ML060270501

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Request for Additional Information Concerning Decommissioning Plan for the Ward Center for Nuclear Studies at Cornell University, Triga Reactor
ML060270501
Person / Time
Site: 05000157, 05000097
Issue date: 02/03/2006
From: Hughes D
NRC/NRR/ADRA/DPR/PRTA
To: Fay C
Cornell Univ
Hughes D, NRR/DPR/PRT, 301-415-1631
References
TAC MC1141
Download: ML060270501 (5)


Text

February 3, 2006 Dr. Charles R. Fay Vice Provost for Research Administration Cornell University 314 Day Hall Ithaca, NY 14853-2801

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION 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 (TAC NO. MC1141)

Dear Dr. Fay:

We are reviewing your Revision 1, July 2003 Decommissioning Plan (DP) for the Ward Center for Nuclear Studies at Cornell University for Facility Operating Licenses No. R-80 and R-89 for the Cornell University Reactors. The DP was submitted on August 22, 2003, and changes were proposed in your response dated May 13, 2005, to the Nuclear Regulatory Commissions (NRC) request for additional information (RAI), dated March 28, 2005. During our review of your response, a question has arisen for which we require additional information and clarification. Please provide a response to the enclosed request for additional information within 60 days of the date of this letter. In accordance with 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of the additional information, we will continue our evaluation of your amendment request.

If you have any questions regarding this RAI, please contact me at 301-415-1631.

Sincerely,

/RA/

Daniel E. Hughes, Project Manager Research and Test Reactor Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket Nos. 50-157/97

Enclosure:

As stated cc w/enclosure: See next page

Cornell University Docket Nos. 50-157/97 cc:

Dr. Joseph Burns, Vice Provost for Physical Sciences and Engineering Cornell University 314 Day Hall Ithaca, NY 14853-2801 Barbara Youngberg Chief, Radiation Section NYS Dept. of Environmental Conservation 625 Broadway Albany, NY 12233-7255 Mr. Howard C. Aderhold Ward Center for Nuclear Sciences Cornell University 105 Ward Laboratory Ithaca, NY 14853 Mr. John P. Spath NYS Energy Research and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Thomas McGiff, RSO 125 Humphreys Service Building Ithaca, NY 14853 Steve Beyers, P.E.

Cornell Decommission Project Manager Cornell University Environmental Compliance Offices 129 Humphreys Service Building Ithaca, NY 14853 Dr. William Vernetson Director of Nuclear Facilities Department of Nuclear Engineering Sciences University of Florida 202 Nuclear Sciences Center Gainesville, FL 32611

February 3, 2006 Dr. Charles R. Fay Vice Provost for Research Administration Cornell University 314 Day Hall Ithaca, NY 14853-2801

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION 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 (TAC NO. MC1141)

Dear Dr. Fay:

We are reviewing your Revision 1, July 2003 Decommissioning Plan (DP) for the Ward Center for Nuclear Studies at Cornell University for Facility Operating Licenses No. R-80 and R-89 for the Cornell University Reactors. The DP was submitted on August 22, 2003, and changes were proposed in your response dated May 13, 2005, to the Nuclear Regulatory Commissions (NRC) request for additional information (RAI), dated March 28, 2005. During our review of your response, a question has arisen for which we require additional information and clarification. Please provide a response to the enclosed request for additional information within 60 days of the date of this letter. In accordance with 10 CFR 50.30(b), your response must be executed in a signed original under oath or affirmation. Following receipt of the additional information, we will continue our evaluation of your amendment request.

If you have any questions regarding this RAI, please contact me at 301-415-1631.

Sincerely,

/RA/

Daniel E. Hughes, Project Manager Research and Test Reactor Branch Division of Policy and Rulemaking Office of Nuclear Reactor Regulation Docket No. 50-157/97

Enclosure:

As stated cc w/enclosure: See next page DISTRIBUTION:

PUBLIC PRT/R&TR r/f AAdams CBassett PDoyle TDragoun WEresian DHarrison DHughes EHylton PIsaac KWitt MMendonca JQuichocho WSchuster MVoth PYoung WKennedy GHill (2) Ho Nieh CGrimes RidsNrrDprPrta RidsOgcMailCenter ACCESSION NO: ML060270501 TEMPLATE NO: NRR-106 OFFICE PRTA:PM PRTA:LA PRTA:BC NAME DHughes EHylton BThomas DATE 1/31/2006 1/30/2006 2/2/2006 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION CORNELL UNIVERSITY RESEARCH REACTORS DOCKET NO. 50-157/97 The RAI was as follows:

DP, Page 26 of 73, Section 2.3.1.1.3.1 Disposition of Decommissioning Equipment and Materials and Section 4.1.2, page 64 of 73 RG 1.86, Termination of Operating Licenses for Nuclear Reactors, June 1974 described methods and procedures considered acceptable by the Regulatory staff for the termination of operating licenses for nuclear reactors. NUREG 1575, MARSSIM, provides information on planning, conducting, evaluating, and documenting building surface and surface soil final status radiological surveys for demonstrating compliance with dose or risk-based regulations or standards.

It is not appropriate to use either document as criteria for determination of clean waste vs. radioactive waste. The appropriate criterion is that no licensed radioactive material may be disposed of as clean waste. For practical purposes, that means no detectable licensed material. The licensee is responsible for determining that waste disposed as clean waste contains no licensed radioactive material. Please propose a program for screening the waste.

For guidance use:

Information Notice No. 88-22, Disposal of Sludge from Onsite Sewage Treatment Facilities at Nuclear Power Stations at (http://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-notices/1988/in8 8022.html),

Information Notice No. 85-92, Surveys of Wastes Before Disposal From Nuclear Reactor Facilities at (http://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-notices/1985/in8 5092.html), and IE Circular No. 81-07, Control of Radioactively Contaminated Material at (http://www.nrc.gov/reading-rm/doc-collections/gen-comm/circulars/1981/cr8100 7.html)

In your May 13, 2005 response to the above RAI, you proposed the following revision of Section 2.3.1.1.3.1 of the DP:

The equipment, materials, instrumentation, and tools that are used or encountered during the decommissioning may be free released if surveyed and shown not to be radioactive or to have total or removable contamination in excess of the minimum detectable activities associated with the survey methodologies employed. Items that can not be free released will be handled using one of three methods described below;

  • The items may be shipped directly for disposal as radioactive waste at a licensed facility
  • The items may be shipped for processing at a licensed facility
  • The items may be shipped to another licensed facility for storage or use In each case the term licensed facility refers to a facility holding the appropriate radioactive material disposal, processing, storage, or use license appropriate to the class of waste involved.

As you have stated, the minimum detectable activity is dependent on the survey methodology employed. To ensure that the release of equipment, materials and items for unrestricted use is consistent with NRC policy, please state the guidance documents to which your survey methodologies shall conform.