Nuclear Regulatory Commission Withheld and Misrepresented Critical Information Used to Evaluate and Approve the Siting of the Spectra AIM Pipeline Alongside Indian Point

On Wednesday, July 15, 2015 at 2:30 p.m. at the Hendrick Hudson Library in Montrose, NY, at a special presentation to the Nuclear Regulatory Commission’s (NRC) Petition Review Board, nuclear expert Paul Blanch revealed that the Nuclear Regulatory Commission withheld and misrepresented critical information used to evaluate and approve the siting of the Spectra Algonquin Incremental Market Project’s 42-inch diameter gas pipeline adjacent to the Indian Point nuclear power plant. Therefore, the Certificate for the Spectra AIM project, issued by the Federal Energy Regulatory Commission (FERC) on March 3, 2015, which was based on the NRC’s faulty analysis, must be rescinded immediately.

Map of Potential Impact Radius of 42

Map of Potential Impact Radius of 42″ pipeline adjacent to Indian Point Energy Center. Map based on route indicated in Spectra Energy FERC filings from February 2014.

Mr. Blanch began his presentation with this powerful statement:

The NRC has threatened the safety of more than 20 million residents and the infrastructure of the greater NY metropolitan area and is risking trillions of dollars of damage and possibly the US economy by basing its safety assessment on a calculation that was recently obtained from the NRC under FOIA[1].This new information confirms that this NRC ‘calculation’ which was partially handwritten, unapproved, undated and unsigned, used fictitious, false and unsupported assumptions. This NRC calculation supported the FERC approval of the AIM project and the transportation of thousands of tons of TNT equivalent across and in the vicinity of the Indian Point nuclear plants. This ‘back of the envelope-type calculation,’ which misled Congressional representatives, FERC and the general public, must be invalidated and an independent, transparent, structured risk assessment, as outlined in an Occupational Safety & Health Administration (OSHA) methodology, must be undertaken.”

Hand-written document submitted to NRC as part of Entergy Safety Assessment of AIM Pipeline. (Source: see FOIA below)

Hand-written document submitted to NRC as part of Entergy Safety Assessment of AIM Pipeline. (Source: see FOIA document #2 below)

Nationally recognized pipeline expert Richard Kuprewicz, engaged by the Town of Cortlandt to analyze the project, provided formal comments to FERC in November and December. Mr. Kuprewicz participated in the NRC Petition Review Board call. He stated:

In reviewing the various analyses of information provided to date, it has become obvious that those attempting to perform rupture dynamics of the 42-inch pipeline should not be doing such work, as their analyses consistently fail to capture the fundamental basics of gas pipeline rupture dynamics, especially on this system in the vicinity of the nuclear plant.  From my perspective, it appears the permitting agencies are attempting to take advantage of a loophole that permits the NRC to dismiss risks if such analysis can be categorized below a certain threshold value, while ignoring the severe consequences that might prevent the nuke plant to safely shutdown.

Mr. Blanch discovered the new information through a Freedom of Information Act (FOIA) request of NRC correspondence resulting from a letter to Assemblywoman Sandy Galef from the NRC.   The links to the FOIA documents are available here:

Link to FOIA document #1

https://drive.google.com/file/d/0B9zj5jrshSGjNThTek5VczhuNTgyTEZwUlJaSHRkMkoyanZB/view?usp=sharing

Link to FOIA document #2

https://drive.google.com/file/d/0B9zj5jrshSGjTjBKUlE1Y2MzQXEzX0RzcjJkdTVJeG9FaDh3/view?usp=sharing

 

Assemblywoman Galef, who hosted the press conference prior to the presentation said, “At the press conference I joined my colleagues and elected officials to hear more about the grave concerns with the siting of the Spectra AIM pipeline so close to the Indian Point Nuclear Power Plant. We will continue to advocate for greater scrutiny and a halt to this project unless and until it can be determined that this is safe.  Right now, we have no such assurances.”

Background:

According to another FOIA of until-now-private NRC emails, a rupture of a gas pipeline of this pressure and diameter, would release about 4 kilotons of energy a minute. To put this in perspective, the nuclear blasts at Hiroshima and Nagasaki were about 15 kilotons[1]. While this energy release wouldn’t cause the same type of damage, it could cause continuous explosions, which could destroy systems required to shut down the Indian Point reactors, which could cause major release of radioactive material that could impact a 50 mile radius (like Fukushima). Yet, the NRC continues its claim of “no additional risk.”

The risk analysis performed by Entergy and confirmed by the NRC states that if the pipeline ruptures, Spectra Energy’s operators in Houston would be able to shut down the gas flow in 3 minutes. Most gas line ruptures require field verification, which takes additional time.  When a pipeline in San Bruno, CA ruptured, it took hours to get it under control.

If the NRC had used accurate information concerning the dynamics of a pipeline rupture, the impact radius of the explosion and heat flux would have been dramatically expanded. This would have demonstrated that a rupture could lead to a total electrical failure including back-up systems regardless of whether they shut the valves in 3 minutes or 1 hour.

Had the NRC provided accurate information to FERC and the involved agencies, the siting of the pipeline alongside Indian Point would most certainly not have been approved.  While Fukushima was caused by an unforeseeable tragedy, putting the AIM pipeline next to Indian Point creates the potential for an avoidable tragedy.

[1] NRC FOIAs 2015-00176 and 0246 include an NRC internal email that discusses gas release rate of 376,000 kg per minute, which is nearly 1 million pounds per minute of explosive gas. Natural gas contains 10 times the energy per pound than TNT.

About Paul M. Blanch

45 Years Nuclear Power Experience, Navy Submarine Reactor operator and instructor, BS Engineering 1972, Registered Professional Engineer, Westinghouse Engineer of the Year, Participated in design of Millstone and Connecticut nuclear plants, Three Mile Island expert witness, Davis Besse expert witness, Testified before US Senate, Vermont and Massachusetts legislatures.

Employed by/Consultant to:

  • Millstone
  • Connecticut Yankee
  • Maine Yankee
  • Indian Point (Consolidated Edison and Entergy)
  • Electric Power Research Institute (EPRI)
  • Nuclear Entergy Institute (NEI)
  • State Agencies
  • Numerous Law Firms
  • Riverkeeper

Expert Witness for License renewal (10 CFR 54)

  • Indian Point License Renewal
  • Vermont Yankee License Renewal
  • Pilgrim License Renewal
  • Seabrook License Renewal

Identified numerous shortcomings in the NRC’s License Renewal programs/reviews including:

  • Piping degradation
  • Unqualified submerged vital cables
  • Failure to require aging management programs for numerous passive components

Identified and petitioned the NRC to take action related to gas transmission lines at Indian Point

About Richard Kuprewicz

Mr. Kuprewicz has over 40 years experience in the energy industry offering special focus on appropriate pipeline design and operation in areas of unique population density or of an environmentally sensitive nature. He is currently a member of the U.S. Department of Transportation Hazardous Liquids Pipeline Safety Standards Committee (THLPSSC) representing the public, a position appointed by the Secretary of the Department of Transportation. He has also served in the past on the Washington State Citizens Committee on Pipeline Safety a committee appointed by the Governor of the state that advises federal, state, and local governments on all matters related to pipeline safety, including routing, construction, operation and maintenance. He is a chemical engineer, experienced in production, pipeline, and refinery design, construction, operation, maintenance, risk analysis, management, acquisition, emergency response, and safety management processes, including hazard analysis. He has also authored many papers on pipeline safety, both nationally and internationally, and has proved various inputs throughout the development of federal pipeline safety regulation including liquid and gas pipeline safety rulemaking.

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