ML053070546

Response to Questions Dated October 26, 2005 Concerning Decommissioning Plan for the Ward Center for Nuclear Studies at Cornell University, Triga Reactor

ML053070546
Person / Time
Site:	05000157, 05000097
Issue date:	10/26/2005
From:	Fay C Cornell Univ
To:	Document Control Desk, NRC/FSME
References
Download: ML053070546 (3)

Text

Cornell University Office of the Vice Provost for Research 222 Day Hall Ithaca, New York 14853-2801

t. 607.255.7200

f. 607.255.9030 www.research.comell.edu / VPR October 26, 2005 Document Control Desk U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738

SUBJECT:

Response to Questions Dated October 26, 2005 Concerning Decommissioning Plan for the Ward Center for Nuclear Studies at Cornell University, TRIGA Reactor, Docket No 50-157, License R-80 and the ZPR, Docket No. 50-97, License R-89

Dear Mr. Hughes:

Attached to this letter are Cornell's responses to your question posed by e-mail, dated October 26, 2005, related to the Decommissioning Plan (DP) for the Ward Center for Nuclear Studies at Cornell University, Revision 1, July 2003 (DP) for Facility Operating Licenses No. R-80 and R-89 for the Cornell University Reactors, as originally submitted to your office in August, 2003.

Please review this response and advise us of any additional information or clarification that you require.

By my signature belowv, I hereby affirm that I am authorized to represent Cornell University in these matters and that the statements made in these responses are true and accurate to the best of my knowledge and belief.

Charles R. Fay 6

Vice Provost for Research Administration TRIGA D&D Project Director cc.

D. Hughes Enc.

Attachment A (Response to Question - 2 pages)

- oal"D Cornell University is an equal opportunity, affirmative action educator and employer.

Attachment A:

Responses to Question Sent by E-mail, October 26, 2005, regarding, Cornlell University Research Reactors, Docket No. 0-157/9 7 Question:

The Cornell Decommissioning Plan Appendix B, Environmental Report, Section 3.2.3.2 says that surface (water) run-off from Ward Center currently flows primarily south, across paved and unpaved surfaces to the Cascadilla Creek Gorge. In section 3.2.4.4, the report says a protected endangered salamander lives in the gorge adjacent to the site according to the New York Department of Environmental Conservation database. Please discuss the mitigative strategies that you plan to implement, during the decommissioning process, to prevent any deleterious impact on the habitat of the endangered salamander.

Response

The information as reported in Appendix B, Section 3.2.4.4 Endangered or Threatened Federal or State Species, is in error. The only salamander on the New York Department of Environmental Conservation (NYSDEC) electronic database listed as endangered or threatened is the Tiger Salamander, which is found only on Long Island (with two additional reported sightings in the Albany area from the 1830's, but not since).

Cornell naturalists have identified two salamander varieties, the Jefferson Salamander and the Spotted Salamander, in an area of the Fall Creek Gorge. Fall Creek Gorge also runs through Cornell's campus, but is a separate watershed that is not connected to the Cascadilla Gorge. While neither species is Threatened or Endangered, the NYSDEC lists these salamander types as being of "Special Concern", which is a less serious category that includes such relatively common species as the Hellbender, the Eastern Box Turtle, and the Common Loon. In any case, to the best of our knowledge and belief, these species have never been identified in the Cascadilla Creek gorge. Cornell recently completed a similar assessment of Cascadilla Creek in connection with the planned replacement of the gorge crossing footbridge immediately adjacent to the Ward Center and confirmed with State regulators during that process that no Endangered, Threatened, or Special Concern animal species were known to inhabit the Cascadilla Gorge.

Also, to clarify, Figure B-12, included on page 24 of 35 of Appendix B, was altered from the original figure included on the NYSDEC website, which does not specifically identify Cornell as a site of known rare animals. The addition of the "Cornell" label was provided to indicate the approximate location of the campus within the State map and does not indicate that the State has specifically listed Cornell as such a site.

Although no threatened or endangered animals are known to inhabit Cascadilla Gorge and no ground disturbance to the exterior of the building is anticipated to occur as a result of this project, with the possible exception of any required soil sampling activities, Cornell has included in the proposed decommissioning project the requirement for the preparation and implementation of a site-specific erosion and sediment control plan. As Specified in the procurement documents for these services, this Plan is required to meet

the following performance requirements:

"At 1o time shall constnrction operations or any related disturbance of the site result in thte in pairnlent of local vatervays. "Impairment" is defined by regulations as inicluding, but not limited to, the following:

1.

The release of water into receiving waters that causes a substantial visible contrast to natural conditions; or

2.

The deposition of significant sediment into such waters."

Typical measures to ensure this protection include the use of silt curtains installed down-gradient from any area of exterior materials storage or disturbance, the use of rock-filter bags around storm sewers, and similar controls.

In addition to specifying this language, Cornell employs a full-time field inspector on campus to check compliance with local, State, and National storm water pollution prevention requirements. This inspector, who works within the Environmental Compliance Office at Cornell (the same office managing the Decommissioning), will perform routine inspections of the site during the work to check for a variety of compliance issues, and especially to ensure that the adjacent gorge is protected appropriately during the work.

In summary, the combination of no known endangered or threatened species, limited exterior work, and suitable protective measures combine to ensure that no significant impact to threatened or endanger species from the Decommissioning work.

Letter: Attachument A Response to 10-26-05 Question, Cornell Decominissioning Plan Page 2 of 2