Neil Sheehan
Public Affairs Officer
Region I
Mention nuclear power plant and new natural gas pipeline in the same breath and it may not be surprising if some ears perk up.
Such was the case with a plan by Spectra Energy to install a 42-inch-diameter natural gas pipeline that would cross a portion of the Indian Point nuclear power plant site, in Buchanan, N.Y. One of the most salient questions to arise has been whether a rupture of the pipeline could adversely impact the safety or shutdown of the two operating reactors at the site.
The NRC’s conclusion, based on a thorough peer-reviewed analysis, is no.
First, however, it’s important to understand the limitations on the NRC in this complex interstate project. The agency’s role is restricted to ensuring the safe operations of the Indian Point facility; we cannot usurp the roles and responsibilities of other federal, state and local government agencies.
Other agencies involved in the proposed pipeline expansion include the Federal Energy Regulatory Commission (FERC), which is the lead agency for evaluating applications to construct and operate interstate natural gas pipeline facilities; the Pipeline and Hazardous Materials Safety Administration of the Department of Energy; and the Environmental Protection Agency. There are also many state and local government agencies that have separate responsibilities.
Indian Point has for decades had two natural gas pipelines – one 26 inches in diameter and the other 30 inches– running through the property. The Algonquin Gas Transmission Co., a subsidiary of Spectra Energy, built the 26-inch line in 1952 and the adjacent 30-inch line in 1965. Operating licenses were granted to Indian Point Units 1, 2 and 3, in 1962, 1973 and 1975, respectively. The new line would be installed across a more southerly section. (Plans also call for the 26-inch line to be removed from active use at the time the new line begins operating.)
The 42-inch line would not be located within the plant’s Protected Area – the highly secure section where the reactor buildings, spent fuel pools and other key structures are located. Instead, it would traverse the site about a quarter-mile from the Unit 2 and 3 reactors.
There will also be special precautions to enhance the safety of the piping that will be located closest to Indian Point to further limit the already very low potential for a gas pipeline rupture. For one, the steel pipe will have a wall thickness of almost three-quarters of an inch and will buried at least 4 feet deep, under engineered backfill. The line will have additional corrosion protection and all of its welds will be carefully examined.
Reinforced-concrete protective mats will also be placed over the section of the pipeline closest to Indian Point, providing additional physical protection. Warning markings will drive home the message that excavation in that area is a bad idea. Accidental ruptures during excavation work are one of the most frequent causes of pipeline failure.
Entergy Nuclear Operations Inc., the plant’s owner/operator, was required under NRC regulations to perform a site hazards analysis to evaluate how plant operations could be impacted by a rupture of the pipeline. The company determined the plant could safely shut down and, more broadly, that the pipeline would not pose an undue risk in terms of the facility’s safe operation.
The NRC did not accept this analysis at face value. The agency conducted an independent confirmatory analysis. This evaluation, which assumed a complete rupture of the pipeline, concluded the plant could either continue to safely operate or temporarily shut down.
In addition, NRC inspectors performed visual assessments of the proposed pipeline routing to confirm assumptions used in Entergy’s analysis report. They also reviewed the qualifications of the contractor who carried out the company’s analysis and that Entergy’s acceptance of the report was consistent with its quality assurance program standards.
A discussion of the NRC’s inspection and analysis can be found in an inspection report issued on Nov. 7, 2014. In it, the NRC staff states that “the staff determined Entergy had appropriately concluded that the proposed pipeline does not introduce significant additional risk to safety-related structures, systems and components at Indian Point Units 2 and 3, and therefore the change in the design bases external hazards analysis associated with the proposed pipeline does not require prior NRC review and approval.”
After consideration of all of this information, the NRC determined the two Indian Point reactors could safely operate or shut down if a rupture were to occur on any portion of the proposed pipeline where it would traverse Entergy’s property. The NRC shared these findings with FERC. That agency approved Spectra Energy’s proposal to build the expanded pipeline on March 3, 2015, and authorized construction in the vicinity of Indian Point on Sept. 24, 2015.
U.S. NRC Blog 
· Mistaken Trust
An inescapable fact is that the competent investigation of every harmful event reveals that the causation of the harm includes the mistaken/ naïve/ unwarranted/ gullible/ imprudent trust in one or more erroneous/ untrustworthy assumptions, procedures, processes, people, and/or conditions.
Examples?
Counter-examples?
Better wording?
Paul,
Thanks.
Can you supply a link to it?
If not, can you post some excerpts?
There are a lot of good and talented people within the industry. The problem is that they are afraid to come forward for fear of retribution by the NRC or the utilities. I I have been contacted by NRC people who are afraid to go public in support of this issue.
This whole gas/nuclear problem and the manner it is not being addressed is insane. What else can I do?
pbadupws.nrc.gov/docs/ML1528/ML15287A257.pdf
Read the NRC response. I have met with the Chairman, 2 Commissioners, OIG, two US senators and two Congresspersons the director of the Office of Investigations, the NY Governor’s office and now awaiting major media coverage coming out on November 30.
I have requested a meeting/Presentation before the ACRS.
I will be responding to the NRC’s letter prior to the Chairman’s visit to Indian Point on December 7, 2015.
Bottom line
NRC—Nobody Really Cares
Dr. Bill, I still believe, perhaps too naively, that there are a lot of good folks on both the regulator & regulated side of the nuke industry. They are trying to do the best they can by an inherently dangerous technology. The technology is horribly unforgiving of mistakes. It requires constant vigilance as the late Admiral Rickover stated many years ago. I feel complacency has set in, in our industry and the belief that it just cannot happen here. We did the right thing when TMI happened here decades ago, but if something happens overseas, like Fukushima, it is somehow not given the same attention as if it had happened in our backyard. And that is tragic!
• Character
An inescapable fact is that the character of an industry is largely a reflection of the character of its regulators, and, of course, vice versa . Competence, integrity, compliance, and transparency or their lack seldom exists on only one side of an industry-regulatory interface .
If both IP and Spectra Energy had to each post a $40 billion bond, you can bet that the pipeline would get rerouted.
Next…
I have direct communication from the NRC acknowledging there is no firefighting capability either onsite or offsite. I am willing to share this 25 page letter
Mind boggling.
How can this happen?
Where’s the IG?
Where’s the GAO?
Where’s the Commission?
I received a response (FOIA 2016-0104) today requesting a copy of the NRC’s risk calculations referenced in its letter to me of November 6, 2015.
The FOIA branch responded that they could not locate any such calculations that were cited by the NRC to demonstrate there is no additional risk to Indian Point due to the gas lines.
This is not, as Paul Harvey would say “the end of the story.”
I would appreciate other opinions, especially from those at the NRC including Neil Sheehan.
PLEASE visit http://www.sape2016.org and take action suggested on homepage of calling Gov. Cuomo to have him get from FERC a Stay on AIM construction, rescission of AIM approval certificate, to conduct an independent, transparent and comprehensive public safety and risk assessmment of siting this massive gas pipeline insanely at Indian Point nuclear facility, and to make a very public statement calling for these actions!
If the NRC did such a bang up job, why did the Union of Concerned Scientists ask the Nuclear Regulatory Commission to consider having the commission’s independent Advisory Committee on Reactor Safeguards review the process and criteria used to assess potential hazards from natural gas pipelines close to nuclear reactors at Indian Point in Buchanan and Turkey Point in Florida?
http://www.lohud.com/story/news/2015/09/02/scientists-seek-pipeline-review/71536340/
Also, how in God’s name could the public be expected to trust a risk assessment that includes illegible diagrams, literally, on scratch paper submitted to the formal record?
http://sape2016.org/2015/07/16/nuclear-regulatory-commission-withheld-and-misrepresented-critical-information-used-to-evaluate-and-approve-the-siting-of-the-spectra-aim-pipeline-alongside-indian-point/
So glad we still have folks out there with the expertise and willingness to take on a lax regulator. The NRC refuses to learn from worldwide operating experience. Only if we lose more precious lives in this country will they do anything. The NRC is truly a tombstone regulator!
Additional info that shows that the NRC is not looking out for public safety!
Wow Paul, thanks for sharing. How much more proof is necessary that the NRC is not an industry watchdog but an industry lapdog!
Mr. Sheehan’s comments are an intentional distortion of the true facts, I filed two 2,206 petitions since 2010 2010. Both were rejected, one for security reasons and on an the NRC;s false claim it did not meet the criteria for a 2,206 petition, In September 2015 I net with the Chairman and two other Commissioners, the Office of Investigation, Office of Inspector General and other offices.The true facts are clearly articulated in the NRC’s letter to me dated November 6, 2015 (ML15287A257) and its response which will be submitted next week, The following is a list of “facts” according to Paul Blanch about these gas lines. The NRC does not disagree with any of these facts.
1. False and Inaccurate statements were made by Entergy in its analysis and so far the NRC has not investigated these statements.
2. The plants are operating in an unanalyzed condition in that a rupture of the buried lines 400 feet from most vital structures has NEVER been analyzed for an explosion or leak.
3. The control room air inlet is less than 400 feet from the gas lines and there is no detection or protection against natural gas ingress.
4. Even after written requests from at least ywo US Senators and Two Congresspersons, the NRC refuses to allow an independent risk assessment of the new 40 inch gas line.
5. The NRC approved the construction of the new gas line to FERC on November 7, 2015 in spite of an analysis clearly based on false information provided by Entergy,
6. The NRC calculated the expulsion of about 10 Million pounds of TNT equivalent per minute continuing for more than one hour.
7. According to the equations of Regulatory Guide 1.91, this results in a blast radius of more than 4000 feet, encompassing the entire site and the loss of all AC and DC power.
8. The NRC admits that Entergy has no procedures in place to notify the gas company in Houston of a leak, fire or explosion.
9. The NRC admits the fire brigade and other local responders have had no training in responding to gas line events.
10. The NRC states it has no control over the design, construction or operation of the gas lines and claims this is the responsibility of other Federal agencies and not the NRC’s problem
11.There has been no risk analysis conducted calculation the social and economic consequences of a gas line event and the impact on the area surrounding Indian Point.
12. Mr. Sheehan claims a “peer review” but will not allow a risk analysis conducted by OSHA’s Appendix C to §1910.119 — Compliance Guidelines and Recommendations for Process Safety Management
13. The NRC openly admits it did not review other gas line events such as San Bruno and never reviewed and of the numerous NTSB reports on gas line explosion investigations.
This is just a partial overview of some of the problems associated with these gas lines at Indian Point. I expect an ACRS meeting on this topic in the very near future.
FERC must rescind approval of the Spectra AIM pipeline immediately. The NRC’s confirmatory analysis was faulty and a Fukushima-like core meltdown could result from a rupture of the 42″ diameter high pressure gas pipeline. The mitigation measures do not include concrete mats over the road that the pipeline crosses, leaving it vulnerable to someone wishing to do harm. The other agencies mentioned in the NRC’s p.r. piece all said that they based their decision on the NRC’s analysis. Pipeline expert Richard Kuprewicz stated in a letter to Assemblywoman Galef, “The NRC’s assumptions and comments instill no confidence that their analysis is either relevant or appropriate. Theirapproach and statements clearly demonstrate that the NRC does not grasp the tremendous energy releases and dynamics associated with pipeline rupture of this very large diameter pipeline, and therefore should not be using their current approaches to evaluate gas transmission pipeline
rupture impacts on their facilities. Attempting to use inappropriate models that fail to capture the
unique transient impacts of a high-pressure large diameter gas transmission pipeline rupture in a
highly sensitive site is a poor and inappropriate approach that Accufacts has found in far too
many incident investigations associated with misinformation. A true transient release dynamics
graph (release rate versus time) of the proposed 42-inch pipeline rupture case near the Indian
Point nuclear facility should clearly demonstrate the many flaws in the analysis.”
Hard to believe a careful assessment of this situation would result in approval. Gas pipelines do occassionally explode, and were this to happen at Indian Point, critical shut-down mechanisms might be compromised. Are local firefighters prepared to fight a gas-fed fire next to radioactive spent fuel? Nuclear plants are risk enough, we should not compound the risk any more than necessary. Siting the AIM pipeline HERE invites too much risk. Have we learned nothing from Fukushima?
Anyone can tell this pipeline is sited way too close to the Indian Point nuclear plant and its spent fuel. God forbid, were a rupture to occur at that juncture, the resulting fireball could take out mechanisms critical to shutting down the nuclear operation. Nuclear engineers continue to question NRC about this exact point, and have not been satisfied with NRC’s lack of response.
Have we learned nothing from Fukushima?
Gas pipelines are potentially explosive. While such explosions are infrequent, they are not unheard-of: 1,796 serious explosions involving death and/or injury did occur in the twenty years between 1994 and 2013. The resulting human toll (682 dead and 2,646 injured) was as low as it was, because most pipelines transverse sparsely populated areas. But that is not what we are talking about with this AIM pipeline, here in Westchester. You don’t need to be a climate change believer or an opponent of fossil fuels, to know that this pipeline does not belong here–within striking distance of a nuclear plant.
Siting the AIM pipeline here invites an almost unthinkable amount of risk. NRC loses all credibility in assigning such risk to 20 million of us and then asking us to understand the bureaucratic limitations under which they made their evaluation.
Regardless of the safety evaluation, why would Entergy set themselves up for criticism, another “talking point” for the anti-IP crowd? Seems like it would have been a lot simpler if Entergy had simply told Spectra Energy “no.” Is there some kind of eminent domain thing here?
What keeps a San Bruno from happening at IP?
http://www.ntsb.gov/investigations/AccidentReports/Pages/PAR1101.aspx
Thanks NRC for publishing information that will alert any and all terrorists to yet another prime target at a nuclear power plant. I had no idea that there were already natural gas pipelines through the facility. I just wish the NRC would look as hard at the threat Indian Point (IP) poses to New York City as it has looked at how this new pipeline poses a threat to Indian Point. IP has a terrible safety track record and its emergency plan is not considered adequate to protect the millions of people located in its backyard. It will continue to be a prime terrorist target. It is criminal to think the NRC would extend this plant’s operating license!