will hear a crackling or "kee-kee" sound. If this happens and you're in a group, spread out so there are several body lengths between each person. Once you've spread out, use the lightning crouch: put your feet together, squat down, tuck your head, and cover your ears. When the immediate threat of lightning has passed, continue heading to the safest place possible.

Level-6: If someone is struck by lightning, first, contact the Control Room immediately. Since all deaths from lightning strikes result from cardiac arrest and/or stopped breathing, begin treatment as soon as possible. CPR or mouth-to-mouth-resuscitation is the recommended first aid, respectively. If the storm's lightning is ongoing and represents a continuing risk to responders, consider moving the victim to a safer location.

5.9 INCIDENT REPORTING PROCEDURE

Adherence to this HASP and any additional facility safety rules and regulations will significantly reduce the likelihood of personnel being exposed to toxic substances above permissible exposure limits and to physical hazards. However, in the event an incident does occur, it is imperative that specific reporting procedures be followed so that the SHSO and the Project Manager can take appropriate corrective action. Upon notification of an incident, the SHSO will contact the appropriate technical personnel for recommended medical diagnosis and, if necessary,

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treatment. The YNPS Environmental Supervisor (or designee) must also be contacted. The Project Manager and the SHSO will investigate facility/site conditions to determine: (1) the severity of the incident, (2) the cause of the incident and (3) the means to prevent the incident from recurring. The incident will be documented in a memorandum to the file.

5.10 RESPONSIBILITIES

The SHSO or designee will be responsible for responding to emergencies. The SHSO or designee will:

• notify appropriate individuals, authorities and/or health care facilities of the activities and hazards of the investigation;

• ensure that the following safety equipment is available at the remedial site: eyewash station, first aid supplies, and fire extinguishers;

• have working knowledge of all safety equipment available at the remedial site; and

• ensure that a map that details the most direct route to the nearest hospital is prominently posted with the emergency telephone numbers.

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6.0 MONITORING

6.1 GENERAL

When a significant change occurs in conditions or work activities at the remedial site, previously identified hazards should be reassessed. Additional safety meetings may be required so that personnel understand a new monitoring regimen. Some indicators for the need for hazard reassessment include the following:

• commencement of a new work phase;

• emergence of new unforeseen hazards;

• change in job tasks during a work phase;

• change of season;

• change in weather; and

• change in ambient levels of contaminants.

Instrumentation used will be calibrated in accordance with manufacturer's procedures. ERM will calibrate monitoring equipment, which is described in the following sections, at the beginning of each work day in accordance with the procedures and frequency provided by the equipment manufacturers. Calibration results and instrument readings will be recorded on daily field logs.

6.2 DUST MONITORING

In the unlikely event that chemical contamination is found during the pre-excavation soil characterization, site conditions may warrant the use of a real-time airborne particulate meter. If airborne concentrations of particulate exceed 0.01 mg/m3 the level of protection may be increased or engineering controls may be implemented. A full-face air-purifying respirator equipped with organic vapor/ high efficiency particulate air (HEPA) filters may be required under observed dusty conditions or activities. The SHSO or designee will determine the need to employ direct reading instrumentation for airborne particulate monitoring.

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6.3 NOISE MONITORING

A sound level meter will be used to determine the noise level when employees could potentially be exposed to noise, such as around heavy equipment. Site personnel will be required to wear hearing protection in areas where noise level exceeds 85 decibels on the A-weighted scale [dB(A)].

6.4 HEAT STRESS

Heat stress is the combination of both environmental and physical work factors that contribute to the total heat load imposed on the body. Environmental factors that contribute to heat stress include air temperature, radiant heat exchange, air movement, and humidity.

The body's response to heat stress is reflected in the degree of symptoms. When the stress is excessive for the exposed individual, a feeling of discomfort or distress may result and a heat-related disorder may ensue. The severity of the response will depend not only on the magnitude of the prevailing stress, but also on the age, physical fitness, degree of acclimatization, and dehydration of the worker. A table summarizing heat stress disorders is provided below.

Disorder

Symptoms

Cause

Prevention/First Aid

Heat Rash or Prickly Heat

• Rash, itching • Hot, humid conditions

• Sweat doesn’t evaporate easily

• Sweat ducts become clogged

• Ointments • Keep skin clean and dry • Good daily personal

hygiene

Heat Cramps

• Sudden onset of muscle cramps usually in legs or arms

• Hot, moist skin • Normal pulse • Normal or slightly elevated

temperature

• Loss of water (sweating)

• Loss of electrolytes

• Replacing water but not electrolytes

• Move into shade • Loosen clothing • Drink tepid electrolyte

drinks or water • Seek medical assistance

if conditions persist

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Disorder

Symptoms

Cause

Prevention/First Aid

Heat Exhaustion

• Pale, clammy skin • Profuse perspiration • thirst from dehydration • Weakness • Headache • Nausea • Loss of coordination

• Overexertion • Excessive loss of

water and electrolytes

• Move into shade • Remove PPE • Loosen street clothing • Cool by applying damp

cool compresses or ice • Packs • Drink tepid electrolyte

drinks or water • Summon medical

assistance

Heat Stroke • Elevated temperature (>103F)

• Flushed, hot, dry skin • Absence of sweating • Delirious • Rapid pulse • Nausea • Headache • Dizziness • Unconsciousness

• Failure of body’s cooling (sweating) mechanism

• Summon medical assistance immediately

• Move to shade • Remove PPE • Loosen street clothing • Cool by fanning or

applying damp compresses or ice packs

Heat Stress monitoring may be conducted, and work/rest schedules may be implemented if conditions warrant it.

6.5 COLD EXPOSURE

Personnel working outdoors in low temperatures may be subject to cold exposure. Toes, fingers, ears, cheeks, and the nose are especially vulnerable to cold exposure. Factors influencing the development of a cold injury include ambient temperature, wind velocity, humidity, type of exposure, and duration of exposure. Frostbite and hypothermia are two cold injuries that may occur. A table summarizing these injuries is provided below. Work/rest schedules will be developed in the event conditions warrant it.

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Disorder Symptoms Cause Prevention/First Aid Frostbite • just before frostbite occurs,

the affected skin may be slightly flushed

• the skin changes to white or grayish-white in appearance

• pain is sometimes felt early but subsides later (often there is no pain)

• blisters may appear later • the affected part feels

intensely cold and numb • the victim frequently is not

aware of frostbite

• brief or continued exposure of unprotected skin to cold, windy conditions at or below 10 °F

• cover exposed skin, or limit time exposed to cold, windy conditions

• dress in layers, removing clothing as heat is generated from working

• have spare clothing available to replace wet clothing

• use buddy system

Hypothermia

• shivering • apathy, listlessness,

sleepiness • unconsciousness, glassy

stare, slow pulse, and slow respiratory rate

• freezing of the extremities • death

• depression of core body temperature as a result of exposure to temperatures at or below 40 °F combined with wet, windy, conditions

• improper clothing (i.e., no wind or moisture protection)

• dress in layers, removing clothing as heat is generated from working

• use buddy system • move exposed

individuals to cover. • have spare clothing

available to replace wet clothing

• keep victim as warm as possible, remove wet clothing and replace with dry clothing/covering if possible.

• get medical attention as soon as possible.

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7.0 SELECTION OF PPE AND SAFETY EQUIPMENT

7.1 SUMMARY OF PERSONAL PROTECTIVE EQUIPMENT

OSHA has defined PPE levels in 29 CFR 1910.120, and these levels are briefly described below.

• Level A – Totally encapsulating chemical protective suit, SCBA, chemical resistant gloves, steel-toed boots.

• Level B - Hooded chemical-resistant clothing, SCBA, chemical resistant gloves, steel toed boots.

• Level C - Hooded chemical resistant clothing or coveralls, air purifying respirator, chemical resistant gloves, steel toed boots.

• Level D - Coveralls or work uniform, gloves, steel-toed boots.

Level A, B, or C protection is not anticipated for work at the site, and is therefore not further discussed in this HASP.

Level D protection will be required for all site activities. Level D protection is as follows:

• coveralls or long sleeve shirts and long pants, unless otherwise directed by the SHSO or project manager;

• work gloves: leather or cotton as necessary for physical hazards;

Task Description Anticipated Level of PPE

Intrusive Activities

Pre-characterization soil sampling Soils and debris excavation

Level D

Non Intrusive Activities

Move equipment/materials Conduct site walks with subcontractors Soil screening Concrete/asphalt crushing Conduct surveying Regrading, site restoration and planting Monitor air for dust (if necessary)

Level D

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• outer nitrile gloves at a minimum for all hazardous or potentially hazardous material handling activities;

• inner latex surgical gloves are recommended where practical;

• steel toe work shoes that are ANSI approved;

• hard hat (when working with heavy equipment and/or near overhead hazards);

• safety glasses; and

• overboots, shoe covers, booties, or equivalent as determined by the project manager.

Other personal protection that must be readily available for use, if necessary, includes the following:

• hearing protection;

• chemical-resistant gloves; and

• Tyvek©.

7.2 PPE ACTION LEVELS

Decisions to upgrade personal protection will be based on emergent conditions (i.e., previously unforeseen hazards). The Project Manager must be contacted if PPE upgrade is warranted.

7.3 EQUIPMENT DECONTAMINATION

At the completion work at a the remedial site or prior to relocating equipment on-site, any tools, vehicles and waste processing equipment which may have come in contact with liquid, semi-liquid or solid OHM-impacted materials must be decontaminated. General decontamination procedures may include the following:

• all disposable items will be segregated as necessary and disposed of in a dry container;

• a decontamination area will be designated for cleaning equipment;

• before leaving the work area, excess materials will be removed from the equipment and tools and placed in approved, properly labeled containers; and

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• at a minimum, sampling equipment will be cleaned with an Alconox or other laboratory grade detergent solution, rinsed with tap water, and rinsed with deionized water.

7.4 PPE DECONTAMINATION

The minimum Level D decontamination procedures will be followed when Level D PPE is used in potentially impacted areas.

The SHSO and project manager, or the appropriate designee(s), will monitor the respective decontamination procedures to ensure their effectiveness or if modifications of the decontamination procedure may be necessary.

If necessary, a minimum of two basin wash/rinse stations will be placed in the contamination/reduction zone to facilitate cleaning and removal of PPE. Workers will use two stations to clean and rinse boots and gloves. The ground beneath these basins will be covered with plastic to ensure the ground is not impacted with basin rinse water. Drums or other types of containers will be designated to segregate and dispose of PPE that will not be reused.

The following describes procedures to be followed during Level D PPE doffing.

1. Remove and wipe clean hard hat

2. Rinse boots and gloves of gross contamination

3. Scrub boots and gloves clean

4. Rinse boots and gloves

5. Remove outer boots

6. Remove outer gloves

7. Remove Tyvek coveralls

8. Remove respirator, wipe clean and store

9. Remove inner gloves

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10. Boots that have been decontaminated can be worn into the support zone.

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8.0 SITE ACCESS AND CONTROL

8.1 OVERVIEW

The site control measures outlined below are to be followed to protect workers from potential hazards posed by SCFA closure activities and to control access to active work areas.

8.2 SITE ACCESS

The work area will be divided into work zones as a means to control site access. These work zones will be clearly marked with signage and/or barricades. In the unlikely event that the pre-characterization soil sampling indicates contamination, then the exact locations will be determined just prior to initiation of field activities and will be dependent upon other construction activities that may be taking place at the property concurrently. Work zones may include the following:

• Support Zone (SZ) - The outermost area, considered a non-impacted area. Potentially contaminated equipment is not allowed in this area.

• Contaminant Reduction (Decontamination) Zone (CRZ) – A temporary designated area where potentially contaminated PPE can be removed and decontamination processes can take place.

• Exclusion Zone (EZ) - Areas of active investigation and remediation. All personnel within the exclusion zone must wear prescribed levels of protection. The boundary of the exclusion zone will be well defined.

These zones will be established by the SHSO and will be maintained as necessary for the specific activity taking place. Access to the site will occur off Yankee Road. Access to the work areas during remedial activities will be limited to authorized personnel. Access to these areas will be provided to authorized personnel who have received the proper OSHA health and safety training, has reviewed this HASP, and has been briefed by the SHSO. Authorized personnel without the required health and safety training will be allowed in active work areas only if under the direct supervision of an appropriate YAEC or ERM representative.

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8.3 SITE CONTROL

Personnel will not conduct work at the site without properly notifying YAEC prior to commencing work activity.

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9.0 POTENTIAL HEALTH AND SAFETY RISKS

9.1 OVERVIEW

This section provides an analysis of potential safety and health risks likely to be encountered on site during implementation of the project activities.

9.2 GENERAL WORK HAZARDS

The following practices must be adhered to at the remediation project site. The SHSO is responsible to implement these practices and to ensure that each employee is aware of these practices before initiating work and to require their implementation.

• at least one copy of the Site-Specific HASP will be available on-site;

• number of personnel on-site will be restricted to the minimum necessary to complete the required work;

• no worker will be required to conduct any activity that, in his or her opinion, presents unreasonable or undue hazard exposure or risk;

• no worker may engage in activities for which the consequences of their actions are unclear;

• in the unlikely event that contamination is found and work zones are established, no food, beverages, or tobacco products will be consumed in the Exclusion Zone or the Contamination Reduction Zone;

• handling, transportation, and disposal of hazardous materials and waste will be in accordance with applicable local, state, and federal regulations;

• emergency equipment will be located in readily accessible locations that provide minimal contact with hazardous materials or wastes;

• personnel should not work alone in isolated areas;

• the active work areas will be suitably marked or barricaded as necessary to prevent unauthorized visitors, but will not delay emergency services if needed;

• prior to any digging or boring operations, underground utility locations will be identified; the site representative and local utility authorities will be contacted to provide locations of underground

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utility lines and product piping; all boring, excavation, and other site work will be planned and performed with consideration for underground lines;

• smoking and ignition sources in the vicinity of flammable or contaminated material are prohibited; Smoking may only be done in areas designated by YNPS;

• drilling, boring, movement and use of drilling rigs, movement of vehicles, and equipment as well as other activities will be planned and performed with consideration for the location, height, and relative position of aboveground utilities and fixtures, including wires, signs, lights, canopies, other structures, and construction as well as natural features such as trees, boulders, bodies of water, and terrain;

• certain medicines can potentiate the effect from exposure to certain compounds; on-site personnel should consult with their physician regarding the use of prescribed drugs during the remedial operations;

• each sample must be treated and handled with care;

• do not touch obviously OHM-impacted materials; avoiding contact with these materials will facilitate decontamination;

• persons with long hair and/or loose-fitting clothing that could become entangled in power equipment are not permitted in the work area;

• employees shall be suitably dressed to perform their duties safely and in a manner that will not interfere with their vision, hearing, or free use of their hands or feet; only waist-length shirts with sleeves and trousers that cover the entire leg are to be worn; and

• horseplay is prohibited in the work area.

9.3 CHEMICAL HAZARDS

Wash/clean hands and face prior to eating, drinking, chewing, or smoking. As a minimum, utilize commercially available wipes to clean hands regularly. Methanol and Alconox will be used in the course of decontamination of personnel and equipment. Material Safety Data Sheets for these chemicals are included in Appendix C. Use safe work practices and proper PPE when decontaminating equipment and tools to minimize and prevent unnecessary exposures.

Potential radiological hazards will be addressed by personnel under existing plant procedures.

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9.4 PHYSICAL HAZARDS

Physical hazards associated with remedial site activities include slips, trips, falls, contact- and crushing-type injuries, eye abrasions, noise, contusions, lacerations, and heat- and cold-stress concerns. The potential for such hazards necessitates the use of gloves, and safety shoes or boots that meet American National Standards Institute (ANSI) Z41.1, eye protection that meets ANSI Z87.1, and hard hats that meet ANSI Z89.1. Personnel engaged in strenuous physical labor are required to wear sturdy work gloves.

Potential physical hazards that may be present and the procedures that will be utilized to minimize these potential hazards are provided in the following table.

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Further information on some of the more common physical hazards at the remedial site is summarized below.

Potential Hazard Source of Hazard Procedures for Minimizing Hazard

Struck by heavy equipment (construction vehicles)

Working around drill rigs, excavators, dump trucks, and other heavy equipment in the work area.

• Maintain eye contact with operators. • Avoid standing in or moving through operator

‘blind’ spots (e.g., behind vehicles). • Wear hi-visibility safety vest in addition to hard

hat and safety shoes. Localized flooding, explosions, shock / electrocution

Electrical, gas, water, or sewer line underground; overhead power lines

• Contact DIG SAFE or local utility companies to verify location of subsurface utilities.

• Locate existing surface and subsurface utilities prior to start of operations.

Slips, trips, or falls in the work area

Construction debris, excavated materials; steep embankments/terrain, loose soils

• Wear safety footwear with good treads • Keep eyes on path • Use caution

Slips, trips, or falls in wetland areas

Muddy, slippery conditions; subsurface encumbrances

• Wear safety footwear with good treads • Keep eyes on path • Use caution

Cuts, nicks, lacerations

Utility knives, sharp edges, burrs. • Use sharp cutting tools • Wear leather work gloves • Use safe work practices

Strains and sprains

Moving bulky/heavy tools and equipment (i.e., transfer hoses, drums, etc.)

• Use drum dolly to move drums • Use multiple people to move large, bulky, or

heavy items which cannot be moved by other mechanical means

Struck by vehicles Walking/working along roadways

• Wear hi-visibility safety vest • Maintain eye contact with vehicle/heavy

equipment operators • Stay inside areas designated for pedestrian use • Keep as far off the roadway as possible

Fires Shock / electrocution

Sparks or heat producing equipment in the vicinity of combustibles Failure to use ground fault circuit interrupters (GFCI) on portable electrical equipment

• Operate equipment away from combustibles • Maintain portable fire extinguishers nearby • Use GFCI’s on all cord and plug electrical

equipment operating at 50 volts or greater

Chemical exposure (hands, eyes, face, clothing, inhalation)

Decontamination fluids (methanol, alconox, liquinox) Unforeseen site contaminants (test pits, excavations)

• Wear appropriate level & type of PPE • Use safe work practices when handling

chemicals

Engulfment Moving, shifting soils from spoils piles, and unstable excavations

• Do not enter excavations unless the following are in place:

• Properly sloped/benched sidewalls (e.g., 1:1 ¾) or,

• Trench shield or fully shored • Means of egress within 25 feet of work location • No spoils piles or surcharged loads within 2 feet

of the edge Oxygen depravation, chemical exposure

Entry into test pits or excavations • Test atmosphere (bottom, middle, top) of the pit/excavation prior to entry

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9.4.1 Heavy Equipment

Any equipment, including drill rigs, excavators or other heavy machinery will be operated in strict compliance with the manufacturer's instructions, specifications, and limitations, as well as any applicable regulations. All heavy equipment provided or leased on site shall be equipped with audible backup warning devices. The operator is responsible for inspecting the equipment periodically to ensure that it is functioning properly and safely. This inspection will include all pins, pulleys, and connections subject to faster than normal wear and all lubrication points.

When equipment with moving booms, arms, or masts are operated in the vicinity of overhead hazards, the operator, with assistance from a designated signaling person, will ensure that the moving parts of the equipment maintain safe clearances from the hazards. Equipment will be kept away from energized electrical lines by at least 25 feet. Drill rigs and other equipment not specifically designed to move with the boom, mast, or arm elevated will be returned to traveling position and condition before being moved.

9.4.2 Excavations / Test Pits

All excavation work will be performed in strict compliance with the Occupational Safety and Health Administration (OSHA) standard, Excavations, found at 29 CFR 1926 Sub Part P. No entry will be made into any subsurface excavation deeper than four feet unless the following have first been performed:

• Sidewalls have been properly sloped/benched to at least 1:1 ¾, or

• A trench shield has been installed, or

• The excavation has been fully shored, and

• The atmosphere has been tested for oxygen and combustible atmospheres, and

• A means of egress is located within 25 feet of the work location, and

• Verify that the spoils piles and surcharged loads are greater than two feet from the edge of the excavation.

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ERM 31 YANKEE ROWE-001581-7/27/2004

Portable equipment and tools will be inspected periodically and as often as necessary to ensure safety. Defective equipment and tools will be removed from service immediately. Examples of defective tools include: hooks and chains stretched beyond allowable deformations; cables and ropes with more than the allowable number of broken strands; missing grounding prongs on power tools; defective on/off switches; mushroomed heads of impact tools; sprung wrench jaws; and missing or broken handles or guards as well as wooden handles which are cracked, splintered, or loose. Equipment and tools will only be used within their rated capacities and capabilities.

The location of underground pipes, electrical conductors, fuel, water and sewer lines must be determined prior to any drilling work. ERM will contact Digsafe (1-888-DIG-SAFE) and local utility companies prior to performing subsurface work at the site. All lines must be de-energized, locked-out, or blinded off where feasible.

9.4.3 Logging Hazards

Tree felling and removal may be required as part of the SCFA closure activities. The tools and equipment used in logging, as well as unforeseen hazards associated with tree felling can pose serious or life threatening hazards. Only individuals specifically trained in logging, tree felling, and operation of a brush chipper will engage in these activities. All others not directly associated with these activities will remain at least 200 feet from active logging, tree felling, chipping operations.

9.4.4 Fire/ /Explosion/ Electrical Hazards

Before using any spark/heat/flame producing equipment, the work area will be surveyed for the presence of combustibles. No hot work will be commenced within 20 feet of combustibles, and a fire extinguisher will be present whenever hot work is being performed.

Before being used on site, electrical equipment will be inspected to ensure that it is in good repair and has no frayed or loose connections. Only approved, listed equipment and components will be used. Temporary and/or portable power connections will be made in accordance with National Electric Code practices. Equipment and devices so designed will be properly grounded or bonded to an adequate grounding mechanism. All cord and plug connected electrical equipment operating at greater than 50 volts used out doors will have a ground fault circuit interrupter (GFCI) between the tool and the source of power (e.g., electrical outlet, portable power source, etc.).

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ERM 32 YANKEE ROWE-001581-7/27/2004

9.5 BIOLOGICAL HAZARDS

9.5.1 Insects

Insects represent significant sources of disease transmission. Therefore, precautions to avoid or minimize potential contact should be considered prior to field activities. Disease or harmful effects can be transmitted through bites, stings or through direct contact with insects or through ingestion of foods contaminated by certain insects. Examples of disease transmitted by insect bites include encephalitis and west nile virus from contaminated mosquitoes, and Lyme disease and spotted fever from contaminated ticks. Stinging insects, such as bees and wasps, are prevalent throughout the country, particularly during the warmer months. The stings of these insects can be painful and cause serious allergic reactions to some individuals. Individuals with allergic reactions to insect stings should notify the SHSO of this allergy prior to starting work at the site.

9.5.2 Lyme Disease

Lyme disease is an infection caused by the bite from deer ticks. The symptoms of Lyme disease may start out as a skin rash with a bulls-eye pattern, and then progress to more serious symptoms. However, the skin rash may not be evident and symptoms may develop slowly over a period of months. The more serious symptoms can include lesions, headaches, arthritis, neurological disorders (e.g. numbness or tingling in extremities) and permanent damage to the neurological system. If detected early the disease can be treated successfully with antibiotics. The following steps are recommended for prevention of Lyme disease and other diseases transmitted by ticks: • beware of tall grass, bushes, woods and other areas where ticks may

live;

• wear safety boots, long pants tucked into socks/boots, a long sleeve shirt with a snug collar, good cuffs around the wrists and tails tucked into the pants. Insect/tick repellents may also be useful; and

• carefully monitor for the presence of ticks. Carefully inspect clothes and skin when undressing. If a tick is attached to the skin it should be removed with fine tipped tweezers. You should be alert for early symptoms over the next month or so. If you suspect that a tick has bitten you, you should immediately contact a physician for medical advice.

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ERM 33 YANKEE ROWE-001581-7/27/2004

9.5.3 Poisonous Plants

The possible presence of poisonous plants should be anticipated for field activities in wooded or wetland areas. Contact with poison ivy, poison oak and sumac result in an intensely itching skin rash and characteristic blister-like lesions. Contact with these plants should be avoided.

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© 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001

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© 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001

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© 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001

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© 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001

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© 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001

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© 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001 © 2001 DeLorme. Street Atlas USA; © 2001 GDT, Inc., Rel. 01/2001

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Appendix A

Health and Safety Sign-Off Sheet

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Appendix A - HEALTH AND SAFETY SIGN-OFF SHEET

SITE NAME: Yankee Nuclear Power Station, Rowe, Massachusetts

I have received a copy of the Health and Safety Plan prepared for the above referenced site. I have read and understood its content, and I agree that I will abide by its requirements in accordance with the Disclaimers and Limitations on Use.

Name Signature Company

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

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DISCLAIMERS AND LIMITATIONS ON USE

Environmental Resources Management ("ERM") developed the Site-Specific Health and Safety Plan (the "HASP") for use by ERM personnel in connection with the assessment and remediation activities (the "Project") being performed by ERM for Yankee Atomic Energy Company (the "Client") at the YNPS Site (the "Site"). ERM personnel must adhere to the practices and procedures specified in the HASP.

Each ERM Contractor must review the HASP and agree to accept and abide by the HASP, subject to any modifications to the HASP (to address the ERM Contractor's more stringent practices and procedures) agreed upon in writing by ERM and the ERM Contractor. The ERM Contractor shall indicate such acceptance by signing above and providing the signature to ERM's project manager for the Project prior to its commencing work at the Site. However, if any ERM Contractor commences work at the Site, the ERM Contractor shall be deemed to have accepted the HASP and the terms hereof and the failure to execute and return to ERM a copy of this notice shall not be relevant to such interpretation.

If a contractor or a person other than the Client, ERM employees and ERM Contractors (individually, a "Third Party" and collectively, "Third Parties") receives a copy of the HASP, such Third Party should not assume that the HASP is appropriate for the activities being conducted by the Third Party. NO THIRD PARTY HAS THE RIGHT TO RELY ON THE HASP. EACH THIRD PARTY SHOULD ABIDE BY ITS OWN SITE SPECIFIC HEALTH AND SAFETY PLAN IN ACCORDANCE WITH ITS OWN PROFESSIONAL JUDGMENT AND ESTABLISHED PRACTICES.

ERM shall not be responsible for the implementation of any Third Party's safety program(s), except to the extent otherwise expressly agreed upon by ERM and a Third Party in writing. The services performed by ERM for the Client and any right of the Client and/or an ERM Contractor to rely on the HASP shall in no way inure to the benefit of any Third Party, including, but not limited to, employees, agents, or consultants and subcontractors of ERM Contractors, so as to give rise to any cause of action by such Third Party against ERM.

The HASP generated by ERM in connection with the Project is for use on a specific site and in connection with a specific project. ERM makes no representation or warranty as to the suitability of the HASP for reuse on another site or as to the suitability of the HASP for reuse on another project or for modifications made by the Client or a Third Party to the HASP.

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Appendix B

Daily Safety Meeting Form

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DAILY SAFETY MEETING FORM

DATE: TIME: JOB NUMBER:

PROJECT NAME: SPECIFIC LOCATION: TYPE OF WORK:

CHEMICALS PRESENT:

SAFETY TOPICS DISCUSSED Protective Clothing/Equipment:

Hazards of Chemicals Present:

Physical Hazards:

Emergency Procedures:

Hospital/Clinic: Phone: Paramedics:

Hospital Address:

Special Hazards:

Other Topics:

ATTENDEES Name (printed) Signature

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Appendix C

Material Safety Data Sheets

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Division of Facilities Services

DOD Hazardous Material Information (ANSI Format) For Cornell University Convenience Only

METHANOL

The information in this document is compiled from information maintained by the United States Department of Defense (DOD). Anyone using this information is solely reponsible for the accuracy and applicability of this information to a particular use or situation. Cornell University does not in any way warrant or imply the applicability, viability or use of this information to any person or for use in any situation.

Section 1 - Product and Company Identification METHANOL

Product Identification: METHANOL Date of MSDS: 01/01/1987 Technical Review Date: 07/22/1999 FSC: 6810 NIIN: 00-990-0572 Submitter: D DG Status Code: C MFN: 01 Article: N Kit Part: N

Manufacturer's Information

Manufacturer's Name: FISHER SCIENTIFIC CO. Manufacturer's Address1: 1 REAGENT LANE Manufacturer's Address2: FAIR LAWN, NJ 07410 Manufacturer's Country: US General Information Telephone: 201-796-7100

Section 1 - Product and Company Identification Section 9 - Physical & Chemical Properties

Section 2 - Compositon/Information on Ingredients Section 10 - Stability & Reactivity Data

Section 3 - Hazards Identification Including Emergency Overview Section 11 - Toxicological Information

Section 4 - First Aid Measures Section 12 - Ecological Information

Section 5 - Fire Fighting Measures Section 13 - Disposal Considerations

Section 6 - Accidental Release Measures Section 14 - MSDS Transport Information

Section 7 - Handling and Storage Section 15 - Regulatory Information

Section 8 - Exposure Controls & Personal Protection Section 16 - Other Information

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Emergency Telephone: 201-796-7100 OR 201-796-7523 Emergency Telephone: 201-796-7100 OR 201-796-7523 MSDS Preparer's Name: N/P Proprietary: N Reviewed: Y Published: Y CAGE: 1B464 Special Project Code: N

Item Description

Item Name: METHANOL,ACS Item Manager: Specification Number: NK Type/Grade/Class: NK Unit of Issue: Unit of Issue Quantity: Type of Container: BOTTLE

Contractor Information

Contractor's Name: FISHER SCIENTIFIC CO. CHEMICAL MFG DIV Contractor's Address1: 1 REAGENT LANE Contractor's Address2: FAIR LAWN, NJ 07410-2802 Contractor's Telephone: 201-796-7100 Contractor's CAGE: 1B464

Section 2 - Compositon/Information on Ingredients METHANOL

Ingredient Name: METHYL ALCOHOL (METHANOL) (SARA III) Ingredient CAS Number: 67-56-1 Ingredient CAS Code: M RTECS Number: PC1400000 RTECS Code: M =WT: =WT Code: =Volume: =Volume Code: >WT: >WT Code: >Volume: >Volume Code: <WT: <WT Code: <Volume: <Volume Code: % Low WT: % Low WT Code: % High WT: % High WT Code: % Low Volume: % Low Volume Code: % High Volume: % High Volume Code: % Text: 100 % Enviromental Weight: Other REC Limits: N/P OSHA PEL: S,200PPM/250STEL OSHA PEL Code: M OSHA STEL: OSHA STEL Code: ACGIH TLV: S,200PPM/250STEL; 93 ACGIH TLV Code: M ACGIH STEL: N/P ACGIH STEL Code: EPA Reporting Quantity: 5000 LBS DOT Reporting Quantity: 5000 LBS Ozone Depleting Chemical: N

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Section 3 - Hazards Identification, Including Emergency Overview METHANOL

Health Hazards Acute & Chronic: N/P Signs & Symptoms of Overexposure: POISON,HARMFUL.EYES:IRRITATION,FAILURE OF VISION.IMHAL:HEADACHE.VOMIT,NAUSEA.CNS DEPRESSION.GI-TRACT Medical Conditions Aggravated by Exposure: N/P LD50 LC50 Mixture: N/P

Route of Entry Indicators: Inhalation: N/P Skin: N/P Ingestion: N/P

Carcenogenicity Indicators NTP: N/P IARC: N/P OSHA: N/P

Carcinogenicity Explanation: N/P

Section 4 - First Aid Measures METHANOL

First Aid: INHALE:REMOVE TO FRESH AIR, GIVE CPR/O*2 IF NEED;EYES/SKIN:FLUSH W LG AMTS H*2O FOR 15 MIN;INGEST:RINSE MOUTH; GET MEDICAL ATTENTION FOR EYES, BREATHING DIFFICULTY, OR OTHER SYMPTOMS OF OVEREXPOSURE.

Section 5 - Fire Fighting Measures METHANOL

Fire Fighting Procedures: USE WATER TO COOL CONTRS.WEAR SCBA IN FIRES AND COFINED AREA Unusual Fire or Explosion Hazard: NONE SPECIFIED.USE REASONABLE CARE.FLAMMABLE LIQUID. Extinguishing Media: DRY CHEMICAL,CO*2,FOAM) Flash Point: Flash Point Text: 50F/10C (

Autoignition Temperature: Autoignition Temperature Text: N/A Lower Limit(s): 6.0 Upper Limit(s): 36.5

Section 6 - Accidental Release Measures METHANOL

Spill Release Procedures:

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USE PROPER PERSONAL PROTECTION.ABSORB ON VERMICULITE.SCOOP UP AND PLACE IN A SUITABLE CONTAINER.

Section 7 - Handling and Storage METHANOL

Handling and Storage Precautions: Other Precautions:

Section 8 - Exposure Controls & Personal Protection METHANOL

Repiratory Protection: USE NIOSH APPROVED RESPIRATOR FOR ORGANIC VAPORS. Ventilation: LOCAL EXHAUST TO MAINTN BELOW TLV. Protective Gloves: RUBBER Eye Protection: SAFETY GLASSES Other Protective Equipment: FULL PROTECTIVE CLOTHING,SAFETY SHOWER,EYE WASH STATION Work Hygenic Practices: N/P Supplemental Health & Safety Information: MSDS DATED APRIL 8, 1980

Section 9 - Physical & Chemical Properties METHANOL

HCC: F2 NRC/State License Number: Net Property Weight for Ammo: Boiling Point: Boiling Point Text: 148F/64.5C Melting/Freezing Point: Melting/Freezing Text: N/A Decomposition Point: Decomposition Text: N/A Vapor Pressure: 100 Vapor Density: 1.11 Percent Volatile Organic Content: Specific Gravity: 0.792 Volatile Organic Content Pounds per Gallon: pH: N/P Volatile Organic Content Grams per Liter: Viscosity: N/P Evaporation Weight and Reference: <1.0 (BUT ACET=1) Solubility in Water: COMPLETE Appearance and Odor: CLEAR,COLORLESS LIQUID. Percent Volatiles by Volume: 100 Corrosion Rate: N/P

Section 10 - Stability & Reactivity Data METHANOL

Stability Indicator: YES Materials to Avoid: STRONG OXIDIZERS Stability Condition to Avoid: HEAT,SPARKS,FLAME Hazardous Decomposition Products:

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MAY GIVE CO & CO*2 ON BURNING. Hazardous Polymerization Indicator: NO Conditions to Avoid Polymerization: N/P

Section 11 - Toxicological Information METHANOL

Toxicological Information: N/P

Section 12 - Ecological Information METHANOL

Ecological Information: N/P

Section 13 - Disposal Considerations METHANOL

Waste Disposal Methods: DISPOSE OF THE COLLECTED MATERIAL IN ACCORDANCE WITH LOCAL, STATE AND FEDERAL REGULATIONS.

Section 14 - MSDS Transport Information METHANOL

Transport Information: N/P

Section 15 - Regulatory Information METHANOL

SARA Title III Information: N/P Federal Regulatory Information: N/P State Regulatory Information: N/P

Section 16 - Other Information METHANOL

Other Information: N/P

HMIS Transportation Information Product Identification: METHANOL Transporation ID Number: 97013 Responsible Party CAGE: 1B464 Date MSDS Prepared: 01/01/1987 Date MSDS Reviewed: 09/30/1986 MFN: 09/30/1986 Submitter: D DG Status Code: C

Container Information

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Unit of Issue: Container Quantity: Type of Container: BOTTLE Net Unit Weight:

Article without MSDS: N Technical Entry NOS Shipping Number: Radioactivity: Form: Net Explosive Weight: Coast Guard Ammunition Code: Magnetism: N/P AF MMAC Code: DOD Exemption Number: Limited Quantity Indicator: Multiple Kit Number: 0 Kit Indicator: N Kit Part Indicator: N Review Indicator: Y Additional Data:

Department of Transportation Information DOT Proper Shipping Name: METHANOL DOT PSN Code: JEZ Symbols: I DOT PSN Modifier: METHYL ALCOHOL SEE METHANOL Hazard Class: 3 UN ID Number: UN1230 DOT Packaging Group: II Label: FLAMMABLE LIQUID, POISON Special Provision(s): T8 Packaging Exception: Non Bulk Packaging: 202 Bulk Packaging: 242 Maximimum Quanity in Passenger Area: 1 L Maximimum Quanity in Cargo Area: 60 L Stow in Vessel Requirements: B Requirements Water/Sp/Other: 40

IMO Detail Information IMO Proper Shipping Name: METHYL ALCOHOL IMO PSN Code: JQR IMO PSN Modifier: IMDG Page Number: SEE 3251 UN Number: 1230 UN Hazard Class: 3.2 IMO Packaging Group: II Subsidiary Risk Label: TOXIC EMS Number: 3-06 Medical First Aid Guide Number: 306

IATA Detail Information IATA Proper Shipping Name: METHANOL IATA PSN Code: QHQ IATA PSN Modifier: IATA UN Id Number: 1230

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IATA UN Class: 3 Subsidiary Risk Class: 6.1 UN Packaging Group: II IATA Label: FLAMM. LIQ. & TOXIC Packaging Note for Passengers: 305 Maximum Quantity for Passengers: 1L Packaging Note for Cargo: 307 Maximum Quantity for Cargo: 60L Exceptions: A104, A113

AFI Detail Information AFI Proper Shipping Name: METHANOL OR METHYL ALCOHOL AFI Symbols: AFI PSN Code: QHQ AFI PSN Modifier: AFI UN Id Number: UN1230 AFI Hazard Class: 3 AFI Packing Group: II AFI Label: 6.1 Special Provisions: P4 Back Pack Reference: A7.3

HAZCOM Label Information Product Identification: METHANOL CAGE: 1B464 Assigned Individual: N Company Name: FISHER SCIENTIFIC CO. CHEMICAL MFG DIV Company PO Box: Company Street Address1: 1 REAGENT LANE Company Street Address2: FAIR LAWN, NJ 07410-2802 US Health Emergency Telephone: 201-796-7100 OR 201-796-7523 Label Required Indicator: Y Date Label Reviewed: 12/16/1998 Status Code: C Manufacturer's Label Number: Date of Label: 12/16/1998 Year Procured: N/K Organization Code: F Chronic Hazard Indicator: N/P Eye Protection Indicator: N/P Skin Protection Indicator: N/P Respiratory Protection Indicator: N/P Signal Word: N/P Health Hazard: Contact Hazard: Fire Hazard: Reactivity Hazard:

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Division of Facilities Services

DOD Hazardous Material Information (ANSI Format) For Cornell University Convenience Only

ALCONOX

The information in this document is compiled from information maintained by the United States Department of Defense (DOD). Anyone using this information is solely reponsible for the accuracy and applicability of this information to a particular use or situation. Cornell University does not in any way warrant or imply the applicability, viability or use of this information to any person or for use in any situation.

Section 1 - Product and Company Identification ALCONOX

Product Identification: ALCONOX Date of MSDS: 08/14/1992 Technical Review Date: 09/28/1992 FSC: 6505 NIIN: 00-839-8894 Submitter: N EN Status Code: C MFN: 01 Article: N Kit Part: N

Manufacturer's Information

Manufacturer's Name: ALCONOX INC Manufacturer's Address1: 215 PARK AVE S Manufacturer's Address2: NEW YORK, NY 10003 Manufacturer's Country: US General Information Telephone: 212-473-1300

Section 1 - Product and Company Identification Section 9 - Physical & Chemical Properties

Section 2 - Compositon/Information on Ingredients Section 10 - Stability & Reactivity Data

Section 3 - Hazards Identification Including Emergency Overview Section 11 - Toxicological Information

Section 4 - First Aid Measures Section 12 - Ecological Information

Section 5 - Fire Fighting Measures Section 13 - Disposal Considerations

Section 6 - Accidental Release Measures Section 14 - MSDS Transport Information

Section 7 - Handling and Storage Section 15 - Regulatory Information

Section 8 - Exposure Controls & Personal Protection Section 16 - Other Information

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Emergency Telephone: 212-473-1300 Emergency Telephone: 212-473-1300 MSDS Preparer's Name: N/P Proprietary: N Reviewed: N Published: Y CAGE: 17534 Special Project Code: N

Item Description

Item Name: DETERGENT,SURGICAL INSTRUMENT Item Manager: NK Specification Number: NK Type/Grade/Class: NK Unit of Issue: NK Quantitative Expression: NK Unit of Issue Quantity: NK Type of Container:

Contractor Information

Contractor's Name: ALCONOX INC Contractor's Address1: 9 EAST 40TH STREET, SUITE 200 Contractor's Address2: NEW YORK, NY 10016 Contractor's Telephone: 212-532-4040 Contractor's CAGE: 17534

Section 2 - Compositon/Information on Ingredients ALCONOX

Ingredient Name: ALCONOX Ingredient CAS Number: Ingredient CAS Code: X RTECS Number: RTECS Code: X =WT: =WT Code: =Volume: =Volume Code: >WT: >WT Code: >Volume: >Volume Code: <WT: <WT Code: <Volume: <Volume Code: % Low WT: % Low WT Code: % High WT: % High WT Code: % Low Volume: % Low Volume Code: % High Volume: % High Volume Code: % Text: N/K % Enviromental Weight: Other REC Limits: N/K OSHA PEL: NOT APPLICABLE OSHA PEL Code: M OSHA STEL: OSHA STEL Code: ACGIH TLV: NOT APPLICABLE ACGIH TLV Code: M ACGIH STEL: N/P ACGIH STEL Code: EPA Reporting Quantity: DOT Reporting Quantity: Ozone Depleting Chemical:

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Section 3 - Hazards Identification, Including Emergency Overview ALCONOX

Health Hazards Acute & Chronic: PROLONGED EXPOSURE TO DUST MAY IRRITATE MUCOUS MEMBRANES. Signs & Symptoms of Overexposure: SEE HEALTH HAZARDS. Medical Conditions Aggravated by Exposure: NONE SPECIFIED BY MANUFACTURER. LD50 LC50 Mixture: NONE SPECIFIED BY MANUFACTURER.

Route of Entry Indicators: Inhalation: YES Skin: NO Ingestion: NO

Carcenogenicity Indicators NTP: NO IARC: NO OSHA: NO

Carcinogenicity Explanation: NOT RELEVANT

Section 4 - First Aid Measures ALCONOX

First Aid: EYES: FLUSH WITH PLENTY OF WATER FOR AT LEAST 15 MIN. SKIN: FLUSH WITH PLENTY OF WATER. INGEST: DRINK LARGE QTY OF WATER TO DILUTE MATERIAL. GET MED ATTN FOR DISCOMFORT. INHAL: REMOVE TO FRESH AIR. SU PPORT BRTHG (GIVE O*2/ARTF RESP) (FP N).

Section 5 - Fire Fighting Measures ALCONOX

Fire Fighting Procedures: WEAR NIOSH/MSHA APPROVED SCBA AND FULL PROTECTIVE EQUIPMENT (FP N). Unusual Fire or Explosion Hazard: NONE. Extinguishing Media: WATER, CARBON DIOXIDE, DRY CHEMICAL, FOAM SAND/EARTH. Flash Point: Flash Point Text: NONE

Autoignition Temperature: Autoignition Temperature Text: N/A Lower Limit(s): N/A Upper Limit(s): N/A

Section 6 - Accidental Release Measures ALCONOX

Spill Release Procedures:

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MATERIAL FOAMS PROFUSELY, SHOVEL & RECOVER AS MUCH AS POSSIBLE. RINSE REMAINDER TO SEWER. MATERIAL IS COMPLETELY BIODEGRADABLE.

Section 7 - Handling and Storage ALCONOX

Handling and Storage Precautions: Other Precautions:

Section 8 - Exposure Controls & Personal Protection ALCONOX

Repiratory Protection: NIOSH/MSHA APPROVED DUST MASK. Ventilation: LOCAL EXHAUST: NORMAL. Protective Gloves: IMPERVIOUS GLOVES (FP N). Eye Protection: CHEMICAL WORKERS GOGGLES (FP N). Other Protective Equipment: NOT REQUIRED. Work Hygenic Practices: NONE SPECIFIED BY MANUFACTURER. Supplemental Health & Safety Information: NONE SPECIFIED BY MANUFACTURER.

Section 9 - Physical & Chemical Properties ALCONOX

HCC: NRC/State License Number: Net Property Weight for Ammo: Boiling Point: Boiling Point Text: N/A Melting/Freezing Point: Melting/Freezing Text: N/K Decomposition Point: Decomposition Text: N/K Vapor Pressure: N/A Vapor Density: N/A Percent Volatile Organic Content: Specific Gravity: N/A Volatile Organic Content Pounds per Gallon: pH: N/K Volatile Organic Content Grams per Liter: Viscosity: N/P Evaporation Weight and Reference: NOT APPLICABLE Solubility in Water: APPRECIABLE Appearance and Odor: WHITE POWDER INTERSPERSED W/CREAM COLORED FLAKES-ODORLESS Percent Volatiles by Volume: N/A Corrosion Rate: N/K

Section 10 - Stability & Reactivity Data ALCONOX

Stability Indicator: YES Materials to Avoid: AVOID STRONG ACIDS. Stability Condition to Avoid: NONE. Hazardous Decomposition Products:

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MAY RELEASE CARBON DIOXIDE GAS ON BURNING. Hazardous Polymerization Indicator: NO Conditions to Avoid Polymerization: NOT RELEVANT

Section 11 - Toxicological Information ALCONOX

Toxicological Information: N/P

Section 12 - Ecological Information ALCONOX

Ecological Information: N/P

Section 13 - Disposal Considerations ALCONOX

Waste Disposal Methods: SMALL QTY MAY BE DISPOSED OF IN SEWER. LARGE QTY SHOULD BE DISPOSED OF ACCORDING TO LOCAL, FEDERAL & STATE REQUIREMENTS FOR NON-HAZARDOUS DETERGENT.

Section 14 - MSDS Transport Information ALCONOX

Transport Information: N/P

Section 15 - Regulatory Information ALCONOX

SARA Title III Information: N/P Federal Regulatory Information: N/P State Regulatory Information: N/P

Section 16 - Other Information ALCONOX

Other Information: N/P

HMIS Transportation Information Product Identification: ALCONOX Transporation ID Number: 88154 Responsible Party CAGE: 17534 Date MSDS Prepared: 08/14/1992 Date MSDS Reviewed: 02/22/1993 MFN: 02/22/1993 Submitter: N TN Status Code: C

Container Information

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Unit of Issue: NK Container Quantity: NK Type of Container: Net Unit Weight:

Article without MSDS: N Technical Entry NOS Shipping Number: Radioactivity: Form: Net Explosive Weight: Coast Guard Ammunition Code: Magnetism: N/P AF MMAC Code: DOD Exemption Number: Limited Quantity Indicator: Multiple Kit Number: 0 Kit Indicator: N Kit Part Indicator: N Review Indicator: Y Additional Data: NOT REGULATED FOR TRANSPORTATION

Department of Transportation Information DOT Proper Shipping Name: NOT REGULATED BY THIS MODE OF TRANSPORTATION DOT PSN Code: ZZZ Symbols: N/R DOT PSN Modifier: Hazard Class: N/R UN ID Number: N/R DOT Packaging Group: N/R Label: N/R Special Provision(s): N/R Packaging Exception: N/R Non Bulk Packaging: N/R Bulk Packaging: N/R Maximimum Quanity in Passenger Area: N/R Maximimum Quanity in Cargo Area: N/R Stow in Vessel Requirements: N/R Requirements Water/Sp/Other: N/R

IMO Detail Information IMO Proper Shipping Name: NOT REGULATED FOR THIS MODE OF TRANSPORTATION IMO PSN Code: ZZZ IMO PSN Modifier: IMDG Page Number: N/R UN Number: N/R UN Hazard Class: N/R IMO Packaging Group: N/R Subsidiary Risk Label: N/R EMS Number: N/R Medical First Aid Guide Number: N/R

IATA Detail Information IATA Proper Shipping Name: NOT REGULATED BY THIS MODE OF TRANSPORTATION IATA PSN Code: ZZZ IATA PSN Modifier: IATA UN Id Number: N/R

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IATA UN Class: N/R Subsidiary Risk Class: N/R UN Packaging Group: N/R IATA Label: N/R Packaging Note for Passengers: N/R Maximum Quantity for Passengers: N/R Packaging Note for Cargo: N/R Maximum Quantity for Cargo: N/R Exceptions: N/R

AFI Detail Information AFI Proper Shipping Name: NOT REGULATED BY THIS MODE OF TRANSPORTATION AFI Symbols: AFI PSN Code: ZZZ AFI PSN Modifier: AFI UN Id Number: N/R AFI Hazard Class: N/R AFI Packing Group: N/R AFI Label: N/R Special Provisions: N/A Back Pack Reference: N/A

HAZCOM Label Information Product Identification: ALCONOX CAGE: 17534 Assigned Individual: N Company Name: ALCONOX INC Company PO Box: Company Street Address1: 9 EAST 40TH STREET, SUITE 200 Company Street Address2: NEW YORK, NY 10016 US Health Emergency Telephone: 212-473-1300 Label Required Indicator: Y Date Label Reviewed: 09/18/1992 Status Code: C Manufacturer's Label Number: Date of Label: 09/18/1992 Year Procured: N/K Organization Code: G Chronic Hazard Indicator: N Eye Protection Indicator: YES Skin Protection Indicator: YES Respiratory Protection Indicator: YES Signal Word: CAUTION Health Hazard: Slight Contact Hazard: Slight Fire Hazard: None Reactivity Hazard: None

8/8/2002 12:40:10 AM