ML18114A586
| ML18114A586 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/04/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18114A585 | List: |
| References | |
| FRN-790404, NUDOCS 7905240204 | |
| Download: ML18114A586 (8) | |
Text
In the Matter of e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION APRIL 4 197; OFFICE OF NUCLEAR REACTOR REGULATION HAROLD R. DENTON, DIRECTOR
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Virginia Electric Power Company (Surry Power Station, Units 1 and 2
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Docket Nos. 50-280
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- and 50-281 DIRECTOR'S DECISION UNDER 10 CFR §2.206 By letter dated February 20, 1979, the Environmental Policy Institute (Institute) requested that the Nuclear Regulatory Commission prepare ~n environmental impact statement on the Virginia Electric Power Company's (VEPCO) proposed steam generator repair program at the Surry Power Station a-nd hold a Show Cause hearing on tnis proposed program.
This letter was. filed pursuant to 10 CFR §2.206 of the Commission's regulations.
The asserted bases for the request by the Institute are (1) that the notice of proposed issuance of the amendments to the operating licenses for the Surry Nuclear Power Station to allow the steam generator reRlace-ment was published only one day prior to actual issuance of the amendments, (2) that the Commission did not adequately address the matter of occupational exposure, (3) that no steam generator replacement activities should be approved until the pending transient worker re~ulations are promulgated,
e e and (4) that the Commission should review the Corrrnission 1s treatment of steam generator repair and replacement at pressurized water reactors.
In accordance with 10 CFR §50.59 of the Corrrnission's regulations, a licensee seeking to make a change in the technical specifications or a change in the facility involving an unreviewed safety question must.
submit an application for an amendment to the license.
On August 17, 1977, VEPCO submi.tted a request for NRC review and approval required in order to repair the steam generators at the Surry Power Sta,tion, Units 1 and 2.
It was determined in accordance with 10 CFR §S0.59 that such a program would involve an unreviewed safety question and, therefore,*
would require an amendment of VEPC0 1s Facility Operating License Nos.
DPR-32 and DPR-37 for the Surry plant.
In accordance with 10 CFR
§2.105, a Notice of the Proposed Issuance of Amendments to the licenses at issue was published in the Federal Regtster on October. 27, i977 (42 FR 56652).
The Notice was also available for public inspection in the Commission's Public Document Room and at the local public document room at the Swem Library, College of William and Mary, Williamsburg, Virginia. This Notice provided an opportunity for interested persons to request a hearing by November 28, 1977.
No requests for a hearing were received in response to that*Federal Register notice.* The Institute's
- The.::.tomic Safety and Licensing Board constituted to "review.reque~ts for a hearing under the October 27, 1977 Federal Recister Notice orovided the Commonwealth of Virginia the opportunity to file a
~ecuest for a hearing up to 10 days after issuance of the Staff 1s Sa1ety Evaluation Report which was issued on December 15, 1978.
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- e:e::-:Jer 20, 1978, the Sommonv:ealth stated it v1ould not request a
e
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request does not purport to be filed pursuant to the October 27, 1977 notice of opportunity to request a hearing.
The Institute's February 20, 1979 letter requested review of the procedures by which Amendments 46 and 47 to the Surry licenses were issued.
It i-las_ incorrectly stated that only-one day 1s notice was given for the proposed issuance of the amendments.
As previously stated, notice of the proposed issu-ance ct: these amendments was made on October 27, 1977, ( 42. -FR ~9652), wel 1 over a year before the amendments were issued.
The January 19, 1979 notice of issuance to which the *Institute refers (44 FR 4057). was for an ECCS a.nalysis at a steam generator tube plugging limit of 28% and did not apply to the steam generator repair program.
The*Institute requested a review of the negative declaration matle in the Environmental Impact Appraisal (EIA) for the steam generator repair program and requested the completion of a full environmental impact statement. The bases for the request were (l) that the EIA rejected* analysis of the radiologic impact made by Sattel le Northwest Laboratory published as NUREG/CR-0199, "Radiological Assessment of Steam Generator Removal and Replacement", (2) that the Commission compared the occupa ti ona l exposure for the repair to exposures encountered with repair and maintenance of defective steam generators rather than with normal maintenance exposures and (3) that the Commission must analyze the environmental imp~ct based upon actual release and pathway analysis a~: rJt bj comparison to normal operation *.
e The *EIA issued by the Commission recognized t~e radiological analysis published in NUREG/CR-0199.
The EIA discusses the exposure ranges in NUREG/CR-0199 and states that the lower end of the generic estimate
. II
a ** is the appropriate estimate fo.r comparing with VEPCO' s estimate....
The. position taken in the EIA considered the NUREG document qualification that "High exposure rates were chosen to assure a conservative analysis.
rn*some cases, this approach may result in overestimates of the actual exposure o **
11 As stated in the EIA, the difference between the VEPCO and the NUREG estimates were reconciled by recognizing VEPCO has used the Surry plant specific measured data applicable to its own repair effor*t and further reduces the de,ses by use of temporary shielding which was suggested but not credited in the generic NUR~G.
The Commission's use of the VEPCO estimate is based on a review of the Surry steam generator repair program and a comparison with.the NUREG report. Based on this review.it was concluded that the VEPCO dose* estimate should be*more representative of the actual dose incurred.
The comparison of occupational exposures to be encountered during the repair with exposures encountered with repair and maintenance of
- defective steam generators is appropriate in this report. The steam generators at Surry.have shown significant tube degradation, the repair of which has resulted in high occupational exposures.
Continued use of these steam generato~s would result in continued high *exposures.
e The man-rem savings resulti~g from the repair can be determined by comparing expected repair and maintenance doses from continued use of th~ degraded steam generators with expected repair and maintenance doses from operation with new steam generators. It is expected that the man-rem saved from new generator maintenance compared to continued maintenance ori the old steam generators would offset the doses incurred during repair in-just a few years. It is this dose comparison which serves to justify the expected occupational exposure resulting from repair.
The EIA contains an estimate of releases (Table 4.2.) for *the repair both by VEPCO and the NRR (NUREG/CR-0199). These are compared with Surry operating experience and the values predicted in the staff's.
Final Environmental Statement (FES).
As can be seen tlrle expected. releases from the repair are much less than those predicted in the FES.
Therefore the *environmental impacts resulting from the steam generator repair program are*bounded by the FES impacts. A copy of the Negative Declaration and the Environmental Impact Appraisal is attached to and made a part of this decision {Appendix A) *.
Prior to issuing the amendment to allow the repairs to* be made to the steam generators, the Office of Nuclear Reactor Regulation prepared the Staff Safety Evaluation Report (SER) which is attached to and-made a part of this decision (Appendix B).
That evaluation, which expressly cddressed the matter.of radiation exposure to workers, concluded that there is reasonable assurance that the health and safety of the public
e (including the workers) will not be endangered by the proposed steam generator repair program and that the changes would be conducted in compliance with the Commission 1s regulations.
It was requested that no steam generator replacement activities be approved until the pending transient workers exposure regulations are promulgated.
The Cammi ss ion has al ready approved the repair program for Surry (Amendments_ 46 and 47) and does not consider it appropriate to restrict the Surry work until the proposed transient worker r~gul~tions are promulgated because the work has already been approved and the proposed rule wou,-d have little effect on radiation protection.
Presently licensees are not required in all cases to obtain historical radiation exposure infonnation for the current* calendar quarter.
In theory, if a trans-ient worker received occupational radiation exposures from several licensees during the current calendar quarter and did.not inform the licensees, he could encounter doses in excess of the 10 CFR Part 20 standards.
The proposed rule would require licensees to obtain this information from the transient worker.
Based on 1976 employee tennination data only lout of 32,377 individuals exceeded 3 rems per quarter because of multiple jobs. Consequently the risk from not requiring this infonnation is not significant enough to require special implementation of the proposed rule for the Surry steam generator work.
In addition, Surry does request all employees, including transient workers, to *report historical
e occupational radiation exposures. It is expected that the rule will be promulgated prior to the Turkey Point and Palisades work.
Finally, complete review of the Commission 1s treatment of steam.
generator repair and replacement activities at pressurized water reactors.
was* requested. The Commission is curr*ently reviewing steam generator tube,ntegrity under our Task Action Plans for Generic Activities.
These tasks will include o6cupationa1 exposures.
Based on the foregoing discuss ion and the pro visions of 1.0 CFR
§2.206, I have determined that there exists no adequate basis for holding a Show Cause hearing on the steam generator repair program and that an environmental impact ~tatement need not be prepared.
The request of the Envfronmental Policy Institute is hereby denied.
A copy of this detennination will be p.laced in the Commission's Public Document Room at 1717 H Street, N. W., Washington, D. C.
20555 and the Local Public Document Room for the Surry Nuclear Power Station located at the Swem Library, College of William and Mary, Williamsburg, Virginia 23185. A copy of this document will also be filed with the*
Secretary of the Commission for its review in accordance with 10 CFR
§2o206(c) of the Commission's regulations.
In accordance with 10 CFR §2.206(c) of the Commission's Rules of Practice, this decision will constitute the final act~on of the
e
- Commission 20 days after the date of issuance, unless the Commission on its own motion institutes the review of this decision within that time.
I Or:rinal Signed BJ E. G. Case
~D/J Haro 1 d R. Denton, Di rector lJ Office of Nuclear Reactor Regulation Appendix A -
Notice of Issuance of Amendments to Facility Operating Licenses, Negative Declaration and Environmental Impact Appraisal dated January 20, 1979 Appendix B -
Staff Safety Evaluation Report dated December 15,,1978