ML18113A763

Requests Thorough EIS on Vepco'S Proposed Steam Generator Replacement & Asks Commission to Hold Public Hearing Requiring VEPCO to Show Cause Why Hazardous Procedure Should Be Allowed

ML18113A763
Person / Time
Site:	Surry
Issue date:	12/29/1978
From:	Allen J NORTH ANNA ENVIRONMENTAL COALITION
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
NUDOCS 7901110333
Download: ML18113A763 (2)

Text

,l~~U!~MEN*rAL COALJTIOf\1-Ch,~.rlot Ve!'i'v llle, Virginia  ;,railing Addrea a: tt:z ()...; Dr ni, HuntsTilla 9 AlilbEmA i Te 35801 December 29, 1978 (206) !536--0678 Secretary of the Com~lsaion J. So nuclear Regulatory Commisa ion Re: Hear in~ and Environ-Docketin15 & Ser~ice Section mental Impact State-

~aahington, D. C. 20555 ment for Surry Steam Generator Replace~ent In the Matter of Virginia Electric and Power Company Surry Nuclear Power Station, Units 1 and 2 Docket Noa. 50,..230 and 50-281 Dear Sirs Thia letter is addressed to you 1n a.ccord.l:mce with the proT1-Bio:l!! 0~ 10 CB 2.206 nnd 10 CPR 51.50 to r&q":J81lt !Jut tb~-:S::cltf::U-

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c ~ l o t e 1:nT1ro=c,nttl I:=ipt!-Ot S<en-:,::;oont (EI!J} en *.'!..:"'-"O'o ;n-opo:1o4 **':"'i atea::::i generator replacement at its SUrry Nuclear Po.rer Station.

There is no question but what this experimental remedial pro-cedure represents "an unreviewed safety question" in accordance with 10 CFR 50.59, and is "a significant licensing step" in terms or the ACRS diaousaion of October 28, *1978 (Tr. ~8 - 39).

Nevertheless, despite the fact that ~O's proposal to remove and *replace defective Westinghouse,steam generators is the first pro-cedure or its kind in the country and represents an attempt tQ.. solve an industry-wide problem involving malf'unction and radiation exposure, NRC did not issue a news release on October 21, 1977 for publio hearing 0 The only notice that ~ can discover is Mr. Case's letter of that date to the Federal Register, read by_few if any affected citizens in the Surry area9 and seen for the first time by .NAEC just a few weeks ago when Surry's Project Manager kindly mailed the Coalition a requested copy.

RAm requested the copy after learning that the aigni.f'ioant hru';srda con-sideration o~ atea:n generator replacement could { and should ) be pre-ood..-d b7 a. pal>l.1c hear 1.ng. per the lo-28-78 .!CBS trans or 1pt, pa.e 122-3 i.

m. IBBilis Do you expect requeata for a public hearilJs on this action?

MR* .BENTON: No. r believe the comment period for that action has alre~ expired.

The foregoing exchange led the Coalition to make the above request for-a hearing* on this major modification planned for the Surry nuclear plant a modification which certainly involves the "possibility for an accident' or mal:functlon of a different type* than a:ny evaluated previously in the*

safety analysis _report *** "

e it

• e transcript of October 28 makes Study of the ACRS Surry Subcornm t ee it clear that the Surry procedure involves multiple unknowns at every stage of the undertaking, including, but not limited to:

" *** occupational radiation exposure, airborne*

radioactive releases, liquid and solid wa.ate handling, disposal of steam generator lower a..s semblies and the tubing, and radiological conseq_uences of postulated accidents.**" lTr. 5)

It is-generally.acknowledged that welding the reactor coolant pipe will give the highest radiation exposure to the workers involved, but total dosage estIDiatea vary widely: VEPCO estimates only 2070 11 ma.nra:n per unit whereas "the ]attelle study ran 3300 to 5500. {Tr. 33)

How will the rsdiological dose be distributed, .ACRS a.aka.

DR. ISB INs What is the relationship here to transient workers? *** Isn't the staff looking in general at this problem? Have you reached some position?

• • • I believe there are changes to part 20 forthcoming. I do not believe that they have been issued yet on transient workers. I am sorr:;. I can't give you much of the details. (Tr.48/9)

Thus it ia evident that needed regulations lag behind the.nu.clear a ituationa requiring them.

• Similarly, we find on page 19 that it will.

be months before Westinghouse completes its report on comparative dose estimates between "retub.ing and replacing steam generatorso On page 18, Mr. Grimes speaks of "the time *scale that is desired by this utility" as if the NRC were powerless to insist upon s~~as' being completed, environmental impact statements prepared, public hear-ings held, and significant hazards confronted before any major and exper mental modification ia allowed at a nu.clear plant.* It is our understanding that NRO *Regulations require a licensing *procedure before a utility la per-.

mitted to go forward with such a sign~fioimt licensing step.

Thus the Coalition reapectfu.lly repeats its request that the Commis-sion prepare a thorough Environ:nental Impact Statement on VEPOO's proposed steam generator replacement at Surry, and that the Com.mission hold a public hearing at which VEPCO is required to show cause a.a to why suoh a hazardous and unproven procedure should be allowed at the Surry station. We further ask t_hat the public hearing be widely noticed in Virginia. Thank you for your professional consideration.