ML19095A188
| ML19095A188 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/24/1979 |
| From: | Truth in Power |
| To: | NRC/SECY |
| References | |
| Download: ML19095A188 (3) | |
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 Station, Units 1 and *2 Docket Nos. 50-2$f{) and 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 radiation 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
- -*:/ N-ORTH ANN_. ENVIRONMENf AL COALITION Mailing Address:
412 Owen* Drh'e Charlottesville, Virginia HantaTill*,.Al~ama 36801 December 29, 1978 (2os) S36-0678 Secretary of the Commission
- u. S0 Nuclear Regulatory Commission Docketing&: Service Section
- Washington, D. C.
20555 Re:
Hearing and Environ-mental Impact State-ment tor Surry St.e.fQoe=--..._
Generator Re ~~E~~..&..i.:
In the Matter ot Virginia Electric and Power Comp Su.rry Nuclear Power Station, Units land' 2 Dooket Nos. 50,,,,230 and 50-281 Dear Sirs This letter is addressed to you in accordance with the ~
aiona of 10 CFR 2.206 and 10 CFR 51060 to request that the Nuc~~~,..:..~-
Regu.latory Commission lNRO) conduct a full hearing and prepare a complete Environmental Impact Statement (EIS) on VEPCO's proposed stean 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 accordance with 10 CFR 50.59, and is "a slgniticant licensing step" in terms of the ACRS discussion ot October 28, 1978 (Tr. 38 - 39).
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Nevertheless, despite the fact that VEPCO's proposal to remove
~
and replace defective Westinghouse steam generators is the first pro-ii ~ /K~
cedure of' its kind in the country and represents an attempt to solve /',r7'"'
an industry-wide problem involving malfunction and radiation exposure,
,,, ;\\,,
NRC did not issue a news release on October 21, 1977 for public hear1ng0
//'~
The only notice that NA.EC can discover is Mr. Case's letter ot 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 f'ew weeks ago when
"', Su.rry's Project Manager kindly mailed the Coalition a req_uested copy.
NA.ID requested the copy after learning that the significant hazards con-s idarat ion of steam generator repl~ement could { and should j be pre-ceded by a public hearing, per the lo-28-78.ACES transcript, page 122-3:
DR. I5BINs Do you_ expect requests for a public 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 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 malfunction of a different type than any evaluated previously in the safety analysis report *** "
Stu~ ot the ACRS-Surry Subcommittee transcript of October 28 makes it clear that the Sarry procedure involves *multiple unknowns at every*
stage of the undertaking, including, but not limited tos_
n *** occupational radiation exposure, airborne-radioa.ot ive releases, liquid and solid waste
. handling, disposal of steam genera.tor lower*
assemblies and the-tubing, and radiological-consequences of postulated acoidents *** 11 (Tr. 5)
It is generally acknowledged that welding the reactor coolant pipe will give the highest radiation exposure to the workers involved, but total dosage estimates var:, widely:
VEPOO estimates only 2070 manrsn _per unit whereas "the.Battelle atud.3' ran 3300 to 5500." l'fr* 33)
How will the radiological dose be distributed,.ACR.8 asks.
DR. ISBllls What is the relationship here to transient workers? *** Isn't the staff looking in general at this problem? Have you reached some position?
MR..B.ARR.mTa
- I believe there are changes to part 20 forthcoming.
I do. not believe that they have been issued yet on trans lent 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 nuclear situations requiring them. Similarly, we find on page 19 that it will be months before Westinghouse completes its report on comparative dose estimates between "retubing and replacing _steam generatorae On page 18, l4r. Grimes speaks of "the time scale that is desired by this utility" as if' the NRO were powerless to insist upon suttas*
being completed, env1ro:nmental impact statements prepared, pu.blic bear-ings held, and sig?lif'ica:t ha~a.rd..i:, confronted before arJ3 major and exper mental modification is allowed at a nuclear plant. It is our understanding that NRO Rego.lations require a licensing procedure before a utility is per-mitted to go forward with such a significant licensillg step.
- Thus the Coalition reapecttu.lly repeats its request that the Commis-sion prepare a thorough EnviroDnental Impact Statement on VEPOO's proposed steam generator replacement at Surry, and that the Commission hold a public hearing at which VEPCO is required to show cause as to wb1' such a hazardous and unproven procedure should be allowed at the Sllr1"1' stat ion.
We further ask that the public hearing be widely noticed 1n Virginia.
Thank you for your professional c: onsideration.
Sincerely, NOHTH ANN.A. ENVIRONMENTAL CO.ALIT ION