Mr. Paul Blanch 

135 Hyde Rd. 

West Hartford, CT 06117 

Dear Mr. Blanch: 

UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, D.C. 20555-0001 

November 6, 2015 

I am responding to concerns you have raised concerning Spectra Energy's proposed 42-inch 

diameter natural gas pipeline that is planned to cross the owner-controlled property at the Indian 

Point Nuclear Generating Unit Nos. 2 and 3. 

On October 15, 2014, you submitted a petition (Agencywide Documents Access and 

Management System (ADAMS) Accession No. ML 14294A751), pursuant to Title 10 Code of 

Federal Regulations (10 CFR) Section 2.206, requesting enforcement action against Entergy 

Nuclear Operations, Inc., the licensee for Indian Point Nuclear Generating Unit Nos. 2 and 3. 

You stated that the 10 CFR 50.59 site hazards analysis, prepared by the licensee to determine 

the safety impact on the Indian Point plant due to the proposed pipeline, is inadequate and 

incomplete. You requested that the Nuclear Regulatory Commission (NRC) issue violations of 

10 CFR 50.9, "Completeness and accuracy of information," 10 CFR 50.59, "Changes, tests, and 

experiments," and 10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power 

Plants and Fuel Reprocessing Plants." You also requested that the NRC issue a Demand for 

Information seeking, among other items, that Entergy provide the results of a new and realistic 

risk/hazard analysis. 

In addition, by letter dated July 27, 2015, (ADAMS Accession No. ML 15251A050), you provided 

39 follow-up questions resulting from your presentation before the Petition Review Board (PRB) 

on July 15, 2015 (see transcript at ADAMS Accession No. ML 15216A047). During that 

presentation, the PRB agreed to respond, in writing, to all of your follow-up questions. 

Several of your submittals request NRC involvement that overreaches our regulatory authority. 

This includes NRC review and approval of the proposed pipeline along with the imposition of 

NRC requirements. Examples include requests to treat the pipeline, valves, control systems, 

and construction as safety-related and to require that they meet all NRC regulations including 

quality assurance, redundancy, environmental qualification, and inservice inspections. The 

NRC's role is limited to ensuring the safe operations of Indian Point Nuclear Generating Unit 

Nos. 2 and 3. Other Federal government agencies involved in the proposed Spectra Energy 

gas pipeline expansion include: (1) the Federal Energy Regulatory Commission (FERC), which 

is responsible for evaluating applications for authorization to construct and operate interstate 

natural gas pipeline facilities, (2) the Pipeline and Hazardous Materials Safety Administration of 

the Department of Transportation, which is responsible for administering the national regulatory 

program to ensure the safe transportation of natural gas, petroleum, and other hazardous 

materials by pipeline, (3) the Environmental Protection Agency, which is responsible for 

protecting human health and safeguarding the natural environment, (4) the U.S. Army Corps of 

Engineers which regulates any work or structures that potentially affect the navigable capacity 

of a waterbody, (5) the National Oceanic and Atmospheric Administration's National Marine 
P. Blanch - 2 -

Fisheries Service, and (6) the U.S. Fish and Wildlife Service. In addition, there are multiple 

State and local government agencies that also have separate responsibilities. Therefore, many 

of your requests for NRC intervention cannot be granted by the NRC because they are outside 

of the regulatory authority of the NRC. 

Throughout the PRB review of your petition, the supplemental letters, and your presentations 

before the PRB, you focused repeated attention on a number of issues. The PRB would like to 

summarize its findings on the following items: 

Inaccurate and Incomplete 50.59 Site Hazards Analysis 

The original petition of October 15, 2014, requested violations of 10 CFR 50.59, 50.9, and 

Appendix B to 10 CFR 50 for providing inaccurate and incomplete information in the 50.59 site 

hazards analysis. In addition, you requested a Demand for Information seeking an explanation 

as to why the previous violations do not also constitute a violation of 10 CFR 50.5, "Deliberate 

Misconduct." 

The NRC staff thoroughly reviewed the licensee's 50.59 site hazards analysis and the results of 

that review were documented in the Region I inspection report dated November 7, 2014 

(ADAMS Accession No. ML 14314A052). As indicated in the inspection report, the staff 

determined that Entergy's conclusions involving the potential rupture of the proposed pipeline 

poses no threat to the safe operation of the plant or safe shutdown of the plant, are reasonable 

and acceptable, and are also comparable with the staff's independent confirmatory analysis. In 

addition, staff reviewed the qualifications and resume of Entergy's contractor who performed the 

licensee's analysis and determined that the individual possessed the requisite knowledge, 

experience, and abilities to conduct the pipeline hazards analysis and that the analysis had been 

conducted in accordance with approved procedures. 

Therefore, the NRC staff does not agree with your assertions that the licensee's 50.59 site 

hazards analysis was inaccurate and incomplete and that the contractor performing their blast 

analysis was not qualified to Entergy's Appendix B Quality Assurance Program. As a result, no 

enforcement actions will be taken against Entergy. 

Assumed 3 Minute Isolation Valve Closure Time for the Proposed Spectra Pipeline 

Based on information included in Spectra Energy's application to FERC, Entergy's site hazards 

analysis assumed that remote plant operators located in Houston, TX, would be able to 

recognize a pipe rupture from pressure sensors located in the pipeline and take appropriate 

actions to close the pipeline isolation valves within 3 minutes of a major pipe rupture. You 

characterized this assumption as a material false statement. 

Due to concerns regarding the significance of the assumed valve closure time, the NRC staff 

performed a bounding sensitivity analysis. The staff's sensitivity analysis consisted of two 

cases. First, the staff considered the case when the isolation valves are assumed to close 

within the time specified by Spectra Energy (3 minutes). Second, the staff assumed the release 

of gas for a full hour with the unbroken end of pipe connected to an infinite source. The 

resulting pressure pulse and heat flux values are only marginally different from one another and, 

in both cases, showed that equipment relied on to safely shut down the facility would remain 

available and operable. Therefore, the staff concluded that valve closure times do not have a 
P. Blanch - 3 -

significant impact on the site hazard analysis, and the licensee's assumption of a 3 minute valve 

closure time does not have a material impact on that analysis. 

Request for an Independent Risk Assessment Including a Transient Risk Analysis 

The NRC, an independent regulatory agency, prepared its own independent confirmatory 

analysis of the effects on safety related equipment resulting from a postulated pipeline rupture 

and the results were comparable to those submitted by the licensee. For the evaluation of the 

explosion hazard, the NRC staff used the peak gas release rate resulting from a pipe rupture to 

estimate the mass of natural gas that would be available. This approach predicts more gas 

released than other approaches like a time dependent gas release or a release averaged over 

time. 

The conservative, bounding analysis prepared by the NRC staff postulates more severe results 

than a transient analysis. A transient analysis averages the release of gas over time and the 

release rate would gradually decline. As described above, the NRC analysis assumed that the 

maximum release rate was sustained and did not decline in the manner that a transient analysis 

would predict. This conservative approach assumes more gas is available to explode than in a 

transient analysis, and produces results that bound more detailed analyses, such as a transient 

analysis. 

Considering that the NRC's independent analysis is conservative and bounding, the 

NRC concludes there is no need for another NRC sponsored independent analysis. 

The NRC Should Withdraw its Findings to the Federal Energy Regulatory Commission 

You have requested that the NRC withdraw its findings to FERC that the proposed 

pipeline would not present an unacceptable risk to the Indian Point facility. The staff 

has performed a thorough review of Entergy's 50.59 site hazards analysis and has 

performed its own independent confirmatory analysis that is in agreement with the 

licensee's results. The NRC has no basis to withdraw its previous conclusions to 

FERC. 

Follow-up Questions from the PRB Presentation of July 15. 2015 

During your second presentation before the PRB on July 15, 2015, the PRB agreed to respond 

to your follow-up questions. Your letter of July 27, 2015, included a list of 39 questions. We 

have responded to your questions in the enclosure. 

In summary, the NRC's role in the proposed natural gas pipeline is limited to its regulatory 

authority of ensuring the safe operation of the Indian Point operating facility. Based on the 

review of Entergy's 50.59 site hazards analysis and the NRC's independent calculation results 

using conservative assumptions and rationale, the staff has determined that Entergy has 

appropriately concluded that the proposed pipeline does not introduce more than minimal 

additional risk to the Indian Point facility and, therefore, the change in the external hazards 

analysis associated with the proposed pipeline does not require prior NRC review and approval. 
P. Blanch - 4 -

The NRC appreciates your concerns and will continue to evaluate all new information 

regarding the existing and proposed natural gas pipelines through the Reactor 

Oversight Program. 

Docket Nos.: 50-247 and 50-286 

Enclosure 

As stated 

Sincerely, 

J2 

Christopher G. Mill , irector 

Division of License Renewal 

Office of Nuclear Reactor Regulation 
PETITIONER QUESTIONS RELATIVE TO 

PETITION REVIEW BOARD MEETING OF JULY 15, 2015 

INDIAN POINT PROPOSED NATURAL GAS PIPELINE 

The petitioner's letter dated July 27, 2015, grouped questions together according to 

subject area. Each group of questions was preceded by a preamble. For the purpose 

of clarity, the preamble has been italicized followed by each question and the NRC 

staff's response. 

Freedom of Information Act (FOIAJ Requests 

FOIA response #1 (ADAMS Accession No. ML 15061A219 contains a summary and 

handwritten calculations that are not signed, dated, approved, reviewed, etc. 

Furthermore, an arbitrary and undefined term is added to the equation "Y" that results in 

a conclusion that grossly underestimates Potential Impact Radius (PIR), therefore the 

risk to the public. 

FOIA response #2 (ADAMS Accession No. ML15247A108) contains an email from David 

Beaulieu dated April 27, 2015 (ADAMS Accession No. ML 15274A108), which 

discusses gas pipeline dynamics. The information in this email directly contradicts the 

information provided to FERG by the NRG in its confirmatory analysis used in its 

approval of the Spectra Algonquin Incremental Market (AIM) project. This internal 

NRG email primarily addresses the operator response times and the amount of gas 

that will be released during a rupture. The gas release rate according to this email is 

close to one million pounds of gas per minute and likely to continue for hours. The 

result is that the NRG contradicts its own guidance (Regulatory Guide 1.91) for 

measuring (PIR) and clearly contradicts both the Entergy and the NRG analysis. 

We now know from the NRG email of April 27, 2015 that the volume of gas and the 

amount of time it would take to terminate the gas flow totally undermine the public 

confidence that Entergy and the NRG are properly operating and regulating the plant. 

Moreover, because the blast radius, heat flux and vapor clouds effects are very likely 

underestimated. A long term Station Blackout (SBO) may result. Additionally we are 

now aware that the fuel oil tanks likely contain flammable material that has not been 

considered in any analysis. 

The ramifications of these undocumented calculations and alleged material false 

statements are so grave that the NRG must rescind its approval of the pipeline 

because FERG based its approval of the Spectra AIM project on the alleged material 

false statements made to the NRG by Entergy in its analysis dated August 21, 2014 

until a truly independent risk analysis is conducted. 

The NRG provided its final analysis and approval to FERG in its inspection report dated 

November 7, 2007. The NRG personnel participating in this inspection have no 

documented experience in gas line accidents. In fact, the NRG's primary contributor, 

Mr. Tammara, has no documented experience in gas rupture dynamics or experience 
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with other events such as the San Bruno and other major gas line catastrophes and 

was not a member of the team conducting the inspection. 

Mr. Richard Kuprewicz, a nationally recognized pipeline expert, and others have 

requested that the NRG endorse an independent, transparent, thorough risk 

assessment by recognized experts. The public and elected officials, including 

Senators Charles Schumer and Kirsten Gillibrand and Congresswoman Nita Lowey 

have also made this request, yet the NRG continues to stand by its confirmatory 

analysis of November 7, 2014 and refuses any consideration of any independent risk 

analysis by experts with documented credentials. 

After the second presentation to the Petition Review Board, Mr. Richard Kuprewicz 

wrote to NY Assemblywoman Sandy Galef with a suggested plan for a transient risk 

analysis "that incorporates the true transient nature of a pipeline rupture capturing the 

extremely high change in gas rate release with time that reflects the tremendous 

extremes of a gas transmission pipeline rupture, especially on a 42-inch high pressure 

pipeline." Mr. Kuprewicz's plan could form the basis for the portion of the independent 

risk assessment. 

Entergy, in its 10 CFR 50. 59 analysis, stated that a rupture of the existing buried gas 

pipeline due to sabotage was not considered in the 2008 risk study conducted by 

Mr. David Allen that evaluated the potential terrorist threat to the exposed portions of 

the existing gas lines. Mr. Art Burritt of the NRG confirmed that failure of the existing 

gas pipeline may impact safety related Structures, Systems and Components (SSCs) 

at Indian Point located within 400 feet of these SSCs. This is an unanalyzed condition 

that requires immediate NRG attention. 10 CFR 50. 72 requires reporting of this 

potential event within 8 hours, yet the NRG has not taken any visible actions to 

address this issue after more than four weeks while the plants continue to operate in 

an unanalyzed condition. 

Questions 

1. Please identify the missing information in FOIA document 1, including the date, 

author, approval chain, reviewers and the NRC's procedure for conducting safety 

related calculations. 

Response 

The NRC continues to withhold certain information in FOIA document 1 due to 

its security sensitive nature. The qualifications of the individual who performed 

the calculation are described in NRC Inspection Report 05000247/2014004 and 

05000286/2014004 dated November 7, 2014(ML14314A052). The calculation 

in FOIA document 1 was performed to support the above inspection and 

received an independent peer review within the NRC. 

The NRC does not perform "safety-related calculations." Therefore, the NRC 

staff does not have specific procedures for performing calculations used to 
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support inspections or to perform confirmatory analysis. The term, "safetyrelated calculations" implies formal calculations performed by licensees for the 

design of NRC regulated facilities. Safety-related calculations by licensees must 

be performed in accordance with approved plant procedures and associated 

quality control. Calculations performed by the staff do not require the same level 

of documentation and are performed as needed to support independent 

confirmatory analysis. 

2. In FOIA document 1, the NRC in its risk calculation modifies equation #1 of 

RG 1.91 by inserting an undefined term "Y". What is this undefined term and 

why was it used? Its impact may be significant. 

Response 

NRC Regulatory Guide (RG) 1.91, "Evaluations of Explosions Postulated to Occur at Nearby 

Facilities and on Transportation Routes Near Nuclear Power Plants," describes methods 

that the NRC staff finds acceptable for evaluating postulated explosions at nearby facilities 

and transportation routes. The NRC did not modify any of the equations in RG 1.91 as part 

of its confirmatory analysis. 

Equations (3) and (4) of RG 1.91 explains how TNT equivalent, WTNT, is determined and 

how equation (1) is used to determine the maximum distance from an explosion where an 

overpressure of 1.0 psi [pounds per square inch] is predicted to exist. Specifically: 

where 

RG 1.91 Equation (3) 

E=blast wave energy 

a=yield (i.e., the fraction of available combustion energy participating in blast 

wave generation) 

f!.Hc=theoretical net heat of combustion 

mF=mass of flammable vapor released 

WTNT=E/4420 kj/kg 

WTNT= af!.Hcmd4420 

RG 1.91 Equation (4) 

Combining (3) and (4) 

The yield factor, a, included in Equation (3) is designated as "Y" in the NRC confirmatory 

calculation found in FOIA document 1 (ADAMS Accession No. ML 15061A219). This is 

consistent with the methodology of RG 1.91 without any modifications to equation (3). 

Table 1 of RG 1.91 provides suggested yield factors and, for methane, 5% (0.05) is used. 

3. Please provide the specific qualifications of the personnel conducting the 

inspection that provided the basis for the approval of the AIM project to FERC on 

November 7, 2014. 
- 4 -

Response 

NRC Inspection Report 05000247/2014004 and 05000286/2014004 dated November 7, 

2014 (ADAMS Accession No. ML 14314A052), identifies the inspectors who performed the 

inspection. All NRC inspectors must complete a rigorous qualification program that 

demonstrates that they possess the knowledge and skills necessary to effectively perform 

regulatory activities in their position. The knowledge and skills can be obtained through 

previous experience, formal training, study activities, and on-the-job training activities. Upon 

completion of the qualification program, the employee must pass an oral qualification board 

to confirm that the individual can integrate and apply agency, office, and position-specific 

competencies to actual situations. Inspector qualifications are continually maintained and 

enhanced through post-qualification and refresher training to ensure that the NRC has the 

skills needed to fulfill its mission. 

4. In FOIA document 2 (ADAMS Accession No. ML 15247A108), the NRC stated that 

the PIR [potential impact radius] would not be significantly impacted should the gas 

release continue for one hour instead of 3 minutes. Equation #1 of Regulatory 

Guide 1.91, that calculates the blast radius, directly contradicts this statement and 

predicts the PIR will be increased by a factor of 2.71 with a new PIR of about 3000 

feet. How can the NRC ignore its own primary guidance? 

Response 

The NRC has not ignored its own primary guidance. Equation (1) of Regulatory Guide 1.91 

states: 

Where 

Rmin=Z * W113 

Rmin = distance from explosion where pressure equals 1 psi 

Z =conversion factor (a constant) 

W = equivalent tons of TNT 

The NRC used the ALOHA code to determine the equivalent tons, W, to use in Equation (1) 

above. The ALOHA code recognizes that the bulk of the gas released would dissipate due 

to turbulence and buoyancy and would not be available for an explosion. Predicting an 

increase of the PIR by a factor of 2.71 is a misapplication of Equation (1) of RG 1.91. This 

misapplication increases W by a factor of 20 to account for a full hour release rather than 3 

minutes. The factor of 2.71 is obtained by taking the cube root of 20. This approach is not 

realistic, ignores the buoyancy of natural gas and dissipation from turbulence, and assumes 

that natural gas will accumulate for a full hour and remain available for an explosion. 

5. Will the NRC agree to an independent risk assessment prior to allowing any further 

construction on the project and any further disturbance to land? The composition of 

the team conducting the independent risk assessment must include nuclear and 

gas experts and there must be representation of stakeholders, including the public 

and impacted residents, as well as local, state and federal elected officials. The 

NRC may elect to be a part of this risk analysis team. 
- 5 -

Response 

The NRC does not have the authority to allow or reject the construction of this project. The 

NRC's role was, and is, to ensure that the licensee of the Indian Point facility adequately 

assessed the safety implications of the proposed pipeline at the nuclear site, as well as to 

determine if the licensee's analysis met the NRC's requirements regarding plant changes. 

The NRC found that the licensee adequately addressed the safety implications and that the 

proposed pipeline poses no threat to the safe shutdown of the facility. That having been 

said, the NRC, an independent government agency, performed its own independent 

confirmatory analysis of a potential rupture of the proposed natural gas pipeline and whether 

it would affect the safe operation of Indian Point. The analysis was conservative and 

bounding. The results of the NRC's analysis were similar to that obtained by Entergy's 

contractor, The Risk Research Group, Inc., and confirmed that a breach of the proposed 

natural gas pipeline will not prevent an orderly safe shutdown of the Indian Point facility. 

The staff does not believe that additional analyses of the proposed pipeline are necessary. 

6. When will the NRC conduct a thorough safety analysis of the existing 63-year old 

buried pipeline, which by Mr. Burritt's own admission, this failure is likely to impact 

vital structures without any documented analysis? 

Response 

The NRC and its predecessor, the Atomic Energy Commission (AEC), have conducted a 

thorough safety analysis of the existing natural gas pipelines multiple times. Each time, the 

NRC or AEC staff concluded that the failure of the existing gas pipelines will not impair the 

safe operation or shutdown of the Indian Point facility. 

Among the many analyses documented are the AEC's Safety Evaluation Report, issued on 

September 21, 1973 (ADAMS Accession No. ML072260465), which stated on p. 2-4 that: 

"Two natural gas lines cross the Hudson River and pass about 620 feet from the Indian 

Point 3 containment structure. Based on previous staff reviews, failures of these gas lines 

will not impair the safe operation of Indian Point 3." The previous staff reviews were the 

NRC's review of the Preliminary Safety Analysis Report, submitted by Consolidated Edison 

on August 30, 1968 (ML093480204). 

On December 6, 1995 (ADAMS Accession No. ML 11227A100), the licensee submitted the 

Individual Plant Examination of External Events (IPEEE) report for Indian Point. In this 

report, the licensee first evaluated any susceptibility to damage from seismic events. Based 

on a hazard analysis, the licensee concluded that the probability of occurrence was low 

enough that the pipelines could be screened out as a seismic vulnerability. The licensee 

next considered pipeline failures from other causes, such as an inadvertent overpressure 

condition. Although the licensee concluded there is a small probability that conditions could 

exist that would cause damage to Indian Point Unit 3, it screened this scenario out from 

further consideration based on the low probability of the scenario. The NRC's staff 

evaluation report of the Indian Point Unit 3 IPEEE did not identify any deficiencies with this 

approach. 
- 6 -

In April 2003, NRC staff undertook a review of the possible consequences of a rupture of a 

pipeline, independent of the probability of a pipeline failure. The staff concluded that for a 

large rupture and resulting fire, safety-related structures would not be significantly affected. 

With respect to potential fires, the effects are limited to possible ignition of flammable 

materials such as wood, as well as injury of exposed on-site personnel (principally skin 

burns). For the one scenario that might damage safety-related structures (the explosion of a 

large unconfined vapor cloud), the staff concluded that the factors needed to achieve an 

explosion creating sizeable overpressures make the probability for occurrence very low. 

In 2008, the licensee contracted another evaluation of the pipelines. In an evaluation dated 

August 14, 2008, the contractor evaluated three scenarios based on a simultaneous rupture 

of both pipelines; a jet fire, a vapor cloud flash fire, and a large vapor cloud explosion. The 

NRC reviewed this analysis and concluded that failures of these gas pipelines will not impair 

the safe shutdown of Indian Point. 

Pipeline Integrity 

The NRG Petition Review Board stated in a letter dated April 28, 2015 to me: (ADAMS 

Accession No. ML 15124A027)." The pipeline isolation valves are constructed under 

criteria developed by the U.S. Department of Transportation (DOT). Therefore, the 

petitioner's concerns regarding the safety class of the isolation valves should be 

directed to DOT." The NRG has no authority to delegate nuclear safety to the DOT. 

The operations, integrity, and inspections of these valves are partially designed "to 

prevent or mitigate the consequences of accidents which could result in potential 

off site exposures" to the environment and are therefore safety related. See 10 GFR 

50.2 below. 

10 CFR 50.2 Definitions 

Safety-related structures, systems and components means those structures, 

systems and components that are relied upon to remain functional during and 

following design basis events to assure: 

(1) The integrity of the reactor coolant pressure boundary 

(2) The capability to shut down the reactor and maintain it in a safe shutdown 

condition; or 

(3) The capability to prevent or mitigate the consequences of accidents 

which could result in potential off site exposures comparable to the 

applicable guideline exposures set forth in§ 50.34(a}(1} or§ 100.11 of 

this chapter, as applicable. 

Ouestjons: 

7. How will the NRC assure nuclear safety and impose NRC Regulations on the design and 

construction of the proposed AIM project? 
- 7 -

8. How will the NRC assure that the valves, piping, control systems and leak detection systems 

and other vital components meet the following NRC Regulations: 

Quality Assurance 

Redundancy 

Environmental Qualification 

I n-Service-1 nspections 

• ASME codes 

• Technical Specifications 

Emergency response 

Operator training 

• Other NRC Regulations for safety related components 

Response to Questions 7 and 8 

The NRC does not have the regulatory authority to impose its requirements on natural gas 

pipelines. A complex interstate natural gas pipeline expansion such as this requires the 

involvement of a number of Federal and State government agencies all having their distinct 

responsibilities. Other Federal government agencies involved in the proposed Spectra 

Energy gas pipeline expansion include: (1) the Federal Energy Regulatory Commission, 

which is responsible for evaluating applications for authorization to construct and operate 

interstate natural gas pipeline facilities, (2) the Pipeline and Hazardous Materials Safety 

Administration of the Department of Transportation, which is responsible for administering 

the national regulatory program to ensure the safe transportation of natural gas, petroleum, 

and other hazardous materials by pipeline, (3) the Environmental Protection Agency, which 

is responsible for protecting human health and safeguarding the natural environment, (4) the 

U.S. Army Corps of Engineers, which regulates any work or structures that potentially affect 

the navigable capacity of a waterbody, (5) the National Oceanic and Atmospheric 

Administration's National Marine Fisheries Service, and (6) the U.S. Fish and Wildlife 

Service. The design and construction of the proposed pipeline will be performed in 

accordance with the applicable regulations found in Title 49 of the Code of Federal 

Regulations administered by the Pipeline and Hazardous Materials Safety Administration 

within the Department of Transportation. Therefore, the NRC will not perform a review of 

the proposed pipeline, and there will be no attempt to impose NRC regulations on the 

design and construction of the pipeline. 

The NRC's role with respect to the proposed pipeline is limited to ensuring the safe 

operation of the Indian Point facility. In this regard, NRC regulations required the licensee to 

perform a site hazards analysis to determine the safety impact of the proposed pipeline. 

Entergy performed this analysis and submitted it for public inspection on August 21, 2014 

(ADAMS Accession No. ML 14253A339). The Entergy analysis concluded, and the NRC 

independently confirmed, that the proposed pipeline will not impair the safe operation or 

shutdown of the Indian Point facility. 
- 8 -

Valve closure time 

Entergy, in its analysis, stated the gas flow would be terminated within 3 minutes, 

should a rupture occur. I believe this to be a material false statement. 

The Entergy 10 CFR 50.59 safety evaluation confirmatory analysis (EN-L/-101ATT9.1, Rev.11) 

states: 

The existing pipeline automation and control system, which would be used for the 

proposed new 42-inch pipeline near JPEG [Indian Point Energy Center], does not 

provide for an automatic isolation of the closest upstream and downstream 

mainline valves upon the detection of a pipeline rupture. 

The two closest actuated valves are located at milepost 2.61 on the west side of 

the Hudson River and at milepost 5.47 just east of JPEG. They would require an 

operator to take action to close these valves. The system, however, is monitored 

24 hours a day and an alarm would immediately alert the control point operator, 

located in Houston, Texas, of an event and isolation would be initiated. This 

would result in all of the gas between these valves at the time of closure being 

able to vent or burn. The estimated time to respond to the alarm (less than one 

minute) and the closure time of the valves (about one minute) was used as the 

basis for an assumed closure time of three minutes for the analysis performed in 

the attached report." 

In the email of April 27, 2015 (FO/A document 2) from David Beaulieu to NRG staff, 

including Mr. Douglas Pickett, the premise for the 3-minute timeframe for remote valve 

closure was re-evaluated. It concurs with Mr. Kuprewicz's statement during the first 

petition review call on January 28, 2015, that a pressure drop may not be identified 

right away. The Beaulieu email cites a report from the Oak Ridge National Laboratory, 

"The time between a pipeline break and RCV closure can vary from about 3 minutes 

for immediate leak or rupture detection to hours if field confirmation of the break is 

necessary to validate the closure decision." 

The NRG based its recommendation to FERG on the 3-minute remote closure time. 

This NRG internal document is more than sufficient to grant my petition as it 

substantiates the submission of information contrary to the requirements of 

10 CFR 50.9. 

Mr. Kuprewicz reviewed the FOIA documents in preparation for the PRB call and wrote 

an email to me on July 14, 2015 in which he stated: 

Rupture will always be a full bore rupture, releasing at both ends of the open 

pipes as the fracture mechanics forces throw tons of buried pipe steel out of the 

ground yielding very large craters (the location of the rupture at these pressures 

should be performed at a site nearest the plant). 

The location of the rupture so close to an upstream compressor station will 

mask pressure loss indications for quite some time, as mass release 
- 9 -

significantly exceeds the flow rate in the pipeline before rupture. Pressure loss 

indication will not be the primary indicator of a pipeline rupture for quite some 

time. 

Right now I believe, very high heat fluxes will be the most likely scenario that 

may impact equipment to safely shutdown the plant, though blast forces cannot 

at this time be evaluated on these various structures, my experience would 

suggest blast is not controlling on the facility though you have a better 

understand of specific plant safety equipment location needed to cool down the 

facility. 

The repeated attempts to convey that an analysis of a rupture at this site near 

the plant on the 42-inch actually reflects the actual rupture case reflects a 

serious lack, even negligent (a term I don't use lightly in public) attempt, to 

properly analyze a 42-inch pipeline rupture scenario, on this line at this site, on 

this system. 

Any critical independent analysis should clearly define the base case scenario 

and pipeline operating conditions (flow, pressure) before trying to defend any 

resulting conclusions. 

Questjons: 

9. How many valves are required to be closed should a rupture occur in either the proposed or 

the existing gas lines? 

10. Are all of these valves remotely operated? 

11. Is a single failure1 considered? 

Response to Questions 9, 10, and 11 

The design and construction of the proposed pipeline, which includes requirements for the 

pipeline isolation valves, will be performed in accordance with the applicable regulations 

found in Title 49 of the Code of Federal Regulations administered by the Pipeline and 

Hazardous Materials Safety Administration within the Department of Transportation. 

As explained in the response to questions 7 and 8, the NRC does not have the regulatory 

authority to impose its requirements on natural gas pipelines. Therefore, the NRC will not 

perform a detailed design review of the proposed pipeline and there will be no attempt to 

impose NRC regulations on the design and construction of the pipeline. 

1 Single failure. A single failure means an occurrence which results in the loss of capability of a component to perform 

its intended safety functions. Multiple failures resulting from a single occurrence are considered to be a single failure. 

Fluid and electric systems are considered to be designed against an assumed single failure if neither (1) a single 

failure of any active component (assuming passive components function properly) nor (2) a single failure of a passive 

component (assuming active components function properly), results in a loss of the capability of the system to perform 

its safety functions. (10 CFR Part 50, Appendix A) 
- 10 -

12. Why has the NRG not informed FERG that the fundamental assumptions and calculations 

were inaccurate? 

Response 

The NRG staff concludes that the fundamental assumptions and calculations relied upon for 

its confirmatory analysis remain accurate. 

Independent analyses performed by both Entergy and the NRG staff concluded that a 

rupture of the proposed pipeline will not adversely impact the safe shutdown of the Indian 

Point facility. The staff's confirmatory analysis was conservative and bounds expected 

conditions that would result from a pipeline rupture. 

13. Has the NRG staff reviewed the piping and instrumentation (P&IDs) diagrams for the new 

gas line showing valves, pressure, flow and leak detection instruments? If so, please 

describe. Does the design meet all NRG requirements to assure all regulations, codes and 

standards are being properly applied and met? 

14. Has the NRG evaluated Spectra's procedures and operator response times and 

ability to detect a significant loss of integrity of a major gas line? 

Response to questions 13 and 14 

No. The staff does not plan to perform a detailed review of piping and instrumentation 

diagrams for the pipeline. As explained in the response to questions 7 and 8, the NRG does 

not have the regulatory authority to impose requirements on natural gas pipelines. The 

NRG will not perform a review of the proposed pipeline procedures or Spectra operator 

training. 

15. Has the NRG evaluated Spectra's safety record with regard to pipeline leaks and incidents? 

A Spectra pipeline ruptured in the Arkansas River on May 31, 2015 and the company did not 

know about it for over 24 hours. 

16. Why, as stated by the NRG in the Petition Review Board call on July 15, 2015, did the NRG 

not look at the 30" San Bruno pipeline rupture incident in 2010, or other major gas line 

ruptures documented by the NTSB [National Transporation Safety Board], when doing the 

confirmatory analysis of the 42" diameter AIM pipeline? 

17. What historical data did the NRG use in its confirmatory analysis to evaluate the risk of 

rupture of the 42-inch diameter high-pressure pipeline? 

Response to questions 15. 16. and 17 

As previously discussed, the NRG's regulatory authority regarding the proposed pipeline is 

limited to ensuring the safe operation of the Indian Point facility. In that regard, the NRG 

reviewed the analysis conducted by the Indian Point licensee, which concluded that 

operation of the new pipeline would have minimal impact on plant safety and would not 
- 11 -

require a license amendment. In addition, the NRC staff performed an independent 

confirmatory analysis which was conservative and bounding. The staff's analysis was 

deterministic and did not rely on quantitative risk or probabilities of failure. Therefore, 

historical information regarding previous natural gas pipeline ruptures and Spectra Energy's 

safety record was not material and not considered as part of the NRC staff's review and 

confirmatory analysis. 

Blast radius 

Regulatory Guide 1.91 contains an equation #1 for determining the blast radius or 

Potential Impact Radius. According to Entergy's and the NRC's analyses, both Entergy 

and the NRG calculate the blast radius from a rupture of a 42 inch diameter pipeline 

operating at 850 psi in the range of approximately 1100 feet. 

If the amount of gas released continues for one hour instead of 3 minutes about 20 

times more gas will be released. According to the NRC's own equation #1, this alone 

will increase the blast radius from about 1100 feet to about 3000 feet without any 

consideration of vapor clouds or heat flux. 

Furthermore, the June 29, 2015 letter from the NRG to me addresses reference #6 

"Risk Analysis of Natural Gas Pipeline: Case Study of a Generic Pipeline," Chiara 

Vianello", Giuseppe Maschio Universita di Padova, DIPIC - Dip. di Principi e lmpianti 

Chimici di lngneria Chimica Via Marzolo 9- 35131 Padova, Italy" that projects a PIR 

approaching 8000 feet. 

According to the Entergy report of August 21, 2014, the two SSCs Important to Safety 

(ITS) structures closest to the new AIM pipeline are the switchyard (115 ft.) and the 

GT213 fuel tank (105 ft.). The report states, "a loss of the SSCs important to safety 

would not result in a significant decrease in the margin of safety provided for public 

health and safety except for the assumed loss of the switch yard and GT 213 FOST, 

which are more significant SSCs ITS." However, the evaluation then continues, "a 

postulated gas pipeline rupture near the switchyard could cause total loss of the 

switch yard of the type that could occur with low probability events such as extreme 

natural phenomena (e.g. earthquake, tornado winds/missiles, hurricanes, etc.) that the 

switchyard is not protected against. The potential loss of the switch yard can result in 

loss of offsite power to the plant and result in a generator or turbine trip with or without 

fast bus transfer to the turbine generator bus. This is considered a relatively high 

probability event ... " The report goes on to analyze the loss of back-up power and 

Entergy concludes that design enhancements reduce risk, however this risk reduction 

is not analytically supported. 

The conclusion in the report is not supported by the NRG regulations and is refuted in 

its internal documents, references and citations. There most certainly is a risk of 

complete loss of power, failure of back-up generation, loss of the access road and the 

city water tank and the risk of a full system failure must be evaluated in a thorough, 

transparent, independent risk assessment. Entergy may have analyzed the loss of the 

switchyard and the FOST independently, but not due to a single initiating event. 
- 12 -

Questions 

18. Why would the NRC revert to such an obscure reference #6 that is not even cited in 

RG1.91? 

19. Why does PIR radius range from 800 to 8000 feet depending on reference 

used? Why did the NRC use the smaller radius when assessing risk? 

Response to questions 18 and 19 

The NRC's letter dated June 29, 2015 (ADAMS Accession No. ML 15097A190), states that 

the acceptance criteria for evaluating potential hazards are found in Standard Review 

Plan 2.2.3, "Evaluation of Potential Accidents." The acceptance criteria requires licensees 

to either: (1) use a deterministic approach to evaluate the impacts of a hazard, or (2) 

demonstrate that that the quantitative risk is acceptably low on the basis of low probability of 

explosions. A demonstration that the rate of exposure to a peak positive incident 

overpressure in excess of 1.0 psi (6.9 kPa) is less than 1 x10-5 per year when based on 

conservative assumptions, or 1x10-7 per year when based on realistic assumptions, is 

acceptable. 

The NRC staff performed an independent confirmatory analysis using a conservative 

deterministic analysis that assumed a double-ended rupture of the proposed gas pipeline. 

The staff's analysis did not consider probabilities. Therefore, a probabilistic analysis was 

not required and any technical argument regarding the use of probabilities is moot for this 

approach. The staff's discussion of probabilities included in the letter of June 29, 2015, 

along with the inclusion of Reference 6, demonstrated the rationale and conservatisms of 

NRC's assumptions in addressing the event frequencies for the consequences of a 

catastrophic pipeline rupture. The cited Reference 6 discussed vapor cloud explosion and 

heat flux scenarios pertaining to generic pipelines and, therefore, there is no direct 

relevance between the reference and the methodology of RG 1.91. Consequently, a 

comparison of PIR radii range is neither applicable nor appropriate. 

Finally, the NRC staff disagrees with the above extrapolation of the blast radius from 1100 to 

3000 feet. As discussed in the response to question 4, it is a misapplication of Equation (1) 

of RG 1.91 to extrapolate a 3 minute gas pipeline release to a 1 hour gas pipeline release by 

multiplying the available mass by a factor of 20 and taking the cube root. Multiplying the 

calculated safe distances by a factor of 2.71 (i.e., the cube root of 20), ignores buoyancy of 

natural gas and artificially assumes that the entire amount of gas released over an hour will 

remain confined and available for an explosion. Thus, the above argument extending the 

calculated safe distance of 1100 feet to 3000 feet is flawed. 

Questions 

20. Why do the NRC and Entergy use very different formulas to calculate blast radius, 

both claiming compliance with RG 1.91? 

21. Why did the NRC modify the equation for calculating the blast radius in RG 1.91? 
- 13 -

22. RG 1.91 specifically states "Methods and solutions that differ from those set forth 

in regulatory guides will be deemed acceptable if they provide a basis for the 

findings required for the issuance or continuance of a permit or license by the 

Commission." These calculations and methods differ from the Regulatory Guide. 

Did the NRC use RG 1.91, as the sole reference for evaluating explosions 

postulated to occur at nearby facilities and on transportation routes near nuclear 

power plants? 

23. Why did Entergy and the NRC fail to provide a basis for deviation from the 

Regulatory Guide? 

Response to Questions 20. 21. 22. and 23 

RG 1.91 is the staff's guidance document for evaluating the impact of explosions from 

nearby facilities and transportation routes. Entergy and the NRC used the methodology and 

equations of RG 1.91, without deviation, to determine the blast radius of 1.0 psi. No other 

methodology was used. As discussed in the response to question 2, neither Entergy nor the 

NRC modified the equations of RG 1.91. 

24. Why would the NRC use the EPA computer program (ALOHA), which is prohibited 

for use for a gas pipeline rupture, not referenced in RG 1.91, to calculate the blast 

radius of a rupture that could have a devastating impact to the more than 20 million 

persons residing in the vicinity of Indian Point? 

Response 

The NRC staff used the Areal Locations of Hazardous Atmospheres (ALOHA) 

computer code to determine the mass of natural gas resulting from a double-ended 

pipeline rupture that would be available for an explosion. The ALOHA computer 

program does not prohibit its use for modeling gas pipeline ruptures. It is important 

to understand what is meant by the ALOHA User's Manual statement: "ALOHA 

cannot model gas release from a pipe that has broken in the middle and is leaking 

from both broken ends," and how the staff modeled its confirmatory analysis to 

address this limitation. 

In order to determine the minimum safe distance to 1 psi overpressure using the 

methodology of RG 1.91, it is necessary to determine: (1) the initial gas release rate from 

the pipeline break and (2) the total amount of gas available for an explosion at the source of 

the release. The calculated release may be determined by equations available in standard 

literature reference material or by using appropriate computer models. In this case, the 

NRC staff used the ALOHA computer code as a tool to calculate the maximum release rate, 

which is converted by hand calculation to TNT equivalent. The TNT equivalent value is then 

used to calculate the minimum safe distance to 1 psi overpressure using the methodology of 

RG 1.91. The ALOHA code was not directly used to calculate the minimum safe distance. 

The ALOHA User's Manual includes conditions and limitations for its use. Specifically, when 

modeling a pipe rupture, ALOHA assumes unidirectional flow from only one end of the 

broken pipe. Thus, when modeling a guillotine pipe rupture, all flow is assumed to be 
- 14 -

released from one end of the broken pipe without any backflow from the opposite, or 

downstream end of the pipe. Clearly, some amount of backflow would be expected from the 

downstream end of the broken pipe and some type of correction is necessary to use ALOHA 

to model this scenario. 

When evaluating a break in the middle of a pipeline, the NRC staff doubled the predicted 

gas release from the upstream side of a pipe break to account for flow escaping from both 

sides of the break. This approach is conservative because in the event of an actual break, 

the downstream side of the pipe would release much less gas than the estimated release 

from the upstream side. 

The staff also compared release rates calculated by ALOHA with average release rates 

calculated manually, based on equations available in reference literature and reports. The 

ALOHA model calculated maximum and average release rates that are higher than the 

release rates calculated by hand and, therefore, are considered conservative for this 

application. Accordingly, the staff is confident that its use of the ALOHA code is appropriate 

for this application and results in conservative gas release rates. 

25. Has the NRC performed a validation and verification of the ALOHA program to 

ascertain its accuracy? 

Response 

There is no need for the NRC staff to perform a validation and verification of the ALOHA 

computer program. ALOHA has been measured against similar computer models and the 

results are considered comparable. 

ALOHA is part of the CAMEO® software suite, which is developed jointly by the National 

Oceanic and Atmospheric Administration (NOAA) and the U.S. Environmental Protection 

Agency (EPA). Versions of ALOHA have existed since the early 1980s. ALOHA is a computer 

program designed to model chemical releases for emergency responders and planners. It can 

estimate how a toxic cloud might disperse after a chemical release and it includes several fire 

and explosion scenarios. ALOHA can model how a hazardous gas cloud will travel downwindincluding both neutrally buoyant and heavy gas dispersion. Additionally, if the chemical is 

flammable, ALOHA also models pool fires, vapor cloud explosions, jet fires, and flammable gas 

clouds (where flash fires might occur). 

Blast Impact 

The NRC's email from April 27, 2015 states the quantity of gas released in a pipeline 

rupture is calculated by the same prohibited ALOHA program as 376,000 kg in the first 

minute and a release of 200, 000 kg in the next two minutes (accounting for the 

pressure drop) and 100, 000 kg after the valve closure. In the first four minutes, the 

amount of energy released is equal to that from the atomic bombs dropped on Japan in 

1945. Once more the use and results of ALOHA for this calculation is questionable 

however assuming these numbers are correct: 
- 15 -

Questions 

26. Why would the NRC allow tons of TNT equivalent to be transported per minute 

through a nuclear site putting the entire Hudson Valley, and its residents and 

infrastructure at stake without a detailed analysis? 

27. Why does the NRC continue to ignore potential major amounts of flammable 

material in the fuel oil storage tanks? Why has the NRC refused to respond 

directly to questions about the contents of these tanks? 

Response to questions 26 and 27 

The NRC reviewed the licensee's 50.59 site hazards analysis and performed an 

independent confirmatory analysis that substantiate Entergy's conclusions that the proposed 

pipeline poses no increased risks to the Indian Point facility. The NRC staff shared its 

findings with FERC, which subsequently approved the proposal. Multiple Federal and state 

agencies had a role in the review and approval of the Spectra pipeline. As previously 

discussed, the NRC does not have regulatory authority to approve the proposed natural gas 

pipeline. The role of the NRC is limited to ensuring that the Indian Point licensee performed 

a site hazards analysis in order to determine whether the proposed pipeline presented an 

unacceptable risk to the safe operations of the facility. 

The fuel oil tanks of concern were formerly used to generate super heat for the Indian Point 

Unit 1 steam generators. Indian Point Unit 1 was permanently shut down in 1974. Since 

that time, the fuel oil tanks have been drained, decommissioned, and abandoned onsite. 

Supply piping to the fuel oil tanks has been disconnected. If any residual oil remains in 

these tanks, it would not represent any concerns. Any remaining residual oil would not be 

explosive and at worst, would only present a minor fire hazard. 

Vapor Clouds 

RG 1.91 cites "International Atomic Energy Agency [IAEA], Safety Standards Series, 

Safety Guide No. NS-G-3.1, "External Human Induced Events in Site Evaluation for 

Nuclear Power Plants, 2002, Vienna Austria" as a reference. This International 

Standard·addresses vapor cloud explosions and states: "In some States (Countries) 

an SD V {screening distance value} in the range of 8-10 km is used for the sources of 

hazardous clouds." 

Apparently the IAEA considers the danger from vapor clouds to range out to beyond 

8 Km, yet the NRG has no problem locating major gas transmission lines within 

400 feet of vital structures of two operating 1000 Mwe nuclear plants located in one of 

the most densely populated areas in the world. 

Questions 

28. Fully recognizing this is not a regulation but only a statement and that most of the 

world avoids gas lines within 8 to 10 Km from nuclear plants, how can the NRC 
- 16 -

justify locating gas lines within 400 feet of vital structures without any justification or 

explanation? 

29. Why wasn't an explanation from an IAEA document included in the analysis? How did the 

NRC evaluate the potential for vapor cloud explosions while totally ignoring its own guidance 

provided in RG 1.91 and its references? 

Response to Questions 28 and 29 

IAEA Safety Standards Series, Safety Guide No. NS-G-3.1, "External Human Induced 

Events in Site Evaluation for Nuclear Power Plants," provides recommendations and 

guidance for evaluating potential site locations for nuclear power plants in order to identify 

hazardous phenomena associated with human induced events initiated by sources external 

to the plant. The IAEA document does not provide guidance on analyzing potential gas 

pipeline ruptures and, therefore, there was no need to reference it in either the Entergy site 

hazards analysis or NRC's confirmatory analysis. 

The statement quoted from the IAEA document, "In some States [countries] an SDV 

[screening distance value] in the range of 8-10 km is used for the sources of hazardous 

clouds," was a footnote intended as a tool to initially screen out those facilities and activities 

to which no further consideration to external hazards should be given. The IAEA document 

does not recommend that gas pipelines be separated from nuclear power plants by 8-10 km. 

Similar to the 50.59 site hazards analysis performed by the licensee for the proposed 

pipeline, Entergy used the same contractor using the same methodology to perform a 

similar site hazards analysis for the existing gas pipelines in 2008. As discussed in the 

responses to questions 6 and 31, this analysis assumed the simultaneous rupture of both 

gas pipelines at their above ground locations. The licensee's analysis concluded that a 

rupture of both gas pipelines at their above ground location will not result in damage to 

safety related structures. The NRC staff reviewed this analysis and concluded that failures 

of these gas pipelines will not impair the safe shutdown of Indian Point. 

The NRC staff did not ignore the guidance of RG 1.91. As previously discussed, the staff's 

confirmatory analysis to evaluate vapor cloud explosions did not modify the equations of 

RG 1.91 and implemented the methodology without exception. 

General Concerns 

30. I have reviewed both the Entergy and NRC calculations and did not see any calculations 

discussing heat flux. How did the NRC calculate the impact of heat flux, vapor cloud 

explosions and possible secondary fires such as from the "abandoned" fuel oil storage 

tanks? 

Response 

The ALOHA code was used by both Entergy and the NRC staff to calculate heat flux 

resulting from a postulated rupture of the proposed gas pipeline. The NRC staff performed 

a bounding analysis that assumed a double-ended rupture of the proposed pipeline with an 
- 17 -

infinite upstream source of natural gas for a full hour. The threshold value of heat flux, i.e., 

12.6 kw/m2 , where plastic melts, was not exceeded within the security owner controlled area 

(SOCA) fence and, therefore, safety-related structures, systems, and components would not 

be exposed to the threshold value of heat flux. 

The NRC staff did not consider secondary fires or other secondary impacts such as fuel oil 

storage tanks. The GT2/3 fuel oil storage tank near the switchyard is located 105 feet from 

the proposed pipeline's location. If this tank ruptured, local topography would result in its 

contents flowing away from the site and, therefore, it would not represent a threat to the 

Indian Point facility. The abandoned fuel oil storage tanks that supported operation of Indian 

Point Unit No. 1 were drained and decommissioned following the permanent shutdown of 

Unit No. 1in1974. These tanks are located several hundred feet outside of the SOCA 

fence. Any residual oil that might remain in these tanks would not explode and at most, 

would only burn. A small fire at this location would not represent a threat to the Indian Point 

facility. 

31. Please explain why the probability of failure and risk for the existing gas line is less than that 

of the new gas line. Indian Point's Final Safety Analysis (FSAR), approved by the NRC 

states that a failure of the existing buried gas transmission lines is "not feasible" which, to me 

means it is significantly less than 10-7 failures per year. How can the proposed AIM pipeline 

realistically have a higher failure probability than the existing 63-year old line that has no 

documented inspection history? 

Response 

There has been no assertion by either the licensee or the NRC that the probability of failure 

and risk for the existing gas pipelines is less than that of the proposed new gas pipeline. 

Section 2.2.2, "Site Ownership and Control," of the Indian Point 3 UFSAR is being 

misinterpreted. Section 2.2.2 of the UFSAR was updated in Revision 3 to reference a 2008 

study of the existing natural gas pipelines. Up until that time, only a single gas pipeline was 

assumed to rupture. However, since acts of intentional and malicious activity could no 

longer be excluded, the licensee contracted a study that assumed the simultaneous rupture 

and ignition of both gas pipelines at the above ground location inside the owner controlled 

property. This would clearly represent worst case conditions and would provide the most 

conservative analysis for explosions and fires. 

The licensee assumed that the most likely cause for both exposed pipelines to rupture 

would be the result of a terrorist action. The licensee's statement that "An attempt to 

uncover, breach and ignite a buried portion of the pipeline was not considered feasible," 

represents the conclusion that a terrorist would target the exposed pipelines as opposed to 

bringing in heavy equipment to uncover buried piping. The licensee's statement makes no 

reference to probability. Thus, any attempt to link the licensee's statement of "not feasible" 

to a determination that the probability of a pipe rupture is less than 10-7 failures per year, is 

out of context and a misinterpretation of the UFSAR. 

Finally, with regard to the statement that the existing gas pipeline "has no documented 

inspection history," see the response to question 33 below. 
- 18 -

32. Entergy, in its analysis, considers the potential for AIM gas line ruptures to be a Design Basis 

Event (DBE). The existing old gas lines are much closer to vital SSC's and the failure of 

these lines is intuitively much higher. Why does Entergy and the NRC not consider these 

lines to be a potential DBE and associated requirements imposed? 

Response 

The existing gas pipelines were not required to be analyzed as a potential design basis 

accident (OBA) in the Final Safety Analysis Report as part of the original licensing of Indian 

Point. Notwithstanding this, the potential rupture and ignition of the existing gas pipelines is 

considered part of the plant's licensing basis, and has been reviewed. Similarly, the 

proposed AIM gas pipeline was not required to be analyzed as a potential OBA, and was 

instead analyzed and evaluated through the 10 CFR 50.59 process. 

33. Has the NRC reviewed Spectra's operating and inspection procedures to assure the integrity 

of the existing Algonquin gas transmission system? 

Response 

No. The U.S. Department of Transportation Pipeline and Hazardous Materials Safety 

Administration (PHMSA) enforces regulations for the nation's gas pipeline transportation 

system. 

Spectra Energy implements standard operating procedures requiring: (a) periodic inspection 

of its pipelines using in-line inspection tools able to identify potential corrosion and damage 

defects, (b) monitoring of corrosion protection systems, and (c) frequent aerial patrols to 

identify unauthorized activities on the right-of-way. Since the Algonquin Indian Point 

right-of-way containing the 26-inch and 30-inch natural gas pipelines is located in a defined 

high consequence area (HCA) as interpreted and classified by Spectra, PHMSA regulations 

require inspections of pipelines located in HCAs on a more frequent basis, with a maximum 

interval of seven years for the internal inspections. 

Algonquin has advised Entergy that, consistent with those regulations, Algonquin most 

recently conducted in-line tool inspections of the existing 26-inch and 30-inch lines in 2011 

and 2014, respectively. Algonquin further advised Entergy that all inspections and follow-up 

actions were completed in accordance with applicable regulations and its own engineering 

standards. Pursuant to regulations in 49 CFR Part 192, Spectra Energy is required to 

maintain pipeline records for the useful life of the pipeline. 

34. Are Entergy operators at Indian Point trained in how to address an explosion/fire/gas release 

from existing the lines or even aware of the location of the lines at Indian Point or 

knowledgeable about the risks associated with these 63-year-old lines? 

Response 

As a condition of their license, Indian Point is required to have a Fire Protection Program 

where plant operators are trained as a fire brigade to respond to and fight a comprehensive 

variety of plant fires. 
- 19 -

The NRC regularly inspects the ability of the fire brigade to respond to fires through its 

Reactor Oversight Process baseline inspection program. We verify through inspections that 

the site fire brigade maintains the ability to properly respond to, and extinguish, plant fires. 

35. Do Entergy and Spectra coordinate safety and emergency response training? How often is 

training conducted? Does the NRC review these training procedures? 

Response 

There are no NRC requirements for Entergy and Spectra Energy to coordinate safety and 

emergency response training. However, as part of the Reactor Oversight Process, the NRC 

reviews Entergy's emergency planning procedures and training. 

These reviews include regular drills and exercises that assist licensees in identifying areas 

for improvement, such as in the interface of security operations and emergency 

preparedness. Entergy is required to exercise its emergency plan with offsite authorities, 

including the local Buchanan fire department, at least once every two years to ensure state 

and local officials remain proficient in implementing their emergency plans. Those biennial 

exercises are inspected by the NRC and evaluated by FEMA. Licensees also self-test their 

emergency plans regularly by conducting drills. Each plant's performance in exercises can 

be accessed through the NRC website at the Reactor Oversight Process page. 

36. What actions will the NRC take to respond to the existing pipelines' unanalyzed condition? 

Response 

Both the licensee and the AEC/NRC have analyzed the existing gas pipelines and 

concluded that they do not present an unacceptable risk to the Indian Point site. See the 

response to question 6. 

37. Has the NRC reviewed Entergy's existing and proposed emergency procedures for the local 

Buchanan volunteer fire brigade to deal with a major rupture and resulting fires at the Indian 

Point facility? Has the NRC discussed the ability and/or inability to provide adequate fire 

services with the local Buchanan volunteer fire brigade? If not, why? If so, how adequate 

does the NRC deem the Buchanan volunteer fire brigade is in addressing a pipeline rupture 

at Indian Point? 

Response 

Plant procedures are in place which require a call for offsite fire department assistance for 

numerous situations, including the case if the onsite fire brigade is unable to effectively 

control or extinguish the fire. In the case of a natural gas pipeline failure near Indian Point, it 

is expected that a call for offsite support would be made. Plant operators or fire brigade 

members would not be responsible to isolate the source of the natural gas, or rely on 

automatic isolation valves. Rather, the gas pipeline transmission operator would isolate the 

source from a remote control station. Damage to plant structures would not impair the safe 

operation of the facility or its ability to safely shutdown. 
- 20 -

As discussed in the response to question 35, the local Buchanan fire department 

participates in biennial exercises of the Entergy emergency plan. Those exercises, which 

are inspected by the NRC and evaluated by FEMA, demonstrate the continued proficiency 

of the Buchanan fire department to provide their necessary support. 

38. Did the NRC receive and review the Piping, Instrumentation and Flow Diagrams of the 

proposed and the existing gas transmission lines? 

Response 

No. The design and construction of the existing and proposed gas pipelines are outside the 

authority of the NRC. Therefore, there is no regulatory basis for the NRC to review detailed 

design information of either the existing or proposed gas pipelines. Design requirements of 

the nation's natural gas pipelines are included in Title 49 of the Code of Federal Regulations 

that are administered by the Pipeline and Hazardous Materials Safety Administration of the 

Department of Transportation. 

39. Does the NRC have any Quality Assurance requirements/procedures for conducting safety 

related calculations? If so, what are they? 

Response 

No. As discussed in the response to question 1, the NRC staff does not perform 

"safety-related" calculations. Calculations may be performed by the staff as 

needed to support independent confirmatory analysis. In this case, the staff 

performed an independent analysis that received a peer review by a qualified 

NRC engineer. 
P. Blanch - 4 -

The NRG appreciates your concerns and will continue to evaluate all new information 

regarding the existing and proposed natural gas pipelines through the Reactor 

Oversight Program. 

Sincerely, 

/RAJ 

Christopher G. Miller, Director 

Division of License Renewal 

Office of Nuclear Reactor Regulation 

Docket Nos.: 50-247 and 50-286 

Enclosure 

As stated 

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ADAMS Accession No.: ML 15287A257 

OFFICE DORL/LPLl-1 /PM DORL/LPLl-1/LA NRO/DSEA/RPAC/BC 

NAME DPickett KGoldstein MMcCoppin 

DATE 10/21/2015 10/16/2015 10/27/2015 

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DATE 10/21/2015 10/29/2015 11/03/2015 

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