ML19093B325
| ML19093B325 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/16/1979 |
| From: | Mason H District of Columbia |
| To: | NRC/SECY |
| References | |
| Download: ML19093B325 (8) | |
Text
HILDA HOWLAND M. MASON Counc;\\member at Large e
COUNCIL OF THE DISTRICT OF COLU~IBIA WA.SHI:NGTON.D.C. 20004 February 16, 1979 Secretary of the Commission U.S. Nuclear Regulatory Commission Docketing and Service Section Washington, D.C. 20555
Dear Sir:
As a native Virginian and a former resident of the Chesapeake Bay area, I have recently become aware of the risks associated with VEPCO's imminent replacement operation for the steam generators at the Surry atomic power station.
As I understand the situation, even though this unique
$127 million operation will involve considerable radiation exposures to the environment and to workers, the following facts seem clear:
- 1.
There has been no Environmental Impact Statement.
- 2.
There has been no public hearing.
- 3.
The Virginia State Health Department has had no input in the decision-making.
- 4.
A Nuclear Regulatory Commission spokesman, Dr. Barrett, is on record (in the October 28, 1978 meeting of the Advisory Committee on Reactor Safeguards) as characterizing VEPCO's commitment to "ALARA" standards for radiation exposure as "weasel-worded~"
- 5.
VEPCO specifically stated at the same meeting that it did *not plan to observe in all respects the applicable Nuclear Regulatory Commission regulations (specifically Regulatory Guide 8.8).
- 6.
VEPCO has also specifically decided not to use decontamination procedures and the manufacturer recommended retubing option which would reduce worker exposures to radiation.
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Secretary of the Conunission page two It seems that in this case the Nuclear Regulatory Commission has issued a license amendment for this procedure with undue deference to the time frame desired by the utility and with little substantive public input, contrary to the spirit of the Commission's own regulations.
I urge that the Commission review the February 1, 1979, denial of Ms. June Allen's Section 2.206 "show cause" petition and allow further consideration of, this matter by appropriate Nuclear Regulatory Commission officials and the concerned public.
HM/em Sincerely, HILDA HOWLAND M. MASON Councilmember at Large
e Dr. Robert Jackson Virginia State Health Dept.
Richmond, Va.
Dear Dr. Jackson,
- ~~,;;;iF, so';~i, Feb. 19, 1979 I am writing to you in regard to the events now taking place at Vepco's Surry station; that is, their replacement of the radioactive steam generators.
- Because of the large radiation release and the known dangers to the involved workers, I believe this should be a
- matter of concern to the State Health Dept.
Vepco has admitted rushing into the replacement option before all the studies were completed, yet the procedure has never been attempted before.
Radiation exposure is a very serious problem and a very real possibility.
Public,hearings, both State and Federal, should be held concerning this matter, since the replacement of the steam generators is also being contemplated at Turkey Point (Fla.) and Palisades.
Respectfully,
,~a)~
Copies to:
Rep. Mo*rris Udall
. U.S. House of Reps.
Washington, D.C.
Sen. Gary Hart U.S. Senate Washington, D.C.
Secretary*of the Commission U.S. Nuclear Regulatory Cornrnissi
- . Washington, D. C.
20555
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e Dr. Robert Jackson Virginia State Health Dept.
Richmond, Va.
Dear Dr. Jackson,
I am writing to you in regard to the events now taking place at Vepco's Surry station; that is, their replacement of the radioactive steam generators.
- Because of the large radiation release and the known dangers to the involved workers, I believe this should be a matter of concern to the State Health Dept.
Vepco has admitted rushing into the replacement option before all the studies were completed, yet the procedure has never been attempted before.
Radiation exposure is a very serious problem and a very real possibility.
Public:hearings, both State and Federal, should be held concerning this matter, since the replacement of the steam generators is also being contemplated at Turkey*
-Point (Fla.) and Palisades.
Copies to:
- Rep. Mo*rris Udall
. U.S. H6use of Reps.
Washington, D.C.
Sen. Gary Hart U.S. Senate Washington, D.C.
Secretary*of the Commission U.S. Nuclear Regulatory Commissi
- . Washington, D.C.
20555 Respectfully,
- ,;?kvd& aJd
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e Hon. Joseph Hendrie, Chairman
-U.S. Nuclear Regulatory Connnission 1717 H Street, N.W.
Washington, D.C.
20555
Dear Commissioner Hendrie:
Environmental Policy Institute 317 Pennsylvania Ave. S.E. Washington, D.C. 20003 202/5 -
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February 20, The Environmental Policy Institute requests that the Commission---.__--~
reconsider the issuance of Amendment Nos. 46 and 47 to Facility Operating License Nos. DPR-32 and DPR-37 issued to Virginia Electric and Power Com-pany (VEPCO) for replacement of the steam generators at Surry Power Station Unit Nos. 1 and 2.
We request review of the procedures by which the amendments were granted and the convening of a public hearing on the amendments.
Notice of the proposed issuance of the amendments (44 FR 4057, January 19, 1979) was published only one day prior to the actual issuance of the amendments which were effective immediately upon issuance.
Notice of issuance, which took place on January 20, 1979, was not published until January 29, 1979 (44 FR 5735).
We request review of the negative declaration made in the Environ-mental Impact Appraisal issued January 20, 1979 concerning the steam generator replacement and request the *completion of a full environmental impact statement.
The Appraisal rejected analysis of the radiologic impact made by Battelle Northwest Laboratories published as NUREG/CR-0199 "Radio-logic Assessment of Steam Generator Removal and Replacement." The Appraisal found that differences between VEPCO's analysis -and NUREG/CR-0199 of man/
rem occupationai exposures could be easily reconciled.
NUREG/CR-0199 clearly notes that it considered both the VEPCO and Florida Power and Light analyses of steam generator replacement and that the substantial differences remained in the analysis.
The Commission accepted without qualification VEPCO's estimate of 2,070 man/rem per unit wh.ile NUREG/CR-0199 showed potential exposures to be between 3,380 man/rem and 5,840 man/rem per unit.
Furthermore, the Commission compared the occupational exposure to exposures encountered with repair and maintenance of defective steam genera-tors,rather than with normal maintenance exposures 1 to justify high exposures.
Finally, the Commission in its negative declaration found that releases to the environment were expected to be less than those resulting from normal operation and therefore they were without significant impact.
The Com-mission must analyze the environmental impact bas.ed upon actual release and pathway analysis and not by comparison to normal operation.
We request that no steam generator replacement activities be ap-proved until the pending transient worker exposure regulations are promulgated (43 FR 4865, February 6, 1978, Proposed Rule).
The 3,380 man/rem to 5,840 man/rem per unit occupational exposure estimates made in NUREG/CR-0199 represent extremely high exposure rates.
These estimates,extended over the
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e Surry units and Florida Power and Light's Turkey Point plant and Consumers Power's Palisades plantj which have applications pending for steam genera-tor replacement, represent a very large number of transient worker exposures.
Finally, we request a complete review of the Commission's treat-ment of steam generator repair and replacement activities at pressurized water reactors.
This review should be extended to include expected steam generator repair and replacement.exposures over the lifetime of these units and design requirements to reduce steam generator maintenance exposures.
DB:ejw cc:
Hon. Gary Hart Hon. Morris K. Udall*.,..._....
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David Berick Bob Alvarez
In the Matter of tmITED STATES OF A};ERICA NUCLEAR REGULATORY co~~1ISSION e
VIRGIXIA ELECTRIC Al\\1) POWER
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Docket No.(s) 50-280 50-281 (Surry Power Stat.ion, l:nits land 2)
CERTIFICATE OF SERVICE
.J: hereby certify that I have this day served the foregoing document(s) upon each person designated on the officia1 service list: CO-;il.pi led by the Office of_ the Secretary of the Comr:i.ission in this proceeding in a~cordance with the requirements of Section 2.712 of 10 CTR Part 2 -
Rules of Practice, of the Nuclear Regulatory Commission's Rules and Regulations.
Dated at Washington, D.C. this
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day.of Pb 197 9.
Office/ of lthe Secretary of th Co~.nission r
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of VIRGINIA ELECTRIC AND POWER COMPANY (Surry, Units 1 and 2)
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Docket No. (s)
- _ 50-280 281 SERVICE LIST Marshall E. Miller, Esq., Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, 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 Michael W. Maupin, Esq.
Hunton and Williams P.O. Box 1535 Richmond, Virginia 23213 Anthony J. Gambardella, E_sq.
Office of the Attorney General 11 South 12th Street - Suite 308 Richmond, Virginia 23219 Swem Library College of William and Mary Williamsburg, Virginia