ML19093B319

Request NRC to Conduct a Full Hearing & Prepare a Complete Environmental Impact Statement on VEPCOs Proposed Steam Generator Replacement

ML19093B319
Person / Time
Site:	Surry
Issue date:	01/08/1979
From:	Sundholm J Richmond Alternative Energy Committee
To:	NRC/SECY
References
Download: ML19093B319 (4)

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Rich~ond Alternative Energy Collimittee

r. 0. Box 25G07 Richmond., virginia 2;5260 (804) 2j2-6536 January 8,

Becretary of the Commission Re

Hearing and Environ-mental lmpact State-ment for Burry Steam Generator Replacement

,.U. S. Nuclear Regulatory Commission Docketing and Service Section Washing~on, D. C. 20555 In the Matter of Virgi~ia ~lectric and Fower Cc~parry Surry Nuclear Fower Station, Units 1 and 2

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Docket i'1os.* _50-2jC_ana 50-281________

Dear Sir:

On December 29, 1978 the North Anna Environmental Coalition

~sent a letter to your office requesting that the Nuclear Regula-

• tory Commission "conduct a full nearing and prepare a complete

.Bjnvironmental Impact Statement. (EI.o) on Vepco 's proposed steam

• generator replacement at.its Surry Nuclear Power Station.* ~~ 11 I am writing to you on behalf of the Richmond Alternative Energy Committee to state that our organization strongly supports the North Anna Environmental Coalition's r~quest for a full hearing and a complete Environmental Impact Statement on the proi:,osed

.Burry steam generator replacement project.

As residents of eastern Virginia, the members of the Rich-

.mond Alternative Energy Committee are dee.ply concerned about the Tauiological dangers involved in replacing the Surry steam gen-

• er.a tors.

For this reason, our organization supports the North

~Anna Environmental Coalition in its request for a ~horough ex-plo~ation of the steam generator replacement issue.

Sincerely, Jon Sundholm, Treasurer Richr.10nd Alternative Energy Corr:mi ttee

I

'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 e/*:[_t-*~f\\;>:;;~,,

January 24, 1979/

Re: 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. 50-230.artd 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 genera.tor.

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

-....*hy such. a potentially hazardous and unproven procedure be allowed at Surry.

Ke also ask the -public hearing be widely noticed throughout Virginia.

Thank you.

enclosure Respectfully, Truth In Power t:::

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.:,"f*-N-ORTH ANNA E'.VIRONMENTA.COALITION Charlottesville, Virginia

• Mailing.Addreas s 4U Owen* DrlTe HtintaTille,.Alabama 35801 (206) 536-0678

• December 29, 1978 Secretary or the Commission

u. So Nuclear Rego.latory Commission Docketing & Service Section

• Washington, D. o.

20555 Re:

• Hearing and Environ-mental Impact State-.

ment for SUrry SteBlll Generator Replacement In the Matter of' Virginia Electric and Power Company Sllrry Nuclear Power Station, Units 1 and'2 Docket Nos. 50-230.and 50-281 Dear Sirs This letter is addressed to you in accordance with the provi-sions of' 10 CFR 2.206 and 10 CFR 51060 to request that the Nuclear Regu.latory Commission lNRO) conduct a tu:ll hearing and prepare a complete Environmental Impact Statement (EIS) on VEPCO'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 aocordanoe with 10 OFR 50.59, and is "a significant 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

.JI" and replaoe defective Westinghouse steam generators is the first pro-t!1 l:. /~S, cedure of its kind 1n the country and represents an attempt to solve

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an industry-wide problem involving malfunction and radiation exposure,

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NRC did not issue a news release on October 21,.1977.£or public hearing0 It'~

The only notice that-NA.EC oan discover is Mr. Case's letter of that.

date to the Federal Register, read by £ew if any affected citizens in the Surry area9 and seen for the first time by NAEO just a few weeks a.go when Surry's ProJect Manager kindly mailed the Coalition a requested copy.

RAm ~equested the copy after learning that the significant hazards con-s idaration of steam generator replacement could ( and should) be pre-ceded by a public hearing, per the lo-28-78 AOBS transcript, page 122-3:

DR. ISB1N1 Do you_ expect requests for a public hearing on this action?

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 ~volves the ttposs1b1lity for an accident or maltanction of' a different. type than any evaluated previously in the**

safety analysis report *** "

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• Study' of the.AORS Surry Subcommittee transcript or Ootober 28 makes it clear that the Surry procedure involves multiple unknowns at every stage of the undertaking, including, but not limited tos

" *** occupational radiation exposure, airborne.:

• radioactive releases, liquid and solid waste

. hand.ling, disposal or steam generator lower assemblies and the. tubing, and radiological consequences of postul~ted 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 vary widelys VEPCO estimates only 2070 manran per unit whereas.. "the.Batt.elle stud_y ran 3300 to 5500*",~. 33).

Row will the radiological dose be distributed, J.CRB aaks.

DR. ISBIN's What is the relationship here to transient workers? *** Isn1t the staff looking in general at this problem? Rave you reached

. some position?

MR.::S.ARR.mTs

• • • I believe there are changes 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 d.etails. (Tr.48/9)

Thus it is evident that needed r~lationa 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 "retub ing and replacing _steam generatorse On page 18, J.tr. Grimes speaks of' "the tlm~ scale that is desired by this utility" as it the NRO were powerless to insist upon stJ..ttaa*

being completed, enviromental impact statements prepared, public "hear.

ings _held, and Sig?li.f'icant ha.2:arcu~ confronted before any major and *exper mental modification ls allowed at a nuclear plant. It is our understanding that NRO Regulations require a lioensing procedure before a utility is per-mitted to go forward with such a s1gnifloant licensing step.

• Thus the Coalition respectfully repeats its request that the Co1111n1s..

sion prepare a thorough Envirozmental Impact Statement on VEPOO*s proposed steam generator repla~ement at Surry, and that the.Commission hold a public hearing at which VEPCO is required to show cause as to wey such a hazardous and unproven procedure should be allowed at the Surry etat ion.

We further a.sk that the public hearing be widely noticed 1n Virginia.

Thank you for your pro.fess ional consideration.

S1noerely, NORTH ANNA ENVIRONMENTAL COALITION