ML18114A542
| ML18114A542 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/18/1979 |
| From: | Jay Dougherty Potomac Alliance |
| To: | Hendrie J NRC COMMISSION (OCM) |
| Shared Package | |
| ML18114A543 | List: |
| References | |
| NUDOCS 7905100262 | |
| Download: ML18114A542 (2) | |
Text
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L Hon. Joseph M. Hendrie, Cha+/-rman, Nuclear Regulatory Commission 1717 H St., N.W.
Washington, D.C.
20555
Dear Mr *. Hendrie:
April 18, 1979
,,** \\I Attached hereto is a petition filed this date on
. *behalf of. four citizens groups requesting the Corr.mission to act immediately to remedy cert.ain actions.by the NRC Staff an~ the Virginia Electric Power Company (VEPCO) which are alleged to be illegal and which will result in human radiation exposures of a magnitude unprecedented in the Commission's history.
Briefly,* VEPCO obtained NRC Staff
. approval of a $169 million proposal to replace* the steam generators at_Sutry Power Station Units 1 and 2 on Janu~ry 20 of.this year and commenced the action shortly thereafter.
This project,* as described in greater scope and detail in the accompanying petition, in*volves the.following:
Occupational radiation exposures estimated to total between 4,000 and 11,000 man-rems (equivalent to the exposures expected at a normally operatirig plant over a period bf up to 22 years);
On-site construction of a long-term waste repository in which will be stored at least 13000 tons of radio-active waste; Substantial redesign of the.Surry facility, including the ~ddition of coolant water reprocessing systems which will discharge large_quantities of effluents
.into the James River.
Under the facts and circumstances of the Surry project the National Environmental Policy Act (NEPA} fairly.cries out for the preparation of an environmental impact statement (EIS).
Yet the Staff not only declined to prepare an EIS, it released an environmental impact appraisal which.is ~learly deficient under the standards established by the *federal courts.
Moreover, as the Commission is.undoubtedly aware, the Surry steam generator replacement praj~ct is on~y the first step in a long series of related projects which will inevitably be performed to cure widespread deteriorat~on of Westinghouse steam generators~.* Operators of the Turkey Point and Palisades
- nuclear plants have already sought formal NRC *.
approval for such projects. The*preparation of a oroqram..iatic EIS concerning all pending and future applications io; such permis~ion was therefore required before the Surry project co-:1ld proceed.
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In addition, the Surry steam generator replacement
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project entails several material violations by VEPCO of NRC regulations.
Foremost among these is the construction of the*long-term waste storage facility on site: whj,le this specifi~ action in and of itself contravenes 10 CFR
§21.301, the overall approach is inconsistent with the
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rational resolution of the nation's nuclear wast,e dilemma.
Petitioners assert further that the Surry project con-stitutes a material reconstruction of the facility, in violation of 10 CFR §50.91, as well as a partial dismant-ling of the facility, in violation of 10 CFR §50.82.
The pet~tion calls upon the Conunission to exercise it's inherent* authority and responsibility under the Atomic Energy Act.to protect the public health and safety, to ensure compliance by its licensees with regulatory req-uirements, and to oversee the activities of the Staff in*
light of limitations imposed by federal law.
The relief requested is set forth in the petition: it_ includes iss-.
uance of a *directive to the NRC Staff requir.ing prepar-ation of the environmental statements called for under NEPA, and issuance of an order halting the Surry project pending a showing by VEPCO.as to why the project should continue in the face of the violations cited above.
Above-all, petitioners urge to Commission to move with utmost haste.
Every day of delay result in massive and needless radiation doses and tilts the cost-benefit
~nalysis away from more reasonable alternative means of solving the problem.
Respectfully,
, s-
.- Doughe:r:r.ty nsel fer Petitioners 307 Eleventh St., N.E.
Washington, D.C.
20002 (202) 547-5244 Attachment cc: all Commissioners
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Director of Nuclear Reactor.Regulation Hon. Gary Hart, U.S. Senate Hon. Morris K. Udall, U.S. House of Representatives