RPI Engineering Symposium Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch, Energy Consultant Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 1 Paul Blanch Energy Consultant
Indian Point the most threatening nuclear facility in the US Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 2 Paul Blanch Energy Consultant
Summary of Problem • Co-location of a nuclear power plant and a natural gas pipeline • Hasty installation of a 42 inch diameter high pressure natural gas pipeline at Indian Point nuclear plant • Calculation of risk for siting approval used a computational tool (ALOHA) that is prohibited for a rupture in this configuration. • NRC/Entergy calculates 1100 foot blast radius. Independent engineers calculate greater than 4000 foot blast radius using NRC-approved equations. • 4000 foot blast radius will engulf entire nuclear site • May disable all site power and back-up safety systems (Fukushima) • A valid risk assessment has not been conducted by the NRC, Entergy, PHMSA, or NYS of neither the existing pipelines nor Spectra ¡Energy’s ¡Algonquin ¡Incremental ¡Market ¡(AIM) ¡pipeline ¡ at Indian Point • No independent risk assessment has been conducted • A risk assessment is required by Federal Regulations • Failure rate for pipelines is increasing • No evacuation protocol for 20 million people in the 50 mile impact radius • No emergency preparedness plan • Lack of public awareness Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 3 Paul Blanch Energy Consultant
Indian Point Looking West Showing Existing Gas Line Route Aerial Photo taken by Paul Blanch June 2010 Width about 3000 feet Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 4 Paul Blanch Energy Consultant
AIM Pipeline Path at Indian Point Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 5 Paul Blanch Energy Consultant
Indian Point 50 mile Evacuation Zone 20 million people impacted Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 6 Paul Blanch Energy Consultant
NRC Equations for Gas Release. Includes heat flux, overpressure and vapor cloud explosions Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 7 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 Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 8 Paul Blanch Energy Consultant
NRC/Entergy Calculation (Results were Redacted) • The NRC and Entergy both calculate a damaging blast radius of about 1100 feet Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 9 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 Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 10 Paul Blanch Energy Consultant
Additional Details of Calculation Problems • NRC scientist with 8 years nuclear experience used prohibited EPA program, ALOHA, and calculated 1100 feet blast radius from 42-inch line (850 psi) • 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) • Chairman Burns of the NRC misrepresented blast calculation to US Congresswoman Lowey (3/24/2015) • Approval of ¡project ¡by ¡FERC ¡based ¡on ¡NRC’s ¡ miscalculation • FERC ¡never ¡saw ¡a ¡copy ¡of ¡NRC’s ¡ calculation Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 11 Paul Blanch Energy Consultant
Blast Information • Entergy admits in 1997 in communication with the NRC that a gas event may cause major damage extending ¡for ¡“several ¡thousand ¡meters” • 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 • 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 • Shut off valves controlled remotely in Houston, TX • NRC used prohibited ALOHA program to miscalculate damage radius • NRC, ¡in ¡response ¡to ¡FOIA ¡request ¡“lost” ¡CD ¡ containing ¡Entergy’s ¡ analysis • No Entergy procedures to terminate leak or fight fire Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 12 Paul Blanch Energy Consultant
Calculation from David Lochbaum Blast Radius of 4200 feet for 3 minute release Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 13 Paul Blanch Energy Consultant
Calculation Summary from NRC Professional Engineer R min =Z*W 1/3 Blast radius of 4300 feet Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 14 Paul Blanch Energy Consultant
Calculation From DOE Professional Engineer Blast radius of 4185 feet Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 15 Paul Blanch Energy Consultant
Calculation by Paul Blanch, PE Blast radius 3000-4000 feet Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 16 Paul Blanch Energy Consultant
Factors Contributing to Increased Risk • Hasty installation • Composition of pipeline metal • Composition of shale gas obtained by hydraulic fracturing • Insufficient regulatory oversight • Non-compliance with regulations Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 17 Paul Blanch Energy Consultant
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 Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 18 Paul Blanch Energy Consultant
Probability of Gas Line Failure from PHMSA 6.6x10 -4 /mile-year Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 19 Paul Blanch Energy Consultant
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 10,000/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 Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 20 Paul Blanch Energy Consultant
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 $1 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 Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 21 Paul Blanch Energy Consultant
Risk Assessment • 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 • 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 ” Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 22 Paul Blanch Energy Consultant
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