ML19093A784
| ML19093A784 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/24/1979 |
| From: | Truth in Power |
| To: | NRC/SECY |
| References | |
| Download: ML19093A784 (5) | |
Text
"\\
'The land we walk is only ours on loan.'
Secretary of the Commission U.S. Nuclear Regulatory Commission Docketing & Service Section Washington, D.C.
20555 Hearing and Environmental Impact Statement for Surry Generator Replacement In the Matter of Virginia Electric and Power Company Surry Nuclear Power St on, Units 1 and 2 Docket Nos.
0-2*0 rtd 50-281
Dear Sir:
Enclosed is a copy of a letter sent to you by the North Anna Environmental Coalition requesting an Environmental Impact Statement be done at VEPCO's Surry, Va. plant before they replace the steam generator.
NAEC's letter raises many important questions that need to be addressed.
How much radiatio.n will the workers be exposed to, and which manrem estimate is the most likely?
How will it affect the migrant workers and residents in the area?
If Westinghouse has not yet completed it's study on comparative dose estimates between "retubing" and replacing steam generators, how is it possible to even make a decision?
Truth In Power respectfully requests along with NAEC that the Commission prepare a complete Environmental Impact Statement on VEPCO's proposed steam generator re-placement at Surry, and that public hearings be held requiring VEPCO to justify why such a potentially hazardous and unproven procedure be allowed at Surry.
We also ask the public hearing be widely noticed throughout Virginia.
Thank you.
enclosure Respectfully, Truth In Power
s<./ NORTH ANNJI ENVIR'O-NM-E,.AL COA-LITION u~ilina, Ad. dress 1 4U Owen1 DriTe Charlottesville, Virginia
.Ill.Clo o
36801 December -29, 1978 Han'taTille, Alabama (206) !536-0678 Secretary of the Commission
- u. So Nuclear Regulatory Commission Docketing &: Service Section
- Washington, D. O.
20555 Re:
- Hearing and Environ-mental Impact State-
~
tor Surry 8.-D Generator Re ~
In the Matter or Virginia Electric and Power Comp Sllrry Nuclear Power Station, Units 1 and*?
Docket Nos. 50-230 and 50..281 Dear Sirs
~
This letter is addressed to you in accordance with the ~'~Wllo..._J,J,:,i' aions or 10 CFR 2.206 and 10 OFR 51.60 to request that the NucLe,~.:....;.__.
Rego.latory Commission lNRO) conduct a full hearing and prepare a complete Environmental Impact Statement (EIS) on VEPCO's proposed stegn generator replacement at its Su.rry Nuclear Power Station.
There is no question but what this experimental remedial pro-cedure represents "an unreviewed safety question" in aooordanoe with 10 CFR 50.59, and is "a slgnirioB.?lt licensing step" in terms of the.ACRS discussion ot October 28; 1978 (Tr. 38 - 39).
,v' Nevertheless, despite the fact that VEPCO's proposal to remove
/:
and replace defective Westinghouse steam generators is the first pro-
~.*-Kj cedure of its kind in the country and represents an attempt to solve /' ff'Z."
an industry-wide problem involving malfunction and radiation exposure, p ;u, NRC did not issue a news release on October 21, 1977 for public hearing 0
.,.,,~
The only notice that NA.EC can discover is Mr. Case's letter of that date to the Federal Register, read by-few it any affected citizens in the Surry area9 and seen for the first time by NAEO just a few weeka ago when
~
- Surry's Project.Manager kindl1 mailed the Coalition a requested copy.
NAm requested the copy after learning that the significant hazards con-sidarat:!.on of st&am genera.tor repltM)ement could ( anci shoulci ; be pre...
oeded by a public hearing, per the lo-28-78.ACBS transcript, page 122-3z DR. ISBINs Do you_ expect requests for a publio hearing on this action?
MR. BENTONs No.
I believe the comment period for that action has already expired.
The foregoing exchange led the Coalition to make the above re~uest for a hearing on this major modification planned for the Su.rry nuclear plant a modification which certainly involves the "possibility tor an accident' or ma1£anction of a different type than~ evaluated previously in the safety analysis report *** "
e Stu~ of' the.AORS SUrry St1bcommittee transcript or October 28 makes it clear that the Sa.rry procedure involves multiple unknowns at ever:,
stage of the undertaking, including, but not limited tos
"; ** occupational radiation exposure, airborne*.*
radioactive releases, liquid and solid waste handling disposal of steam genera.tor lower
- a.ssembli;s and the. tubing, and radiological consequences of postulated accidents.**" (Tr. 5)
It 1s generally acknowledged that welding the reactor coolant pipe will give the highest radiation exposure to the workers involved, but total dosage estimates var., widely:
VEPCO estimates only 2070 manrlD per unit whereas "the :Batt.elle stu~ ra.n'3300 to 5500." llfr* 33)
How will the radiological.dose be distributed, ACRS asks.
DB. ISBIN's What is the relationship here to transient workers? *** Isn't the eta.ft looking in general at this problem? Have you reached some position?
MR.BARRm'l!a
- I believe there are changeli to part 20 forthcoming.
I do not believe that they have been issued yet on transient workers.
I am sorry.
I can't give you much of the details. (Tr.48/9)
Thus it is evident that needed regulations lag behind the llllOlear situations 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 generators.
On page 18, Kr. Grimes speaks of "the time scale that is desired by this utility" as if the NRO were powerless to insist upon au.a.ea*
being completed, envirolllJlental impact statements prepared, public 'hear-ings held, and sig!lif'icant hazarw~ con.fronted before arJ3 major and e.xper~
mental modification is allowed at a nuclear plant. It is our understanding that NRC Regulations require a licensing procedure before a utility is per-mitted to go forward with such a significant licens.ilJg step.
Thus the Coalition respecttlllly repeats its request that the Commis-sion prepare a thorough Envirozmental Impact Statement on VEP<IO's proposed steam generator replacement at Surr.,, and that the Commission hold a pu.blic hearing at which VEPCO is required to show cause as to w~ such a hazardous and unproven procedure should be allowed at the Sllrry stat ion.
We :turther ask that the public hearing be widely noticed in Virginia.
Thank you for your professional e onsideration.
Sincerely, NOBTH.ANNA ENVIRONMENT.AL COALITION
UNITED STATC:S OF A:--:::::E',l c;,.
NUCLEAR R.EGlJ""LATORY CO~*'.?.*!ISS 10::-T In the Hatter of VIRGINIA ELECTRIC AL'l"D POHRR CO}fPANY
)
)
)
)
)
Docket ~;o. (s) 50-280 50-281 (Surry Power Station, Units 1 and 2)
.)
)
)
)
CERTIFICATE CF SEl;JlCE
.I hereby certify that I have this day.c:f:rved the foregoir!g dc-,:-:u:u.e:!t(s) upon each* person.:lesign;1ted on the off:i.ci~~ s~nricf~ list: co'2.;,i !.ec. by the Office of the Secretary of the Co.::r:,is.s:ion in this proceetl::..:ig in accordance with the requiree1ents of Section 2. 712 of !.O GR Part. 2 -
Rules of Practice, of the NucleaI: Regul~tory Com3.issi.o;-z 's Rules an.d Regulations.
Da*ted at. Washington, O
__ \\_,:.,._.,,,t;-is
..,_j ( 5:f day. of ____ 1
_uJ_t'.J ___ l97 2_.
- Secretary of th Coa~tssion
e
.e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of VIRGINIA ELECTRIC AND POWER COMPANY (Surry, Units 1 and 2)
)
)
)
)
)
)
)
)
SERVICE LIST Marshall E. Miller, Esq., Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Wash~ngton, D.C.
20555 Dr. Oscar H. Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C *. 20555 Mr. Frederick J. Shon Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Counsel for NRC Staff U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docket No.(s) 50-280 50-281 Michael W. Maupin, Esq.
Hunton and Williams P.O. Box 1535 Richmond, Virginia 23213 Anthony J. Gambardella, Esq.
Office of the Attorney General 11 South 12th Street - Suite 308 Richmond, Virginia 23219 Swem Library College of William and Mary Williamsburg, Virginia