gas line near indian point nuclear power plant
TRANSCRIPT
RPI Engineering Symposium
Co-locating Nuclear Plants with Natural Gas Pipelines
12/15/16 1Co-locating Nuclear Plants with
Natural Gas Pipelines Paul Blanch Energy Consultant
Paul Blanch, Energy Consultant
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Natural Gas Pipelines Paul Blanch Energy Consultant
Paul BlanchBackground
• Reactor operator and instructor in the US Navy Nuclear Power Program
• BSEE University of Hartford• PE State of California (inactive)• Engineering supervisor at Northeast Utilities for
Millstone and Connecticut Yankee• Identified two generic safety problems (1990)
impacting all world reactors-Changed my life forever
• Expert witness for NYS Attorney General in the relicensing of Indian Point
• Expert witness in numerous other nuclear litigations including Three Mile Island
• Consultant to Chief Nuclear Officers at Millstone, Maine Yankee and Indian Point
• Not opposed to Nuclear Power if properly regulated
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Indian Point Looking WestShowing Existing Gas Line
Route
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Aerial Photo taken by Paul Blanch June 2010Width about 3000 feet
Co-locating Nuclear Plants with Natural Gas Pipelines
Paul Blanch Energy Consultant
Summary of Problem
• Gas lines are an extreme risk to nuclear plants
• A risk assessment is required by Federal Regulations
• A valid independent risk assessment has not been conducted by NRC, Entergy, PHMSA, or NYS
• It has been alleged that Indian Point has submitted criminal and material false statements to the NRC
• NRC still refuses to investigate
• Director of the NRC’s Office of Investigation “resigns” shortly after my meeting with her
• NRC scientist with 8 years nuclear experience used prohibited EPA program, ALOHA, and calculated 1100 feet blast radius from 42-inch line (850 psi)
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Summary of Problem (continued)
• Calculations performed by four engineers (3 PEs) with more than 120 years of nuclear experience using data from the NRC/Entergy, independently calculate a blast radius of more than 4000 feet– Calculations performed in accordance with the intent
of quality assurance program required by the NRC (10 CFR 50 Appendix B)
• Congressional and NY State representatives have pleaded with Federal agencies for an independent risk assessment
• Chairman Burns of the NRC misrepresented blast calculation to US Congresswoman Lowey (3/24/2015)
• NRC refused to investigate alleged criminal actions by Entergy
• Blast radius may engulf entire nuclear site• Approval of project by FERC based on NRC’s
miscalculation• FERC never saw a copy of NRC’s calculation
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Summary of Problem (continued)
• Entergy admits in 1997 in communication with the NRC that a gas event may cause major damage extending for “several thousand meters”
• NRC used prohibited ALOHA program to miscalculate damage radius
• NRC, in response to FOIA request “lost” CD containing Entergy’s analysis
• Energy released in pipe break is about 3 kilotons per minute of TNT equivalent although its impact will be much less than 3 kilotons detonating
• Impact of gas leak may engulf the entire Indian Point site
• No procedures to terminate leak or fight fire
• May disable all site power (aka Fukushima)
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Summary of Problem (continued)
• Although aware of the blast radius miscalculation and other inaccuracies, FERC, PHMSA and NRC have not required a valid risk assessment even though it has been requested by Congressional and NY State representatives
• IAEA recommends distance from gas lines to nuclear facility to be 7-10 km
• Indian Point main control room is 380 feet from active gas lines
• New gas line runs 105 feet from vital structures
• Any risk assessment must be independent and transparent
• Risk assessment should follow the guidance of OSHA 29 CFR 1910.119 Appendix C. – “Compliance Guidelines and Recommendations for
Process Safety Management”
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Insanity on Steroids
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Locating high-pressure gas transmission lines
380 feet from nuclear power plant main control room
and within 35 miles of New York City
Co-locating Nuclear Plants with Natural Gas Pipelines
Paul Blanch Energy Consultant
NRC, Entergy, FERC, PHMSA, NYS Response to
Safety Issues
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NRC, FERC, PHMSA
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PHMSA Regulation Requiring Risk Assessment
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NRC Regulation Requiring Risk Assessment
§ 50.59 Changes, tests, and experiments.
(C)(2) A licensee shall obtain a license amendment pursuant to § 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would:
(i) Result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the final safety analysis report (as updated);
(ii) Result in more than a minimal increase in the likelihood of occurrence of a malfunction of a structure, system, or component (SSC) important to safety previously evaluated in the final safety analysis report (as updated);
(iii) Result in more than a minimal increase in the consequences of an accident previously evaluated in the final safety analysis report (as updated);
(iv) Result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); (v) Create a possibility for an accident of a different type than any previously evaluated in the final safety analysis report (as updated);
(vi) Create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); (vii) Result in a design basis limit for a fission product barrier as described in the FSAR (as updated) being exceeded or altered; or (viii) Result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses.
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Risk • The product of consequences and probability
• The calculated probability has been reduced by the NRC by a factor of 100-1000 without any supporting documentation
• Consequences may surpass those of Fukushima due to population density and radioactive spent fuel on site
• Risk assessments have been requested by many NYS and US Congressional representatives and the Governor– None have been produced to date
• NYS contracted for a risk assessment without mentioning Indian Point– Final product required by October 5, 2016
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Potential Consequences
• Impact on 20 million people
• Uninhabitable land out to 50+ miles – Including much of NYC, NJ and CT
• Impact on US Economy (trillions of $$$)
• Fukushima on site clean-up costs are approaching $2 trillion
• Evacuation of millions for generations
• Uninsured losses
• Prompt and latent fatalities
• loss of infrastructure – Wall Street, Trump Tower, Water Supplies,
Transportation, etc.
• Anarchy and panic
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NRC Equations for Gas Release.
Includes heat flux, overpressure and vapor cloud explosions
Co-locating Nuclear Plants with Natural Gas Pipelines
Paul Blanch Energy Consultant
Calculation Assumptions Provided by the NRC FOIA
• Initial flow from broken line is 376,000Kg/minute
• TNT energy equivalent is about 12 million pounds of TNT per minute or about 5 kilotons per minute
• Gas flow will be terminated within 3 minutes
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NRC/Entergy Calculation
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•The NRC and Entergy both calculate a damaging blast radius of about 1100 feet
(Results were Redacted)
Co-locating Nuclear Plants with Natural Gas Pipelines
Paul Blanch Energy Consultant
NRC Calculation
• NRC used prohibited EPA ALOHA program to calculate blast without any justification but:– It apparently provided the answer they desired
• Calculation not reviewed, signed, dated and not in accordance with any QA requirements
• No calculation provided for realistic 60 minute release
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Probability of an Accident
• Probability of a major release is not clearly defined however the NRC appears to accept an accident (core damage and release) frequency of about 1 in 10 million (10-7/year) from Regulatory Guide 1.91
• While impossible to quantify the estimated failure rate of the gas lines is in the range of 1 in 1000/year to 1 in 100,000/year (terrorism excluded)
• The commercial airline failure rate is about 1 in 20,000,000/flight and includes terrorism
• The potential consequences of an airline crash are trivial when compared to Indian Point gas line event
• The potential of a gas line event is much greater than a commercial flight and is a continuous risk, 365/24/7
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Probability of Gas Line Failure from PHMSA
6.6x10-4/mile-year
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Calculation from David Lochbaum
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Blast Radius of 4200 feet for 3 minute release
Co-locating Nuclear Plants with Natural Gas Pipelines
Paul Blanch Energy Consultant
Calculation Summary from NRC Professional Engineer
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Blast radius of 4300 feet
Co-locating Nuclear Plants with Natural Gas Pipelines
Paul Blanch Energy Consultant
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Calculation From DOE Professional Engineer
Blast radius of 4185 feet
Co-locating Nuclear Plants with Natural Gas Pipelines
Paul Blanch Energy Consultant
Calculation by Paul Blanch, PE
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Blast radius 3000-4000 feet
Co-locating Nuclear Plants with Natural Gas Pipelines
Paul Blanch Energy Consultant
Alleged Wrongdoing by New York State
• NYS, through formal agreement with PHMSA has the responsibility to identify and report violations of 49 CFR 192 to PHMSA. No reports available
• The Governor ordered a risk assessment for the new pipeline. Does not even included possible collateral damage to Indian Point– Contract required to be completed by October 5. 2016
• NYS risk assessment has not been delivered
• AG and Governor Cuomo were formally notified of potential problem since 2010.– Response: Not our responsibility!
• Governor has ordered safety inspection (12/2015) that was never conducted
• NYS denied Blanch FOIA requests for risk assessment information
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Alleged Wrongdoing by NRC
• Denied Blanch petition in 2010 due to “security” concerns.
• Denied Blanch 2014 petition without addressing any issues
• Chairman made inaccurate statements in testimony before US Congresswoman Lowey (3/24/2015)
• Continues to refuse to discuss difference of opinions. (Regulatory Infallibility)
• Apparently used wrong data, assumptions and program for blast radius. – But it did provide desired results
• Did not question unrealistic 3-minute valve closure time in confirmatory analysis. – NTSB reports nominal isolation times range from 30 to
90 minutes
• Formally refused to verify content of million gallon fuel tanks
• Provided false information to FERC and PHMSA resulting in final approval of project
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Alleged Wrongdoing by NRC (continued)
• “Risk Assessment” by Entergy “Lost” per FOIA response
• ACRS and NRC have refused public meetings
• NRC OI refused to investigate alleged criminal actions by Entergy
• Has never performed risk assessment on existing lines located 380 feet from control room
• NRC/Entergy “risk assessment” used prohibited EPA ALOHA computer code
• Closed Blanch petition with 46 open issues in violation of NRC procedures
• Violated at least 2 of its Management directives
• Under investigation by the NRC Inspector General (Case #16-024)
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Alleged Wrongdoing by FERC
• In its application Spectra certified compliance with all requirements of 49 CFR 192
• FERC never confirmed compliance
• These requirements include risk assessment, first responders, public education and awareness and hundreds of others
• FERC approved AIM project without ever seeing any “risk assessment” from the NRC or Spectra
• Ignored formal public comments
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Alleged Wrongdoing by PHMSA
• Ignoring Entergy admission that a gas event may cause major damage for “several thousand meters”
• Ignoring NRC use of prohibited ALOHA program to miscalculate damage
• Ignoring potential social and economic risks calculated in the Trillions of $$
• Ignoring warnings that gas line event may engulf entire Indian Point site
• Ignoring warnings that land may be uninhabitable for generations
• Ignoring invalid assumed valve closure time
• Ignoring concerns of terrorism required by 49 CFR 192 and ASME B31.8(s)
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Alleged Wrongdoing by Entergy
• Provided alleged material false information to the NRC– NRC Office of Investigation refused to investigate
• Provided “risk analysis” inconsistent with any established engineering principals such as blast radius and valve isolation times
• Did not consider possibility of explosive vapor clouds
• Has no procedures to respond to gas leak or explosion or notification to Spectra
• Control room located 380 feet from gas line has no detection, isolation or emergency procedures. Analysis could not be located
• Refused to meet in public to discuss differences of opinions
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Personal Issues with Problematic NYS
AG and Governor’s Actions• Cuomo states he wants Indian Point closed
• Missed Opportunities
• Ignored problems during license renewal
• No action taken after problem formally identified to his office
• Has the power/responsibility through the MOU with PHMSA to identify noncompliances
• Directed and contracted for “risk assessment” while never mentioning impact on Indian Point
• Denied FOIA request (under appeal)
• Negotiated “deal” with Entergy for upstate nuclear plants
• Made inconsistent statements to the public
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Risk vs. Benefit of More Gas Supply Co-located with
Indian Point• Possible Risks– Increased CO2– US Economy could be destroyed – 20 Million inhabitants relocated– Trillions $$$– Uninsured property
• Claimed Benefits– Decreased CO2– Energy Independence– Lower natural gas prices for New
England• Actual Benefit– $$$ to Spectra Energy
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What choices do we have to reduce risk?
• Admit there is a problem
• Stop new pipeline
• Reroute gas from existing pipeline
• Close Indian Point – Reduces but does not eliminate risks
• Close Broadway adjacent to Indian Point removing one terrorist threat
• Reduce airborne threats
• DHS needs to evaluate all potential threats– Airborne, Oklahoma City attack, drones, cyber
security, insiders, etc.
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Regulatory Infallibility
• NRC, FERC, and PHMSA decisions can not be challenged even in a court of law and only after the fact
• NRC, FERC and PHMSA will not discuss differences of opinions
• No effective Congressional oversight• NRC engineers making decisions that impact the
safety of 20 million people do not need to be licensed, be a PE, or any nuclear background – (One would need a license to cut hair in Connecticut)
• Similar lack of requirements for other involved agencies
• Safety reviews and calculations have no requirements for Quality Assurance
• FERC and PHMSA do not review or enforce or look for regulatory non-compliance
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Tombstone Regulation
• Regulations will only be enforced after the tombstones are counted or after a major accident– Fukushima– Three Mile Island– Exxon Valdez– BP Gulf oil spill– San Bruno– Bridge Failures– Dam Failures– Transportation accidents
Examples can be found in numerous NTSB accident reports
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My personal thanks to the following
• RPI President Dr. Shirley Jackson• RPI Professor Yuri Gorby• Congresswoman Nita Lowey and staff• Assemblywoman Sandy Galef and staff• Congressman Engel and staff• Richard Kuprewicz – Pipeline Safety Expert• Ellen Weininger• Amy Rosmarin• Susan Van Dolsen• Nancy Vann• Riverkeeper• David Lochbaum and all of the unnamed NRC
and Entergy personnel providing insights and information
• Hundreds of people contributing thousands of hours and dollars to this effort– even getting arrested for protesting this insanity
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Discussion
• Suggestions from Elected Officials
• Suggestions from NRC, Entergy, FERC, Spectra, PHMSA
• Suggestions/comments/questions from Students, Professors, the Public
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Terms and Acronyms
• NRC - Nuclear Regulatory Commission – Responsible for protecting the “People and Environment”
• OIG - NRC’s Office of the Inspector General • OI - NRC’s Office of Investigation
– Responsible for investigating licensee wrongdoing and can refer cases to Department of Justice
• FERC - Federal Energy Regulatory Commission – Responsible for siting of major energy projects and
compliance with Federal Regulations• PHMSA - Pipeline and Hazardous Materials Safety
Administration – Responsible for regulatory compliance and inspection of
pipelines (49 CFR 192)• CFR - Code of Federal Regulations
– Specifies minimum requirements for all Federal Agencies• ACRS - NRC’s Advisory Committee for Reactor
Safety– Advises Commission on major safety issues facing the
nuclear industry
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Terms and Acronyms
• Entergy – Owner and operator of Indian Point Units 1, 2, 3.
• IPEC– Indian Point Energy Center- A Limited Liability
Corporation operating Indian Point• AG
– New York State Attorney General • NYS
– New York State• IAEA
– International Atomic Energy Agency• PE
– Licensed Professional Engineer• NTSB
– National Transportation Board• FOIA
– Freedom Of Information Act• MOU
– Memorandum Of Understanding between NYS and PHMSA
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Additional Information
For any additional information such as copies of the presentation,
documentation, communications with Federal agencies, FOIA
requests and responses, meeting notes with the NRC, etc.
Please contact:
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