PCB Soil Field Sampling Plan

Transcription

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2 PCB Soil Field Sampling Plan Yankee Nuclear Power Station 49 Yankee Road Rowe Massachusetts February 2005

3 1.0 INTRODUCTION BACKGROU PURPOSE & SCOPE SUMMARY OF EISTING DATA SOIL SAMPLING PROGRAM STAARD OPERATING PROCEDURES SAMPLE LOCATIONS A DESIGNATIONS SAMPLING PROCEDURES A ANALYTICAL PROGRAM Geoprobe Sampling Auger Sampling ANALYTICAL PROGRAM On-Site PCB Screening PCB Laboratory Analyses Radiological Parameters SAMPLE SECURITY A CUSTODY MANAGEMENT OF INVESTIGATION DERIVED WASTES SCEDULE QUALITY ASSURANCE A QUALITY CONTROL QUALITY ASSURANCE PROJECT PLAN CLEANING A DECONTAMINATION OF EQUIPMENT QUALITY ASSURANCE / QUALITY CONTROL SAMPLES PROJECT DOCUMENTATION 12 ERM i YANKEE 2/15/2005

4 TABLES Table 1 Table 2 PCB Soil Results Soil PCB Analytical Program FIGURES Figure 1 Figure 2 Figure 3 Site Locus PCB Soil Sampling Summary Proposed Sampling Locations APPEICES Appendix A Gradient Memorandum on Sampling Appendix B Rapid Assay Instructions Appendix C Results Comparison between NEL Off Site Lab Analysis and Rapid Assay Immunoassay PCB Soil Sample Analysis ERM ii YANKEE 2/15/2005

5 PCB Soil Field Sampling Plan Yankee Nuclear Power Station 49 Yankee Road Rowe Massachusetts February 2005 Kenneth Dow Yankee Atomic Environmental Manager John. W. McTigue, P.G., LSP Environmental Resources Management ERM YANKEE 2/15/2005

6 1.0 INTRODUCTION 1.1 BACKGROU On behalf of Yankee Atomic Electric Company (YAEC), Environmental Resources Management (ERM) has prepared this Polychlorinated Biphenyl (PCB) Soil Field Sampling Plan (FSP) for the Yankee Nuclear Power Station (YNPS) located at 49 Yankee Road in Rowe, Massachusetts (Figure 1). This FSP has been prepared as a supplement to the Quality Assurance Project Plan (QAPP), Site Closure, Revision 2, Yankee Nuclear Power Station, Rowe, Massachusetts, Gradient, dated 6 August PURPOSE & SCOPE The purpose of the PCB Soil FSP is to delineate the lateral and vertical extent of PCB impacts to soil greater than 1 milligram per kilogram (mg/kg) in the vicinity of the Industrial Area at the YNPS. New data generated as a result of this sampling program will be used to define the remedial strategy for PCB-impacted soil and to develop a plan to integrate the remedial activities into the on-going plant decommissioning activities. The sampling program is intended to support closure of the site under the Massachusetts Contingency Plan (MCP) and Toxic Substances Control Act (TSCA). The PCB Soil FSP is intended to: Establish the procedures and rationale for soil sampling activities in support of site closure. Establish requirements, protocols and documentation for protection of worker health and safety. Ensure that soil sampling is consistent with applicable procedures. Ensure that the Data Quality Objectives (DQOs) for site closure are met. Areas not addressed in the PCB Soil FSP include: PCB impacts to the SCFA, which is the focus of separate investigation program. ERM 1 YANKEE 2/15/2005

7 Low-level PCB impacts in areas distant from the Industrial Area where levels are consistently below 1 mg/kg and there is no known source of impact. Radiological analyses, which are the focus of a separate investigation program. Post-remediation closure sampling to satisfy TSCA, which will be performed during a later phase of investigation. Sampling of PCB work areas, including crane pads, which will be performed during a separate sampling event. The data generated under this FSP will be validated and input into the site database and used in conjunction with historic data to determine the need for, and scope of, future soil sampling events and remedial response actions. 1.3 SUMMARY OF EISTING DATA Soil samples have been collected at more than 180 locations for PCB analysis. The majority of samples have been in the upper 12 inches of soil, with sampling at select locations up to 15 feet below ground surface (bgs). Soil excavation activities were conducted in Fall 2004 in the central portion of the site, below the former Vapor Container, which is the primary source of PCB-containing paint chips. Approximately 3,500 cubic yards of soil have been excavated and are currently stored on-site. A summary of the existing PCB soil data is provided in Table 1 and Figure 2. The sampling data has been collected as part of the MCP and site closure investigation activities. PCBs were less than 1 mg/kg in 82 percent of the samples. The maximum concentration of PCBs detected at the site is 240 mg/kg (YRDTS-22). ERM 2 YANKEE 2/15/2005

8 2.0 SOIL SAMPLING PROGRAM 2.1 STAARD OPERATING PROCEDURES YNPS Standard Operating Procedures (SOPs) applicable to the soil investigation include: YNPS ealth and Safety Plan. DP-8120 Collection of Site Characterization and Site Release Samples. DP-8123 Sample Security and Chain of Custody. AP-0626 Job azard Assessments. AP-8122 Subsurface Soil Sampling and Monitoring Well Installation. All YNPS SOPs applicable to this FSP are maintained in the YNPS Environmental Oversight Trailer. 2.2 SAMPLE LOCATIONS A DESIGNATIONS Due to the range of PCB concentrations detected and the size of YNPS, the site was subdivided into five study areas i which are intended to exhibit less variation in the range of PCBs detected. Within each study area a sampling program was developed based on the following criteria: Coverage and variation of existing data. Presence of concrete slabs that were present throughout life of plant. Feasibility of collecting additional samples (based on topography and winter conditions). Observations of paint chips in soil (i.e., adjacent to select building foundations). Gradient performed an analysis of the existing PCB data in an effort to develop the basis for the number of samples (see Appendix A). Based on i The concept of study areas are being used for the purposes of developing the PCB Soil FSP and are not intended for risk assessment purposes. ERM 3 YANKEE 2/15/2005

9 this analysis, 20 samples per study area are expected to be sufficient to provide obtain a 95 percent upper confidence limit of a mean of 1 mg/kg. Sample locations were selected based on the following basis: Grid Sampling - Sample locations were selected to fill existing data gaps. Samples will be collected both on the grid that was created for the site closure sampling program and in targeted areas. The grid sampling will be conducted on a 50-foot grid, where appropriate, to supplement the original 100-foot grid used for the site closure sampling program. Targeted Sampling Sampling will be targeted to supplement the grid based on the existing data and adjacent to structures where paint chips were observed on the ground surface. Replicate Sampling Four sample locations are intended to replicate previous sampling data that appears anomalous: SB-026, SB-092, YRDTS-020, and YRDTS-043. A summary of the proposed sampling activities is provided below: Study area Maximum Concentration (mg/kg) # of Existing Samples # of New Sample Locations Comments Samples along grid, below excavation area, and in targeted area to east of former Vapor Container Samples along hillside along grid. Three samples below roadway to determine if impacts are present below roadway Samples along grid primarily in eastern portion of area, with some confirmatory sample in western portion Sampling north and east of service building to evaluate potential impacts associated with decommissioning activities Sampling south of Service Building and along grid to east of central portion of site. ERM 4 YANKEE 2/15/2005

10 Sample locations within the central portion of the site (Study areas 1, 3, and 4, and in portions of 2 and 5) will be collected using a Geoprobe drill rig. Soil samples will be collected from ground surface to 4 feet bgs at most locations. At five of the sampling locations, the boring will extend to 8 feet bgs to verify the vertical extent of impact. Soil samples will be collected from the following intervals ii : 0 to 3 inches bgs, 1 to 2 feet bgs, 2 to 3 feet bgs, 3 to 4 feet bgs, 4 to 6 feet bgs, and 6 to 8 feet bgs, as appropriate. A sample may also be collected between 3 and 12 inches below grade based on field observations. Samples in the remaining areas will be collected to from 0 to 3 inches bgs, except where noted in Table 2. Those samples will be collected using a hand auger or Geoprobe. The soil samples will be identified using unique sample identification. The sample designations will use the naming convention as detailed in the YNPS QAPP and in Table 2. Sample locations will be recorded using a Global Positioning System (GPS) unit or will be flagged and surveyed. Where feasible, the sample locations will also be marked with a flag, stake, or paint. The soil sample locations are shown in Figure 3. The locations detailed on the figures are approximate and may be adjusted based on field observations. Access to some locations may be restricted due to the ongoing decommissioning activities. 2.3 SAMPLING PROCEDURES A ANALYTICAL PROGRAM Geoprobe Sampling Geoprobe soil samples will be collected under Yankee oversight in compliance with YNPS Procedure DP-8120 Collection of Site Characterization and Site Release Samples. Direct push techniques will be used to push the two-inch diameter core sampler into the subsurface. The hollow two-inch diameter macro-core is pushed by a secondary set of ii The sample depths are to be from existing grade, with the exception of areas where fill has recently been placed or soils have been excavated as part of decommissioning. At locations where fill has been placed, samples will begin at the interface of the new fill and the original grade. At locations where excavations have occurred, the samples will begin at the current grade and a note will be made regarding the estimated depth of the sample location below original grade. ERM 5 YANKEE 2/15/2005

11 solid one-inch diameter rods. The rods/macro-core receive the driving force from the percussion hammer of the Geoprobe. A disposable polyethylene sleeve within the macro-core retains the sample. Once the desired depth is reached, the rods/macro-core are retrieved. The sleeve is removed from the macro-core and the portion of the retrieved soil materials to be sampled is removed from the polyethylene sleeve and the remaining soil materials will be used to backfill the boring. The portion of the core to be submitted for laboratory analysis will be visually inspected and the soil stratigraphy will be classified. Visual observations will be logged on soil sampling forms. Dedicated sampling equipment will be used where feasible. Reused sampling equipment will be decontaminated prior to, and following, sample collection in accordance with the YNPS QAPP Auger Sampling Soil samples will be collected manually using a hand auger to a depth of up to 2 feet bgs at select locations where it is not feasible to use the Geoprobe. Samples will be collected in compliance with YNPS Procedure DP-8120 Collection of Site Characterization and Site Release Samples. Samples will be collected from 0 to 3 inches bgs at all locations, and from 1 to 2 feet bgs at select locations (as listed in Table 2). The portion of the core to be submitted for laboratory analysis will be visually inspected and the soil stratigraphy classified. Visual observations, field observations, and soil stratigraphy description results will be recorded on sample collection logs. 2.4 ANALYTICAL PROGRAM On-Site PCB Screening All soil samples from Study Area 1 and the two upper soil samples (0 to 3 inches and 1 to 2 feet) from all other study areas will be screened on-site for PCBs using the Rapid Assay Test System, manufactured by Strategic Diagnostics Inc., a magnetic particle immunoassay technique. The need for conducting screening on deeper samples will be evaluated based on the results of the screening of the upper two intervals and the existing data. A copy of the user manual for the Rapid Assay Test is provided in Appendix B. YAEC has conducted a site-specific comparison between the screening technique and laboratory data and found them to be suitable for ERM 6 YANKEE 2/15/2005

12 screening purposes (see Appendix C). The screening method should not be used if paint chips are visible in the soil sample PCB Laboratory Analyses Laboratory analysis will be used to confirm that PCB levels are below 1 mg/kg in areas at the site that are not being disturbed by the on-going decommissioning activities. The following soil samples will be submitted for laboratory analysis: All samples with visible paint chips. Soil samples from Study areas 2, 4, and 5 that have reported PCB concentrations less than 1 mg/kg based on the screening method. Other select samples, as deemed appropriate based on the screening results. Select samples not submitted for laboratory analysis will be preserved for potential future analysis by freezing the samples at the site (consistent with Method 8082MCP-Rev 4). Samples will be frozen within 24 hours of collection at less than -10 Celsius. Sampling container should only be filled to 2/3 of capacity to avoid breakage caused by expansion during freezing. Preparation or extraction should be commenced within 24 hours of thawing. Each soil samples will be placed into a 4-ounce sample jar and chilled to 4 Celsius, or less. Soil samples will be submitted for PCB analysis by GC, SW-846 Method 8082, with extraction by Method 3540-C (soxhlet extraction). Northeast Laboratory Services, located in Waterville, Maine, will conduct the analyses. Contact information for the laboratory is as follows: Northeast Laboratories Project Manager: Kelly Perkins PO Box 788 Waterville, Maine Phone: ext. 307 YAEC is in the process of evaluating the use of additional laboratories. If another laboratory is used, the QAPP will be updated, as appropriate. ERM 7 YANKEE 2/15/2005

13 2.4.3 Radiological Parameters Samples at select locations may also be submitted for radiological analysis. The radiological sample program is in the process of being prepared. 2.5 SAMPLE SECURITY A CUSTODY Soil samples will be submitted to the laboratory or YNPS Personnel under proper chain-of-custody procedures. Samples will be preserved on ice or in a refrigerator and sample handling will be documented using chain-ofcustody protocols in accordance with DP-8123, Sample Security and Chain of Custody. 2.6 MANAGEMENT OF INVESTIGATION DERIVED WASTES Soil sampling waste, such as sampling equipment rinse water, will be containerized on-site. The wastes will be screened for radiological constituents. Following screening YNPS personnel will dispose of the wastes in accordance with the applicable YNPS procedures. 2.7 SCEDULE The soil sampling program described is scheduled to begin in February The completion schedule for the soil sampling activities is dependent on field conditions and accessibility to sample locations. Field Sampling Reports should be prepared immediately following sampling to summarize field observations to enable rapid analysis of analytical results upon receipt and expedite decisions regarding further laboratory analyses and the need for additional investigation, if necessary. ERM 8 YANKEE 2/15/2005

14 3.0 QUALITY ASSURANCE A QUALITY CONTROL 3.1 QUALITY ASSURANCE PROJECT PLAN A QAPP has been prepared to provide a standard method of assuring that data collected during site characterization activities is of sufficient quality to support future decisions regarding decommissioning activities and or remedial actions at the site. The primary purpose of the QAPP is to describe the means by which data collected in the field will be validated against predetermined standards, ensuring that data meets minimum quality standards prior to being used for decision-making purposes. The flow of data is important to data quality, as it ensures that appropriate project personnel have adequate opportunities to review data with importance to future site decisions. As such, the QAPP specifies the methods and means for ensuring the data generated during site characterization activities is of a quality necessary to serve its intended purpose. The following provides a list of the sections of the QAPP that are most relevant to the field sampling activities: QAPP Section Topic 9.1 Field Investigation and Documentation Procedures 9.2 Preparation of Sample Containers 9.3 Decontamination 9.4 Field Equipment Usage and Maintenance 10.1 Sample Tracking System 10.2 Sample Custody 13.1 Field Quality Control 3.2 CLEANING A DECONTAMINATION OF EQUIPMENT To the degree possible, dedicated and/or disposable sampling equipment will be used for sampling. Non-dedicated sampling equipment used to ERM 9 YANKEE 2/15/2005

15 collect samples will be cleaned and decontaminated prior to its initial use, between each sampling location and after the final use. The following general procedures will be adhered to concerning decontamination efforts: 1. Non-dedicated sampling equipment will be rinsed with DI water and Alconox to remove visible contamination. A methanol rinse and then a DI water rinse will be used to remove contamination. See the QAPP for specific decontamination procedures. 2. If visual signs such as discoloration indicate that decontamination was insufficient, the equipment will again be decontaminated. If the situation persists, the equipment will be taken out of service until the situation can be corrected. 3. Verification of the non-dedicated sampling equipment cleaning procedures will be documented by the collection of field equipment rinsate blanks, at a frequency in accordance with the QAPP. 4. Properly decontaminated equipment will be stored in aluminum foil or plastic bags during storage and transport. Decontamination protocols will be strictly adhered to in order to minimize the potential for cross-contamination between sampling locations and contamination of off-site areas. Liquids generated during the decontamination process will be collected, containerized and appropriately labeled for disposal. Waste liquids will be stored on site until determination of potential hazard class and final disposition. Only pre-cleaned laboratory-certified sample containers will be used. The laboratories will also provide sample coolers, ice packs, trip blanks, and temperature blanks. More specific decontamination procedures are outlined in the QAPP and SOPs. 3.3 QUALITY ASSURANCE / QUALITY CONTROL SAMPLES The following Quality Assurance / Quality Control samples will be collected during the soil sampling: ERM 10 YANKEE 2/15/2005

16 Temperature blanks One temperature blank per cooler. The temperature of the temperature blank will be measured upon receipt of the cooler at the laboratory. Equipment rinsate blank Manual sampling will be conducted using a hand auger. A rinsate sample will be collected from the hand auger at a rate of one sample per 20 sampling locations. The rinsate blanks will be analyzed for the same parameters as the samples that were collected using the equipment. Field duplicates Field duplicates will be collected at the rate of one duplicate per 20 samples. Samples locations where duplicates will be collected will be determined in the field. Field duplicates will be submitted for the same analyses as the actual sample. To the extent practicable, field duplicate samples are predetermined and target the highest analytical results from previous soil investigations. A field duplicate will be collected for each analysis detailed in this FSP. Matrix spikes Matrix spikes will be collected at the rate of one matrix spike per 20 samples. Samples locations where matrix spikes will be collected will be determined in the field. Matrix spike/matrix spike duplicates (MS/MSDs) will be collected for organic parameters. Matrix spike/matrix duplicates (MS/MD) will be collected for inorganic and wet chemistry analyses. ERM 11 YANKEE 2/15/2005

17 4.0 PROJECT DOCUMENTATION Data management tasks pertinent to project documentation and records, laboratory deliverables, data reporting formats, data handling and management, and data review assessment are presented in the QAPP. The following field sample collection records will be completed at the time of sample collection and documented in a Field Sampling Report: Sample location identification Soil stratigraphy Observations of any notable conditions encountered in materials retrieved (e.g., presence of visible paint chips) Modifications to the FSP GPS coordinates and a map indicating approximate locations COC forms will be completed post sampling by the field sampling team. Within 24 hours of COC completion, copies of the COCs will be faxed to the following people. Kim Reed Gradient Corporation, (617) Andy Coenen ERM, (631) Jeremy Picard ERM, (617) The project documentation will be provided to the Yankee Environmental Oversight Supervisor (Deanne Stefanovich) at the completion of each sampling event. In addition, any deviations from the FSP will be documented in a memorandum to the Yankee Environmental Operations Manager (Marynette erndon). The Yankee Environmental Oversight Supervisor will forward copies of the project documentation, the Field Sampling Report to Jeremy Picard (ERM). ERM 12 YANKEE 2/15/2005

18 Table 1 PCB Soil Results Yankee Nuclear Power Station Rowe, MA Station Sample ID Date Depth Aroclor-1254 Aroclor-1260 Total PCBs (mg/kg) (mg/kg) (mg/kg) YRDTS-001 YRDTS /18/ " 0.2 U 0.2 U YRDTS-002 YRDTS /18/ " U 0.2 YRDTS-003 YRDTS /18/ " 0.2 U 0.2 U YRDTS-004 YRDTS /18/ " 0.2 U 0.2 U YRDTS /24/ " U 4.7 YRDTS /20/ " 42 4U 42 YRDTS RE 11/20/ " 40 4U 40 YRDTS-005 YRDTS-005A 0-2 in 11/11/ " U 47 YRDTS-005A-Dup-1 11/11/ " U 39 YRDTS-005B 2-4 in 11/11/ " U 42 YRDTS-005C 6-12 in 11/11/ " U 1.4 YRDTS-005D in 11/11/ " YRDTS /20/ " U 1.7 YRDTS-006A 10/24/ " U 11 YRDTS-006B 10/24/ " U 0.4 YRDTS-006 YRDTS-006A 0-2 in 11/11/ " U 1.4 YRDTS-006A-DUP in 11/11/ " U 1.1 YRDTS-006B 2-4 in 11/11/ " U YRDTS-006C 6-12 in 11/11/ " 0.04 U 0.04 U YRDTS-006D in 11/11/ " 0.04 U 0.04 U YRDTS-007 YRDTS /24/ " U 1.1 YRDTS-008 YRDTS /24/ " 0.2 U 0.2 U YRDTS-009 YRDTS /24/ " U 0.3 YRDTS-010 YRDTS /24/ " 0.2 U 0.2 U YRDTS-011 YRDTS /24/ " 0.2 U 0.2 U YRDTS-12 YRDTS-12 10/24/ " 0.2 U 0.2 U YRDTS-13 YRDTS-13 10/24/ " U 0.7 YRDTS-14 YRDTS-15 YRDTS-14 YRDTS-15A 10/24/ /24/ " 0-2" U 0.2 U 0.2 U 2.6 YRDTS YRDTS-15B 11/20/ /24/ " 4-6" U 0.2 U 0.2 U 0.22 YRDTS /15/ " U 1.4 YRDTS /20/ " U 12 YRDTS-016A 11/15/ " U 2.4 YRDTS-016 YRDTS-016A 0-2 in 11/11/ " U 1.5 YRDTS-016B 2-4 in 11/11/ " U 2.6 YRDTS-016C 6-12 in 11/11/ " U 0.34 YRDTS-016D in 11/11/ " U YRDTS-017 YRDTS /15/ " U 2.8 YRDTS /20/ " U 0.85 YRDTS /15/ " U 2.5 YRDTS-018A 0-2 in 11/11/ " U 1.8 YRDTS-018 YRDTS-018B 2-4 in 11/11/ " YRDTS-018C 6-12 in 11/11/ " YRDTS-018D in 11/11/ " YRDTS-019 YRDTS-020 YRDTS-019 YRDTS /15/ /20/ " 0-2" J 0.2 U 0.2 U YRDTS YRDTS /20/ /20/ " 4-6" U 0.2 U YRDTS-021 YRDTS /20/ " 0.69 J 0.2 U 0.69 YRDTS /20/ " U 240 YRDTS RE 11/20/ " U 240 YRDTS /20/ " 76 4U 76 YRDTS-022 YRDTS-022A 0-2 in 11/11/ " U 120 YRDTS-022A Dup /11/ " U 27 YRDTS-022B 2-4 in 11/11/ " U 18 YRDTS-022C 6-12 in 11/11/ " YRDTS-022D in 11/11/ " U 2 Page 1 of 6

19 Table 1 PCB Soil Results Yankee Nuclear Power Station Rowe, MA Station Sample ID Date Depth Aroclor-1254 Aroclor-1260 Total PCBs (mg/kg) (mg/kg) (mg/kg) YRDTS /20/ " U 1 YRDTS /20/ " U 3 YRDTS-023 YRDTS-023A 0-2 in 11/11/ " U 4.3 YRDTS-023B 2-4 in 11/11/ " U 2.2 YRDTS-023C 6-12 in 11/11/ " YRDTS-023D in 11/11/ " YRDTS-024 YRDTS /20/ " 2.9 J 0.2 U 2.9 YRDTS /20/ " U 0.85 YRTDS-025 YRDTS /16/ " 0.78 U 0.78 U YRTDS-026 YRDTS /16/ " U 1.3 YRTDS-027 YRDTS /16/ " U 0.24 YRTDS-028 YRDTS /16/ " U 1.2 YRTDS-029 YRDTS /16/ " U 0.45 YRTDS-030 YRDTS /16/ " 0.6 U 0.6 U YRDTS-031 YRDTS-032 YRDTS-033 YRDTS-034 YRDTS-035 YRDTS-036 YRDTS-037 YRDTS-038 YRDTS-039 YRDTS-040 YRDTS-041 YRDTS-042 YRDTS-043 YRDTS-044 YRDTS-045 YRDTS-046 YRDTS-047 YRDTS-048 YRDTS-049 YRDTS-050 YRDTS-051 YRDTS-031A 0-2 in YRDTS-032A 0-2 in YRDTS-033A 0-2 in YRDTS-034A 0-2 in YRDTS-035A 0-2 in YRDTS-036A 0-2 in YRDTS-037A 0-2 in YRDTS-038A 0-2 in YRDTS-039A 0-2 in YRDTS-040A 0-2 in YRDTS-041A 0-2 in YRDTS-042A 0-2 in YRDTS-043A 0-2 in YRDTS-044A 0-2 in YRDTS-045A 0-2 in YRDTS-046A 0-2 in YRDTS-047A 0-2 in YRDTS-048A 0-2 in YRDTS-049A 0-2 in YRDTS-050A 0-2 in YRDTS-051A 0-2 in 11/11/ /11/ /5/ /5/ /5/ /5/ /5/ /4/ /4/ /5/ /5/ /5/ /5/ /11/ /11/ /11/ /11/ /5/ /5/ /5/ /11/ " 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" 0-2" U U U U U 0.04 U 0.36 U 0.04 U 0.2 U U U 0.04 U 0.04 U U 0.27 U U U 0.36 U 0.04 U 0.04 U U YRDTS-031B 2-4 in YRDTS-032B 2-4 in YRDTS-033B 2-4 in YRDTS-034B 2-4 in YRDTS-035B 2-4 in YRDTS-036B 2-4 in YRDTS-037B 2-4 in YRDTS-038B 2-4 in YRDTS-039B 2-4 in YRDTS-040B 2-4 in YRDTS-041B 2-4 in YRDTS-042B 2-4 in YRDTS-043B 2-4 in YRDTS-044B 2-4 in YRDTS-045B 2-4 in YRDTS-046B 2-4 in YRDTS-047B 2-4 in YRDTS-048B 2-4 in YRDTS-049B 2-4 in YRDTS-050B 2-4 in YRDTS-051B 2-4 in 11/11/ /11/ /5/ /5/ /5/ /5/ /5/ /4/ /4/ /5/ /5/ /5/ /5/ /11/ /11/ /11/ /11/ /5/ /5/ /5/ /11/ " 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" 2-4" U U U 0.4 U 0.04 U 0.04 U U U 0.04 U U 0.04 U U U 0.04 U 0.04 U 0.36 U Page 2 of 6

20 Table 1 PCB Soil Results Yankee Nuclear Power Station Rowe, MA Station Sample ID Date Depth Aroclor-1254 Aroclor-1260 Total PCBs (mg/kg) (mg/kg) (mg/kg) SB001 SB I 10/23/ U SB F 10/22/ ' 0.04 U SB002 SB I 10/22/ SB003 SB I 10/22/ U SB004 SB I 10/22/ U 0.13 SB005 SB I 9/7/ U U SB006 SB I 9/7/ U U SB007 SB I 9/7/2004 SB008 SB I 10/22/ SB009 SB I 10/20/ U SB010 SB I 9/7/ U U SB011 SB I 9/7/ U U FD /7/ U U SB012 SB I 10/22/ J U SB013 SB I 10/20/ U 0.14 SB014 SB015 SB016 SB017 SB018 SB I SB I SB I SB I SB I 9/8/2004 9/9/ /19/2004 9/9/ /22/ U U U U U U U SB F SB F SB F SB F SB F 9/8/2004 9/9/ /19/2004 9/9/ /22/ ' 2-3' 2-3' 2-3' 2-3' U U U J U U U U U SB019 SB I 10/20/ U 0.52 SB020 SB I 10/22/ SB021 SB I 9/9/ U 0.17 SB F 9/9/ ' U U SB I 10/20/ U 0.68 SB022 FD /20/ U 1.1 SB F 10/20/ ' 0.04 U 0.04 U SB023 SB024 SB I SB I 9/8/ /7/ U U U 0.82 SB F SB F 9/8/ /7/ ' 2-3' U U U U SB025 SB I 10/22/ U U SB026 SB027 SB I SB I 10/22/ /22/ SB F SB F 10/22/ /22/ ' 1-2' U SB028 SB I 12/2/ U U SB029 SB I 10/19/ U 0.32 SB F 10/19/ ' U 0.28 SB030 SB I 10/22/ SB031 SB I 10/22/ U 0.18 SB032 SB I 10/20/ U 2.5 SB033 SB034 SB035 SB036 SB I SB I SB I SB I 10/22/2003 9/8/ /20/2003 9/8/ U SB F SB F SB F SB F 10/22/2003 9/8/ /20/2003 9/8/ ' 2-3' 1-2' 2-3' U U U U 0.15 SB I 10/7/ U SB037 SB F 10/7/ ' SB F 10/7/ ' U U SB I 12/2/ U U SB038 SB F 12/2/ ' U U SB F 12/2/ ' U U SB039 SB040 SB I SB I 10/24/ /1/ U U U SB F SB F 10/24/ /1/ ' 2-3' U U U U Page 3 of 6

21 Table 1 PCB Soil Results Yankee Nuclear Power Station Rowe, MA Station Sample ID Date Depth Aroclor-1254 Aroclor-1260 Total PCBs (mg/kg) (mg/kg) (mg/kg) SB I 10/7/ U 0.15 SB041 SB F 10/7/ ' U 0.54 FD /7/ ' U 0.36 SB F 10/7/ ' SB I 10/24/ U 2.6 SB042 SB F 10/24/ ' U 0.66 SB F 10/24/ ' U SB044 SB045 SB046 SB047 SB048 SB049 SB050 SB I SB I SB I SB I SB I SB I SB I 9/8/ /2/2004 9/30/2004 9/30/ /30/ /30/ /24/ U U SB F SB F SB F SB F SB F SB F SB F 9/8/ /2/2004 9/30/2004 9/30/ /30/ /30/ /24/ ' 2-3' 5-6' 2-3' 2-3' 2-3' 2-3' U U U U U U U SB051 SB I 10/16/ U U SB052 SB I 12/2/ U U SB053 SB I 9/8/ SB F 9/8/ ' U U SB I 10/30/ U U SB054 SB F 10/30/ ' U U SB F 10/30/ ' U U SB I 9/7/ SB056 SB F 9/7/ ' SB F 9/7/ ' U U SB057 SB I 10/30/ J U SB I 10/30/ SB058 SB F 10/30/ ' SB F 10/30/ ' SB059 SB I 10/30/ U U SB060 SB I 10/30/ SB F 10/30/ ' SB063 SB F 9/30/ ' U U SB064 SB F 9/30/ ' SB065 SB F 9/30/ ' SB073 SB I 11/16/ U U SB074 SB I 9/8/ U SB F 9/8/ ' U U SB075A SB075A-0006I 12/1/ U U SB075A-0203F 12/1/ ' U 0.12 SB075B SB075B-0006I 12/2/ U SB075B-0203F 12/2/ ' U SB076 SB I 12/2/ U 1.6 SB I 9/27/ U 0.52 SB I A 10/6/ U 2.1 SB I B 10/6/ U 0.24 SB078 SB I C 10/6/ U 1.1 SB I A 10/6/ " U SB I C 10/6/ " U 0.2 SB I B 10/6/ " U SB079 SB I 10/24/ U U SB080 SB I 11/30/ U SB081 SB I 12/2/ U SB082 SB I 12/2/ U SB084 SB I 10/16/ SB085 SB I 10/19/ U U SB086 SB I 10/17/ U 0.20 SB087 SB088 SB I SB I 10/20/ /20/ U SB F SB F 10/20/ /20/ ' 1-2' Page 4 of 6

22 Table 1 PCB Soil Results Yankee Nuclear Power Station Rowe, MA Station Sample ID Date Depth Aroclor-1254 Aroclor-1260 Total PCBs (mg/kg) (mg/kg) (mg/kg) SB089 SB090 SB I SB I 10/20/ /20/ U SB F SB F 10/20/ /20/ ' 1-2' U U 0.12 SB091 SB I 10/24/ U U SB I 10/17/ U U SB092 SB F 10/17/ ' U 3.1 SB F 10/17/ ' U U SB I 10/17/ U U SB093 FD /17/ U U SB F 10/17/ ' U U SB F 10/17/ ' U U SB094 SB I 10/20/ U SB F 10/20/ ' U U SB I 10/24/ U SB095 SB F 10/24/ ' U U SB F 10/24/ ' U U SB096 SB I 9/9/ U U SB F 9/9/ ' U U SB097 SB I 11/30/ U 0.26 SB100 SB I 10/21/ SB101 SB I 10/21/ J 0.04 U SB F 10/21/ ' J 0.04 U SB102 SB I 10/21/ SB103 SB I 10/21/ J U SB104 SB105 SB I SB I 10/21/ /21/ U FD SB F 10/21/ /21/ ' J 0.04 U 0.04 U SB106 SB I 10/21/ U 0.15 SB107 SB I 10/21/ SB108 SB I 10/21/2003 SB109 SB I 10/20/2003 SB F 10/20/ ' SB110 SB I 10/20/ SB111 SB I 10/20/ SB112 SB I 10/20/2003 SB113 SB114 SB115 SB116 SB117 SB118 SB I SB I SB I SB I SB I SB I 10/20/ /16/ /16/ /15/ /15/ /15/ U U 0.04 U U U FD SB F SB F SB F SB F SB F 10/20/ /16/ /16/ /15/ /15/ /15/ ' 1-2' 2-3' 1-2' 1-2' J 0.04 U U U 0.04 U 0.04 U U U SB122 SB F 10/28/ ' SB123 SB F 10/28/ ' SB124 SB F 10/28/ ' SB125 SB F 10/28/ ' U U SB126 SB F 10/28/ ' J 0.04 U SB127 SB F 10/28/ ' SB128 SB /14/2003 SB129 SB /14/ U Page 5 of 6

23 Table 1 PCB Soil Results Yankee Nuclear Power Station Rowe, MA Station Sample ID Date Depth Aroclor-1254 Aroclor-1260 Total PCBs (mg/kg) (mg/kg) (mg/kg) SB130 SB /14/ SB131 SB /14/ U U SB139 SB141 SB143 SB I SB I SB I 10/23/ /16/ /16/ U 0.04 U SB F SB F SB F 10/23/ /16/ /16/ ' 2-3' 1-2' J SB I 10/23/2003 SB145 SB F 10/23/ ' U U FD /23/ ' U U SB152 SB153 SB154 SB I SB I SB I 10/15/ /15/ /15/ U SB F SB F SB F 10/15/ /15/ /15/ ' 2-3' 1-2' U U SB156 SB I 10/28/2003 SB157 SB I 10/28/2003 SB158 SB I 10/28/2003 SB159 SB I 10/28/2003 SB904 SB F 11/7/ ' U 0.10 SB F 11/7/ ' U SB F 11/7/ ' U 0.46 SB908 SB F 11/7/ ' U U SB F 11/7/ ' U 0.13 SB F 11/7/ ' U 0.20 SB912 SB F 11/7/ ' U 3.5 SB F 11/7/ ' U 0.19 SB F 11/7/ ' U U SB913 SB F 11/7/ ' U U SB F 11/7/ ' U 2.1 SB F 11/7/ ' U SB914 SB F 11/7/ ' U U SB F 11/7/ ' U SB F 11/7/ ' U SB915 SB F 11/7/ ' U U SB F 11/7/ ' U U SB F 11/7/ ' U 0.14 SB916 SB F 11/7/ ' U 0.15 SB F 11/7/ ' U SB F 11/7/ ' U U SB917 SB F 11/7/ ' U U SB F 11/7/ ' U U SB F 11/7/ ' U U SB F 11/7/ ' U U SB F 11/7/ ' U U SB918 SB F 11/7/ ' U U SB F 11/7/ ' U U SB F 11/7/ ' U U SB F 11/7/ ' U U Alley 1 Alley 2 Alley 3 Alley 4 Alley 5 Alley 6 Alley 1-0 in Alley 2-0 in Alley 3-0 in Alley 4-0 in Alley 5-0 in Alley 6-0 in 11/22/ /22/ /22/ /22/ /22/ /22/2004 0" 0" 0" 0" 0" 0" U U U U U U Alley 1-6 in Alley 2-6 in Alley 3-6 in Alley 4-6 in Alley 5-6 in Alley 6-6 in 11/22/ /22/ /22/ /22/ /22/ /22/2004 6" 6" 6" 6" 6" 6" U U U U U U PAB-001 PAB I 10/16/ U 0.29 PAB-002 PAB I 10/16/ U 0.16 PAB-003 PAB I 10/16/ PAB I 10/16/ PAB-005 PAB I 10/16/ " PAB I 10/16/ " Notes: U= Below Detection Limit J= Estimated Value Page 6 of 6

24 Table 2 Soil PCB Analytical Program Yankee Nuclear Power Station Rowe, MA Study Area Field Sample ID PCB Comment Study Area 1 SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB F SB F SB I Note depth below original grade SB F SB F SB F SB I Note depth below original grade SB F SB F SB F Page 1 of 7

25 Table 2 Soil PCB Analytical Program Yankee Nuclear Power Station Rowe, MA Study Area Field Sample ID PCB Comment Study Area 1 SB I Note depth below original grade SB F SB F SB F SB I Note depth below original grade SB F SB F SB F SB I Note depth below original grade SB F SB F SB F SB I Note depth below original grade SB F SB F SB F SB I Note depth below original grade SB F SB F SB F SB I Note depth below original grade SB F SB F SB F SB I Note depth below original grade SB F SB F SB F SB I SB F SB F SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F Page 2 of 7

26 Table 2 Soil PCB Analytical Program Yankee Nuclear Power Station Rowe, MA Study Area Field Sample ID PCB Comment Study Area 1 SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F Study Area 2 SB I SB I SB I SB I SB I SB I SB F SB I SB I SB I SB I SB I SB I SB I Page 3 of 7

27 Table 2 Soil PCB Analytical Program Yankee Nuclear Power Station Rowe, MA Study Area Field Sample ID PCB Comment Study Area 2 SB I SB F SB I SB I SB I SB I Replicate of YRDTS-020 SB I SB I SB I Replicate of YRDTS-043 SB I SB F SB I SB F SB I SB F SB I SB F SB I SB F SB I SB F SB I SB F SB I SB I SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F Study Area 3 SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F Page 4 of 7

28 Table 2 Soil PCB Analytical Program Yankee Nuclear Power Station Rowe, MA Study Area Field Sample ID PCB Comment Study Area 3 SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F Page 5 of 7

29 Table 2 Soil PCB Analytical Program Yankee Nuclear Power Station Rowe, MA Study Area Field Sample ID PCB Comment Study Area 3 SB I SB F SB F SB F SB I Replicate of SB092 SB F SB F SB F Study Area 4 SB I SB F SB F SB F SB I All depths tested to delineate vertical extent SB F SB F SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F Page 6 of 7

30 Table 2 Soil PCB Analytical Program Yankee Nuclear Power Station Rowe, MA Study Area Field Sample ID PCB Comment Study Area 5 Notes: - PCB sample to be tested - PCB sample to be held SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB F SB F SB I SB F SB I SB F SB I SB F SB I SB F SB I Replicate of SB026 SB F Page 7 of 7

31 N SITE YAEC Property Boundary 0.5 km 0.5 mi Scale 1:25, m 0 1,000 ft Figure 1 - Locus Map Yankee Nuclear Power Station - Rowe, MA R:\Yankee Atomic\Locus Map.fh11 (15-January-2004 Boston)

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34 Appendix A Gradient Memorandum on Sampling

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43 Appendix B Rapid Assay Instructions

44 STRATEGIC DIAGNOSTICS INC. RaPID Assay PCB Test Kit A00133/A00134 Intended Use The RaPID Assay PCB Test Kit can be used as a quantitative, semi-quantitative or qualitative enzyme immunoassay (EIA) for the analysis of PCB (polychlorinated biphenyl) in water (groundwater, surface water, well water). For applications in other matrices please contact our Technical Service department or refer to the soil application procedure provided. The RaPID Assay PCB Test Kit allows reliable and rapid screening for PCB (measured and reported as Aroclor 1254), with quantitation between 0.5 and 10 ppb (as Aroclor 1254), in water. The minimum detection level of the kit is 0.2 ppb (as Aroclor 1254.) Test Principles The PCB RaPID Assay kit applies the principles of enzyme linked immunosorbent assay (ELISA) to the determination of PCB and related compounds. The sample to be tested is added, along with an enzyme conjugate, to a disposable test tube, followed by paramagnetic particles with antibodies specific to PCB attached. Both PCB (which may be in the sample) and the enzyme labeled PCB (the enzyme conjugate) compete for antibody binding sites on the magnetic particles. At the end of an incubation period, a magnetic field is applied to hold the paramagnetic particles (with PCB and labeled PCB analog bound to the antibodies on the particles, in proportion to their original concentration) in the tube and allow the unbound reagents to be decanted. After decanting, the particles are washed with Washing Solution. The presence of PCB is detected by adding the enzyme substrate (hydrogen peroxide) and the chromogen (3,3,5,5 tetramethylbenzidine). The enzyme labeled PCB analog bound to the PCB antibody catalyzes the conversion of the substrate/chromogen mixture to a colored product. After an incubation period, the reaction is stopped and stabilized by the addition of acid. Since the labeled PCB (conjugate) was in competition with the unlabeled PCB (sample) for the antibody sites, the color developed is inversely proportional to the concentration of PCB in the sample. NOTE: Color development is inversely proportional to the PCB concentration. Darker color = lower concentration Lighter color = higher concentration The determination of the PCB level in an unknown sample is interpreted relative to the standard curve generated from kit standards after reading with a spectrophotometer. Performance Characteristics The PCB RaPID Assay will detect different PCB Aroclors to different degrees. Refer to the table below for data on several of these. The PCB RaPID Assay kit provides screening results. As with any analytical technique (GC, PLC, etc. ) positive results requiring some action should be confirmed by an alternative method. The PCB RaPID Assay immunoassay test does not differentiate between PCB and other related compounds. The table below shows compounds at the method detection limit (MDL) which is the lowest concentration of the compound, in water, that can be picked up in the assay. The limit of quantitation (LOQ) is an approximate concentration, in water, required to yield a positive result at the lowest standard. This is the lowest concentration of the compound that can be quantified in the assay. The IC50 is the concentration required to, inhibit one half of the color produced by the negative control. It is also used to calculate cross-reactivity values to similar compounds. Compound MDL (ppb) LOQ (ppb) IC50 (ppb) Aroclor Aroclor Aroclor Aroclor Aroclor Aroclor

45 2 RaPID Assay PCB Test Kit Aroclor Aroclor Aroclor *The following compounds demonstrated no reactivity in the PCB RaPID Assay test kit at concentrations up to 10,000 ppb: Biphenyl, 2,5-Dichlorophenol, 2,3,5- Trichlorophenol, Di-n-octyl-phthalate. The presence of the following substances up to 250 ppm were found to have no significant effect on PCB RaPID Assay results: copper, nickel, zinc, mercury, manganese, phosphate, sulfate, sulfite, magnesium, calcium, nitrate and thiosulfate. umic acid up to 25 ppm and iron to 100 ppm were found to have no significant effect. In addition, sodium chloride concentrations up to 1.0 M showed no effect on results. Precautions Training is strongly recommended prior to using the RaPID Assay test system. Contact Strategic Diagnostics for additional information. Treat PCB, solutions that contain PCB, and potentially contaminated samples as hazardous materials. Use gloves, proper protective clothing, and methods to contain and handle hazardous material where appropriate. Reagents must be added in a consistent manner to the entire rack. A consistent technique is the key to optimal performance. Be sure to treat each tube in an identical manner. Water samples should be at a neutral p prior to analysis. Samples containing gross particulate should be filtered (e.g. 0.2 um Anotop TM 25 Plus, Whatman, Inc.) to remove particles. Store all test kit components at 2 C to 8 C (36 F to 46 F). Storage at ambient temperature (18 C to 27 C or 64 F to 81 F) on the day of use is acceptable. Test tubes require no special storage and may be stored separately to conserve refrigerator space. Allow all reagents to reach ambient temperature (18 C to 27 C or 64 F to 81 F) before beginning the test. This typically requires at least 1 hour to warm from recommended storage conditions. Do not freeze test kit components or expose them to temperatures above 100 F (39 C). Do not use test kit components after the expiration date. Do not use reagents or test tubes from one test kit with reagents or test tubes from a different test kit. Do not mix reagents from kits of different lot numbers. Use approved methodologies to confirm any positive results. Do not under any circumstances attempt to disassemble the base of the magnetic rack. Magnets will be violently attracted to each other. Adequate sample number and distribution are the responsibility of the analyst. The photometer provided in the accessory kit requires electricity and comes with a 110V adapter. Adapters for 220V are available. Do not attempt to operate with a car adaptor. Do not expose color solution to direct sunlight. Do not dilute or adulterate test reagents or use samples not called for in the test procedure; this may give inaccurate results. Tightly recap the standard vials when not in use to prevent evaporative loss. Materials Provided Antibody Coupled Paramagnetic Particles in buffered saline containing preservative and stabilizers. 30 test kit: one 20 ml vial 100 test kit: one 65 ml vial Enzyme Conjugate. 30 test kit: one 10 ml vial 100 test kit: one 35 ml vial Standards Three concentrations (0.25, 1.0 and 5.0 ppb) of PCB standards (as Aroclor 1254) in buffered saline