Authors: Lawrence S. Criscione, PE and Paul M. Blanch, PE
Date: December 18, 2012
To: Senator Joseph Lieberman, Chairman; U.S. Senate Committee on Homeland Security & Governmental Affairs
[...] We are writing to you and your committee about our grave concern regarding the failure of the Nuclear Regulatory Commission and Homeland Security to protect the United States against potential terrorist attacks and random dam or gas transmission pipeline failures. The potential energy released in a gas line rupture at Indian Point is equivalent to that from a massive conventional bomb; the 2010 explosion and fire in San Bruno, CA is an example of the destructive force, which a pipeline rupture can unleash. [...]
Although a terrorist attack upon or the random failure of a dam or natural gas pipeline is extremely unlikely, the potential impact of one of these events is the meltdown of multiple reactors, at either Indian Point or Oconee, resulting in severe radiological and economic consequences to areas surrounding these plants. For the natural gas pipeline explosion at Indian Point, New York City and areas extending beyond 50 miles, along with the infrastructures could be rendered uninhabitable for generations. [...]
The first enclosure details the vulnerability at the Indian Point Nuclear Power Station due to natural gas lines that pass through the station. It is noteworthy that there was a 20-inch gas line rupture on December 11, 2012 in Sissonville, West Virginia. It was reported this explosion sent flames more than a quarter mile (1300 feet). There are vital structures at Indian Point within 400 feet of much larger and higher-pressure gas lines. (See photos in Enclosure 1). It is a well-known fact that there is little or no protection from either a waterborne or airborne attack. [...]
In addition to potential malevolent acts, our concern is also the failure of the gas pipeline or dam due to natural phenomena (e.g. seismic activity) or latent engineering/construction flaws. The mislabeling by the NRC of these concerns as “Security-Related Information” has impeded their resolution [...]
Paul M. Blanch, Energy Consultant, October 25, 2010
Mr. William Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission
[...] I am submitting this 10 CFR 2.206 petition solely on behalf of myself due to my grave concern about the undue risk presented by the natural gas transmission lines traversing the entire Indian Point site.
In early 2009 I first became aware of the presence of the natural gas lines1 from an Indian Point Condition Report (CR) dated December 2008. This CR identified the existence of gas line or lines and its potential to cause buried pipe corrosion of other lines important to nuclear safety.
After many months of research I determined that the proximity of these gas transmission lines to Indian Point nuclear plants may not have been properly analyzed, may not be in compliance with NRC regulations, and likely present an undue risk to the general public.
My concern increased to alarm at news of the San Bruno, California gas line explosion on September 10 of this year, and the realization that the gas lines passing through the Indian Point facility are the same vintage, however are much larger in capacity.
Specifically, my concerns are:
- • Indian Point is not in compliance with existing regulations or the regulations in effect at the time of the initial issuance of the license.
- • Sections of the gas lines2 are unprotected from those wishing harm to the United States.
- • The potential consequences to the general public and the New York, New Jersey and Connecticut infrastructure are incalculable and could be devastating to the US economy.
- • The potential energy released in one hour3, should a gas line rupture occur, is about the same as that released over Hiroshima in 1945 (about 15,000 tons of TNT).
- • It is possible that a rupture of the lines would result in a significant release of radioactive materials from both operating plants along with possible severe damage to the fuel in the spent fuel pools and subsequent releases.
- • The original license was predicated on the fact that there were automatic shutoff valves in the gas lines; but these were subsequently removed without any apparent analysis as required by NRC regulations4.
- • There has been no specific training by the onsite or offsite fire departments to deal with this type of fire/explosion.
- • There is no means to extinguish a major gas line fire until the flow of gas is terminated (upstream and downstream) from multiple gas transmission lines.
- • Operators may be impaired (dead) due to the heat generated or due to lack of oxygen.
- • It is not know if specific procedures are in place to coordinate with the gas company in the event of a rupture or an explosion.
- • Even if these procedures are in place it is likely communication channels would be disrupted in the event of an explosion/fire.
- • A gas line explosion would likely disable all sources of electrical power due to the proximity to the offsite power and potential lack of oxygen to the emergency power sources.
- • There are no references to the gas lines ability to withstand a seismic event.
- • Testing of the integrity of the gas pipes is unknown.
Published: December 23rd, 2012 at 5:27 pm ET