ML20064J347

Followup on Interim Rept on 781220 Deficiency Re Diesel Engine Turbocharger Failures.Three New Turbochargers Will Be Supplied by Vendor

ML20064J347
Person / Time
Site:	Zimmer
Issue date:	01/18/1979
From:	Borgmann E CINCINNATI GAS & ELECTRIC CO.
To:	Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19269C700	List: ML20064J347
References
QA-1079, NUDOCS 7902120103
Download: ML20064J347 (2)

Text

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/1 Secretary of the Commission t U.S. Nuclear Regulatory Commission ~

Re: Hearing and Environmental Docketing 5 Service Section Impact Statement for Surry /) .

Washington, D.C. 20555 Generator Replacement In the Matter of Virginia Electric and Power Company Surry Nuclear Power Stgtion,. Units 1 and 2 b'7) '

Docket Nos. S0-2M and 50-281

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Dear Sir:

Enclosed is a copy of a letter sent to you by the North Anna Environmental Coalition requesting an Environmental Impact Statement be 2one 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.

Respect full'y ,

Truth In Power enclosure 7902120S M 7 9 0 2120 2[tb3

. ' NORTH ANNA ENVIRONMENTAL COALITION 412 Owens Drive Charlottesville, Virginia Mailing Address:

December 29, 1978 Enntsville Alabama 35801 (205) 536-0678 Secretary af the Commisaion U. S. Nuclear Regulatory Commission Re: Hearing and Environ-Docketing & Service Section mental Impact State-Washington, D. C. 20555 ment for Surry *r Generator He M^

b In the Matter of Virginia Electric and Power Comp g{$

Surry Nuclear Power Station, Units 1 and' 2 - C[ .g , l Docket Nos. 50-230 and 50.-281 T 9 p\ -,

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Dear Sir 4,

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l This letter is addressed to you in accordance with the @

sions of 10 CFR 2.206 and 10 CFR 51.50 to request that the Nuc

• Regulatory Commission (NRO) conduct a full hearing and prepare a complete Environmental Impact Statement (EIS) on VZPCO's proposed stean generator replacement at its Surry 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 significant licensing step" in tenne of the ACRS discussion of October 28, 1978 (Tr. 38 - 39).

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

and replace defective Westinghouse steam generators is the first pro- /h cedure of its kind in the country and represents an attempt to solve ~ ' eff ,

an industry-wide problem involving malfunction and radiation exposure,j '#

NRC did not issue a news release on October 21, 1977 for public hearing. [

The only notice that NAEC can discover is Mr. Case's letter of that 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 staan generator replacement could ( and should ) be pre-ceded by a public hearing, per the 10-28-78 ACES transcript, page 122.-3:

DR. ISBIN: Do you expect requests for a public hearing on this action 7 MR. BENTON: 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..."

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2.

i Study of the ACRS Snrry Subcoannittee transcript of Cotober 28 makes it olear that the Snrry procedure involves multiple unknowns at every stage of the undertaking, including, but not limited tos

" ... occupational radiation exposure, airbornet 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 coolant pipe will give the highest radiation exposure to the workers involved, but total dosage estimates vary widely: TEPCO estimates only 2070 manren per unit whereas "the Battelle study ran 3300 to 5500." (Tr. 33)

How will the radiological dose be distributed, ACRS asks.

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

MR. BARRE 2T: ...I believe there are changes to part 20 forthcoming. I do not believs that they have been issued yet on transient workers. I am sorzy. 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 fitui on page 19 that it will be months before Westinghouse ocepletes its report on comparative dose estimates between "retubing" and replacing staan generators.

k 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 att41es'

! being completed, environmental impset statements prepared, public hear-ings held, and significant 1.27arde confronted before any major and experb mental modification is allowed at a nuclear plant. It is our understanding i

that NRC Regulations require a licensing procedure before a utility is per-mitted to go forward with such a signifloant licensing step.

Thus the Coalition respectfully repeats its request that the Consnis-sion prepare a thorough Envirosseental Impact Statement on YEPCO's proposed steam generator replacement at Surry, and that the Ceaunission hold a public hearing at which YEPCO is required to show cause as to why such a hazardous and unproven procedure should be allowed at the Surry station. We further ask that the public hearing be widely noticed in Virginia. Thank you for your professional o ensideration.

Sincerely, NORTH ANNA EN7IRORMENTE COEITION I