ML19269C810

Forwards 781229 Ltr from North Anna Environ Coalition to Nrc,Requesting EIS Before Steam Generator Replacement. Supports Request & Urges Public Hearing on Issue

ML19269C810
Person / Time
Site:	Surry
Issue date:	01/24/1979
From:	TRUTH IN POWER
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
NUDOCS 7902120213
Download: ML19269C810 (3)

Text

.

$[.G .' -.O.

vt.1it L . . %

PC,'D.$ %'..,7..$O $f.&

o TR TR

,#,4 - 325

'The land we =alk is only ours on loan.' u 5%9 A c)7 ,, ,, u ,, ,,,et gp/ January 24, 1 ~9' t

//

Secretary of the Commission U.S. Nuclear Regulatory Commission

• Re: Hearing and Environmental Docketing S Service Section Impact Statement for Surry Washington, D.C. 20555 Generator Replacement In the Matter of Virginia Electric and Power Company Surry Nuclear Power Station, Units 1 and 2 Docket Nos. 50-230 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 de.e 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 crea?

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.

Respectfully, Truth in Power enclosure 7 90 2120 2 lb 3

N~ ORTH ANNA ENVIRONMENTAL COALITION Charlottesville, Virginia Mailing Address: 412 Onss Drive December 29, 1978 Huntsville, Alabama 35801 (205) 536-0678 Secretary of the Oc= mission U. S. Nuclear Regulatory Commission Re: Hearing and Environ-Docketing & Service Section mental Impact State-Tashington, D. C. 20555 ment for Surry S g Generator He m i h

In the Matter of Virginia Electric cud Power Comp V

Surry Nuclear Power Station, Units 1 and 2 Docket Nos. 50-230 and 50-281

_e Q [

\

I

'S Deav 8ir: ,

13 lQ5 -

This letter is addressed to you in accordance with the , 9 sions of 10 CFR 2.206 and 10 CFR 51.50 to request that the Nuc " I Regulatory Commission (NRO) ocnduct a full hearing and prepare a complete Environmental Impact Statement (EIS) on YZPCO's proposed stean generator replacement at its Surry Nuclear Power Station.

There is no question but what this experimental remedial pro-oedure represents "an unreviewed safety question" in accordance with 10 CFR 50.59, and is "a significant licensing step" in terns of the ACRS discussion of October 28, 1978 (Tr. 38 - 39). >

Hevertheless, despite the fact that VEPCO's proposal to remove /

and replace defective 7/estinghouse stean generators is the first pro- #h p cedure of its kind in the country and represents an attempt to solve af/g an industry-wide problem involving malfunction and radiation exposure,j ' , er HRC did not issue a news release on Cotober 21, 1977 for public hearing. [

The only notice that NAEC can discover is Mr. Case's letter of th at date to the Federal Register, read by few if any affected citizens in the

" Surry area, and seen for the first time by NAEC just a few weeks ago when

, Surry's Project Manager kindly mailed the Coalition a requested copy.

NAEC requested the copy after learning that the significant hazards con-sidoration of steas generator replacement oculd ( and should ) be pre-ceded by a public hearing, per the 10-28 78 .1023 transcript, page 122-3:

DR. ISBIN: Do you expect requests for a public hearing on this action?

MR. 3ENTON: 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 malfanction safety analysisofreport..."

a different type thaa any evaluated previously in the

/,

-2.

Study of the ACRS Surry Subcommittee transcript of October 28 makes it clear that the Surry procedure involves multiple unknowns at every stage of the undertaking, including, but not limited to

" ... occupational radiation exposure, airborne radioactive releases, liquid and solid waste handling, disposal of steam generator lower assemblies and the tubing, and radiological consequences of postulated accidents..." (Tr. 5)

It is generally acknowledged that welding the reactor ocolant pipe will give the highest radiation exposure to the workers involved, but total dosage estimates vary widely: YEPCO eatimates only 2070 manrisn per unit whereas "the Battelle study ran 3300 to 5500." (Tr. 33)

How will the radiological dose be distributed, ACRS asks.

DR. IS3 ins What is the relationship here to transient workers?...Isn't the staff looking in general at this problem? Have you reached some position?

MR.3ARRTT: ...I believe there are changes to part 20 forthcoming. I do not be2.ieve 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 regulaticus lag behind the zmolear situations requiring them. Similarly, we fini on page 19 that it will be months before Westinghouse completes its report on comparative dose estimates between "retubing" and replacing stean generators.

On page 18, Mr. Grimes speaks of "the time scale that is desired by this utility" as if the NRC were powerless to insist upon atteles' being completed, environaental impact statements prepared, public ' hear-ings held, and sic 2ificant hasarde confronted before a$y major and exper-i-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 licensing step.

Thus the Coalition respectfally repeats its request that the Consis-sion propare a thorough Environnental Impact Statement on VEPCO's proposed steam generator replacement at Surry, and that the Commission hold a public hearing at which TEECO is required to show cause as to why such a hazardous and unproven procedare should be allowed at the Surry station. We further ask that the public hearing be widely noticed in Virginia. Thank you for your professional c onsideration.

Sincerely, NORTH .WNA 2N72ROKENTE 00EITION