41
RPI Engineering Symposium Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 1 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant Paul Blanch, Energy Consultant

Gas Line Near Indian Point Nuclear Power Plant

Embed Size (px)

Citation preview

Page 1: Gas Line Near Indian Point Nuclear Power Plant

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

Page 2: Gas Line Near Indian Point Nuclear Power Plant

12/15/16 2Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 3: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 3Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 4: Gas Line Near Indian Point Nuclear Power Plant

Indian Point Looking WestShowing Existing Gas Line

Route

12/15/16 4

Aerial Photo taken by Paul Blanch June 2010Width about 3000 feet

Co-locating Nuclear Plants with Natural Gas Pipelines

Paul Blanch Energy Consultant

Page 5: Gas Line Near Indian Point Nuclear Power Plant

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)

12/15/16 5Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 6: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 6Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 7: Gas Line Near Indian Point Nuclear Power Plant

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)

12/15/16 7Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 8: Gas Line Near Indian Point Nuclear Power Plant

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”

12/15/16 8Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 9: Gas Line Near Indian Point Nuclear Power Plant

Insanity on Steroids

12/15/16 9

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

Page 10: Gas Line Near Indian Point Nuclear Power Plant

NRC, Entergy, FERC, PHMSA, NYS Response to

Safety Issues

12/15/16 10Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 11: Gas Line Near Indian Point Nuclear Power Plant

NRC, FERC, PHMSA

12/15/16 11Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 12: Gas Line Near Indian Point Nuclear Power Plant

PHMSA Regulation Requiring Risk Assessment

12/15/16 12Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 13: Gas Line Near Indian Point Nuclear Power Plant

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.

12/15/16 13Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 14: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 14Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 15: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 15Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 16: Gas Line Near Indian Point Nuclear Power Plant

12/15/16 16

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

Page 17: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 17Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 18: Gas Line Near Indian Point Nuclear Power Plant

NRC/Entergy Calculation

12/15/16 18

•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

Page 19: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 19Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 20: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 20Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 21: Gas Line Near Indian Point Nuclear Power Plant

Probability of Gas Line Failure from PHMSA

6.6x10-4/mile-year

12/15/16 21Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 22: Gas Line Near Indian Point Nuclear Power Plant

Calculation from David Lochbaum

12/15/16 22

Blast Radius of 4200 feet for 3 minute release

Co-locating Nuclear Plants with Natural Gas Pipelines

Paul Blanch Energy Consultant

Page 23: Gas Line Near Indian Point Nuclear Power Plant

Calculation Summary from NRC Professional Engineer

12/15/16 23

Blast radius of 4300 feet

Co-locating Nuclear Plants with Natural Gas Pipelines

Paul Blanch Energy Consultant

Page 24: Gas Line Near Indian Point Nuclear Power Plant

12/15/16 24

Calculation From DOE Professional Engineer

Blast radius of 4185 feet

Co-locating Nuclear Plants with Natural Gas Pipelines

Paul Blanch Energy Consultant

Page 25: Gas Line Near Indian Point Nuclear Power Plant

Calculation by Paul Blanch, PE

12/15/16 25

Blast radius 3000-4000 feet

Co-locating Nuclear Plants with Natural Gas Pipelines

Paul Blanch Energy Consultant

Page 26: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 26Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 27: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 27Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 28: Gas Line Near Indian Point Nuclear Power Plant

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)

12/15/16 28Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 29: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 29Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 30: Gas Line Near Indian Point Nuclear Power Plant

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)

12/15/16 30Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 31: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 31Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 32: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 32Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 33: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 33Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 34: Gas Line Near Indian Point Nuclear Power Plant

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.

12/15/16 34Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 35: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 35Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 36: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 36Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 37: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 37Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 38: Gas Line Near Indian Point Nuclear Power Plant

Discussion

• Suggestions from Elected Officials

• Suggestions from NRC, Entergy, FERC, Spectra, PHMSA

• Suggestions/comments/questions from Students, Professors, the Public

12/15/16 38Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 39: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 39Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 40: Gas Line Near Indian Point Nuclear Power Plant

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

12/15/16 40Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant

Page 41: Gas Line Near Indian Point Nuclear Power Plant

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:

[email protected]

12/15/16 41Co-locating Nuclear Plants with

Natural Gas Pipelines Paul Blanch Energy Consultant