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Category:E-Mail
MONTHYEARML23341A2002023-12-0707 December 2023 Email - Indian Point Energy Center Generating Units 1, 2, and 3 Implementation Notice of Amendment No. 67, 300 and 276 to Independent Spent Fuel Storage Installation Only Emergency Plan (Ioep) ML23332A0802023-11-0808 November 2023 Email from State of New York on the Revised License Amendment for Indian Point Energy Center ISFSI Only Emergency Plan ML23325A1632023-11-0808 November 2023 State of New York Comments on the Revised License Amendment for Indian Point Unit 2 and 3 Technical Specification Changes Reflecting Permanent Removal of Spent Fuel ML23331A9542023-11-0808 November 2023 Email - State of New York Comments on the Revised License Amendment for Indian Point Unit 2 and 3 Technical Specification Changes Reflecting Permanent Removal of Spent Fuel ML23144A3452023-05-25025 May 2023 Adam Kahn of Monsey, New York Email Against Treated Water Release from Indian Point Site ML23144A3442023-05-25025 May 2023 Peggy Kurtz of Rockland County, New York Email Against Treated Water Release from Indian Point Site ML23144A3392023-05-25025 May 2023 David Morris of New City, New York Email Against Treated Water Release from Indian Point Site ML23144A3502023-05-25025 May 2023 Dan Kwilecki of Montebello, New York Email Against Treated Water Release from Indian Point Site ML23144A3422023-05-25025 May 2023 Peter Duda of Pearl River, New York Email Against Treated Water Release from Indian Point Site ML23144A3382023-05-25025 May 2023 Dawn Giambalvo of Jersey City, New Jersey Email Against Treated Water Release from Indian Point Site ML23136B1622023-05-15015 May 2023 Town of North Salem, County of Westchester, New York Board Resolution Letter Regarding Treated Water Release from Indian Point Site ML23109A0632023-04-17017 April 2023 Email Acceptance Review for IP2 and IP3 Amended Facility License and Technical Specification to Reflect Permanent Removal of Spent Fuel from Spent Fuel Pits ML23055A1112023-02-23023 February 2023 Alyse Peterson Email- NYSERDA No Comments on Indian Point Unit 2 - Regarding Holtec License Amendment Request to Revise Permanently Defueled Technical Specifications and Staffing Requirements with Spent Fuel Transfer to ISFSI (Dockets 50-24 ML23049A0032023-02-14014 February 2023 NRC Acceptance Email to Holtec for License Amendment Request for Approval of New ISFSI-Only Emergency Plan and Associated EAL Scheme ML22313A1682022-11-0909 November 2022 NRC Response to Updates to the Proposed Amended IP2 Master Trust ML22308A0912022-11-0303 November 2022 Email Acknowledgement for IP2 and IP3 Amended Facility License and Technical Specification to Reflect Permanent Removal of Spent Fuel from Spent Fuel Pits ML22276A1642022-09-29029 September 2022 New York State Revised Draft EA Response E-Mail ML22271A8492022-09-28028 September 2022 E-Mail Transmitting Revised Indian Point Exemption Draft EA ML22269A3452022-09-22022 September 2022 Email Objection to Holtec IP2 Master Decommissioning Trust Agreement for Indian Point Nuclear Generating Facility Unit 1 and 2, EPID L-2022-LLA-0072 ML22259A1992022-09-0202 September 2022 Acceptance for License Amendment Request to Modify Staffing Requirements Following SFP Transfer to Dry Storage ML22265A0142022-08-31031 August 2022 Email Acknowledgement for Amended and Restated Holtec IP3 Master Decommissioning Trust Agreement for Indian Point Nuclear Generating Facility Unit 3 ML22242A2592022-08-19019 August 2022 E-mail from K. Sturzebecher, NRC, to B. Noval, HDI, Acknowledgement for Amended and Restated Holtec IP2 Master Decommissioning Trust Agreement for Indian Point Nuclear Generating Facility Unit 1 and 2 ML22228A1332022-08-0909 August 2022 Acknowledgement for License Amendment Request to Modify Staffing Requirements Following SFP Transfer to Dry Storage ML22215A0432022-08-0101 August 2022 E-Mail Transmitting NYS NSA Exemption Comments & Draft EA Review Completion ML22208A0292022-07-19019 July 2022 E-Mail Transmitting Indian Point Exemption Draft EA ML22168A0072022-06-16016 June 2022 Acceptance Review for License Amendment Request to Revise License Condition to Eliminate Cyber Security Plan Requirements ML22112A0102022-04-21021 April 2022 Acceptance Review: Request for Exemption from 10 CFR 50.54(w)(1) Concerning Indian Point Energy Center Onsite Property Damage Insurance ML22112A0122022-04-21021 April 2022 Acceptance Review: Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance for Indian Point Energy Center ML22103A2432022-04-13013 April 2022 E-mail - Request for Additional Information - License Amendment Request to Revise Emergency Plan and Emergency Action Level Scheme for Permanently Defueled Condition for Indian Point Energy Center ML22104A0342022-04-13013 April 2022 E-mail from Z. Cruz, NRC to J. Fleming, Holtec - Request for Additional Information Related to Request for Exemption from Portions of 10 CFR 50.47 and Part 50 Appendix E for Indian Point Energy Center ML22038A2572022-02-0707 February 2022 E-mail from Z. Cruz, NRC, to J. Fleming, HDI - Acceptance Review: License Amendment Request to Revise Emergency Plan and Emergency Action Level Scheme to Address Permanently Defueled Condition for Indian Point Energy Center ML22035A1862022-02-0404 February 2022 E-mail to J. Fleming, Holtec, from Z. Cruz Perez, NRC - Acceptance Review: Exemption Requests from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E, Section IV for Indian Point Energy Center ML22028A1032022-01-28028 January 2022 E-mail Dated 1/28/2022, Transmittal of Draft Safety Evaluation for Proposed License Amendment Revision to Licensing Basis to Incorporate the Installation and Use of of New Auxiliary Lifting Device ML22038A1592022-01-24024 January 2022 NRR E-mail Capture - (External_Sender) 2021 IPEC Annual Sturgeon Impingement Report ML22006A0442022-01-0505 January 2022 Email from Z Cruz to J Fleming Request for Additional Information - HDI Indian Point Post-Shutdown Decommissioning Activities Report ML21337A2952021-12-0303 December 2021 Subsequent Request for Additional Information License Amendment Request to Revise Licensing Basis for New Auxiliary Lifting Device (E-mail Dated 12/3/2021) ML21335A3692021-12-0101 December 2021 Acceptance Review: Indian Point Energy Center - Exemption Request from 10 CFR Part 20 App G Section Iii.E ML21266A2972021-08-18018 August 2021 8/18/2021 E-mail from H. Specter to R. Guzman Public Comments to NRC, Indian Point Post-Shutdown Decommissioning Activities Report Public Meeting on July 29, 2021 ML21225A6142021-08-0909 August 2021 Email from NRC to the Tuscarora Nation Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A5682021-08-0909 August 2021 Email from NRC to the Stockbridge-Munsee Community Band of Mohican Indians Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A5012021-08-0909 August 2021 Email from NRC to the Shinnecock Indian Nation Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21224A3032021-08-0909 August 2021 Email from NRC to the Mashantucket Pequot Tribe of Connecticut Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A4252021-08-0909 August 2021 Email from NRC to the Oneida Nation of Wisconsin Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A3142021-08-0606 August 2021 Email from NRC to the Oneida Indian Nation Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A4402021-08-0606 August 2021 Email from NRC to the Onondaga Nation of Wisconsin Announcing the IPEC PSDAR Meeting on August 18, 2021 ML21225A5462021-08-0606 August 2021 Email from NRC to the St. Regis Mohawk Tribe Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A5352021-08-0606 August 2021 Email from NRC to the Tonawanda Band of Seneca Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21266A2942021-07-25025 July 2021 E-mail from Paul Blanch to NRC (N. Sheehan, D. Screnci) Public Comments to NRC, Indian Point Post-Shutdown Decommissioning Activities Report Public Meeting, July 29, 2021 ML21197A2002021-07-16016 July 2021 (E-mail 7/16/2021) NRC Staff Assessment and RAI Closeout HDI Fleet Decommissioning Quality Assurance Program and Indian Point Energy Center Quality Assurance Program Manual ML21194A4082021-07-13013 July 2021 (7-13-2021) E-mail NRR Review Hour Estimate Change Supporting the Hi-Lift Crane Proposed License Amendment Request Review 2023-05-25
[Table view] Category:Letter
MONTHYEARML24011A1982024-01-12012 January 2024 ISFSI, Notice of Organization Change for Site Vice President ML23342A1082024-01-0909 January 2024 Independent Spent Fuel Storage Installation Security Inspection Plan ML23353A1742023-12-19019 December 2023 ISFSI, Emergency Plan, Revision 23-04 L-23-019, Proof of Financial Protection 10 CFR 140.152023-12-18018 December 2023 Proof of Financial Protection 10 CFR 140.15 ML23339A0442023-12-0505 December 2023 Issuance of Amendment No. 68, 301 and 277 Regarding Changes to Implement the Independent Spent Fuel Storage Installation Physical Security Plan ML23326A1322023-12-0505 December 2023 Issuance of Amendment No. 67, 300 & 276 to Implement the Independent Spent Fuel Storage Installation Only Emergency Plan ML23338A2262023-12-0404 December 2023 Signed Amendment No. 27 to Indemnity Agreement No. B-19 ML23356A0212023-12-0101 December 2023 American Nuclear Insurers, Secondary Financial Protection (SFP) Program ML23242A2772023-11-30030 November 2023 NRC Letter Issuance - IP LAR for Units 2 and 3 Renewed Facility Licenses and PDTS to Reflect Permanent Removal of Spent Fuel from SFPs ML23338A0482023-11-30030 November 2023 ISFSI, Report of Changes to Physical Security, Training and Qualification, Safeguards Contingency Plan, and ISFSI Security Program, Revision 28 ML22339A1572023-11-27027 November 2023 Letter - Indian Point - Ea/Fonsi Request for Exemptions from Certain Emergency Planning Requirements for 10 CFR 50.47 and 10 CFR Part 50, Appendix E IR 05000003/20230032023-11-21021 November 2023 NRC Inspection Report Nos. 05000003/2023003, 05000247/2023003, 05000286/2023003, and 07200051/2023003 ML23100A1172023-11-17017 November 2023 NRC Response - Indian Point Energy Center Generating Units 1, 2, and 3 Letter with Enclosures Regarding Changes to Remove the Cyber Security Plan License Condition ML23050A0032023-11-17017 November 2023 Letter - Issuance Indian Point Unit 2 License Amendment Request to Modify Tech Specs for Staffing Requirements Following Spent Fuel Transfer to Dry Storage ML23100A1252023-11-17017 November 2023 Letter and Enclosure 1 - Issuance Indian Point Energy Center Units 1, 2, and 3 Exemption for Offsite Primary and Secondary Liability Insurance Indemnity Agreement ML23100A1432023-11-16016 November 2023 Letter - Issuance Indian Point Energy Center Generating Units 1, 2, and 3 Exemption Concerning Onsite Property Damage Insurance (Docket Nos. 50-003, 50-247, 50-286) ML23064A0002023-11-13013 November 2023 NRC Issuance for Approval-Indian Point EC Units 1, 2 and 3 Emergency Plan and Emergency Action Level Scheme Amendments L-23-012, Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point2023-11-13013 November 2023 Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point ML23306A0992023-11-0202 November 2023 and Indian Point Energy Center, Notification of Changes in Schedule in Accordance with 10 CFR 50.82(a)(7) ML23063A1432023-11-0101 November 2023 Letter - Issuance Holtec Request for Indian Point Energy Center Generating Units 1, 2, and 3 Exemptions from Certain Emergency Planning Requirements of 10 CFR 50.47 and Part 50 ML23292A0262023-10-19019 October 2023 LTR-23-0211-RI Thomas Congdon, Executive Deputy, Department of Public Service, Chair, Indian Point Decommissioning Oversight Board, Letter Independent Spent Fuel Storage Installation Inspection and Office of the Inspector General Report-RI ML23289A1582023-10-16016 October 2023 Decommissioning International - Registration of Spent Fuel Casks and Notification of Permanent Removal of All Indian Point Unit 3 Spent Fuel Assemblies from the Spent Fuel Pit ML23270A0082023-09-27027 September 2023 Registration of Spent Fuel Casks ML23237A5712023-09-22022 September 2023 09-22-2023 Letter to Dwaine Perry, Chief, Ramapo Munsee Nation, from Chair Hanson, Responds to Letter Regarding Opposition of the Release and Dumping of Radioactive Waste from Indian Point Nuclear Power Plant Into the Hudson River ML23242A2182023-09-12012 September 2023 IPEC NRC Response to the Town of New Windsor, Ny Board Certified Motion Letter Regarding Treated Water Release from IP Site (Dockets 50-003, 50-247, 50-286) ML23250A0812023-09-0707 September 2023 Registration of Spent Fuel Casks ML23255A0142023-08-31031 August 2023 LTR-23-0211 Thomas Congdon, Executive Deputy, Department of Public Service, Chair, Indian Point Decommissioning Oversight Board, Letter Independent Spent Fuel Storage Installation Inspection and Office of the Inspector General Report IR 05000003/20230022023-08-22022 August 2023 NRC Inspection Report 05000003/2023002, 05000247/2023002, 05000286/2023002, and 07200051/2023002 ML23227A1852023-08-15015 August 2023 Request for a Revised Approval Date Regarding the Indian Point Energy Center Permanently Defueled Emergency Plan and Emergency Action Level Scheme ML23222A1442023-08-10010 August 2023 Registration of Spent Fuel Casks ML23208A1642023-07-26026 July 2023 Village of Croton-on-Hudson New York Letter Dated 7-26-23 Re Holtec Wastewater ML23200A0422023-07-19019 July 2023 Registration of Spent Fuel Casks ML23235A0602023-07-17017 July 2023 LTR-23-0194 Dwaine Perry, Chief, Ramapo Munsee Nation, Ltr Opposition of the Release and Dumping of Radioactive Waste from Indian Point Nuclear Power Plant Into the Hudson River ML23194A0442023-07-11011 July 2023 Clarification for Indian Point Energy Center License Amendment Request, Independent Spent Fuel Storage Installation Physical Security Plan ML23192A1002023-07-11011 July 2023 Response to Request for Additional Information Regarding License Amendment Request to Revise the Emergency Plan and Emergency Action Level Scheme ML23171B0432023-06-23023 June 2023 Letter - Indian Point Energy Center - Request for Additional Information for Independent Spent Fuel Storage Installation Facility-Only Emergency Plan License Amendment ML23118A0972023-06-0606 June 2023 06-06-23 Letter to the Honorable Michael V. Lawler, Et Al., from Chair Hanson Regarding Holtec'S Announcement to Expedite Plans to Release Over 500,000 Gallons of Radioactive Wastewater from Indian Point Energy Center Into the Hudson River ML23144A3512023-05-25025 May 2023 Clementina Bartolotta of Pearl River, New York Email Against Treated Water Release from Indian Point Site ML23144A3522023-05-25025 May 2023 Loredana Bidmead of New York E-Mail Against Treated Water Release from Indian Point Site ML23144A3412023-05-25025 May 2023 Dianne Schirripa of Rockland County, New York Email Against Treated Water Release from Indian Point Site ML23144A3472023-05-25025 May 2023 David Mart of Blauvelt, New York Email Against Treated Water Release from Indian Point Site ML23144A3402023-05-25025 May 2023 Melvin Israel of New York Email Against Treated Water Release from Indian Point Site ML23144A3542023-05-25025 May 2023 Terri Thal of New City, New York Email Against Treated Water Release from Indian Point Site ML23144A3532023-05-25025 May 2023 John Shaw of New York Email Against Treated Water Release from Indian Point Site 2024-01-09
[Table view] |
Text
Paul M. Blanch Energy Consultant 17 March 2015 USNRC Chairman Burns (Chairmam@nrc.gov)
USNRC Commissioner Baren (cmrbaren@nrc.gov)
USNRC Commissioner Svinicki (cmrsvinicki@nrc.gov)
USNRC Commissioner Ostendorff cmrostendorff@nrc.gov
Subject:
Request for expedited 10 CFR 2.206 Directors Decision for proposed Indian Point 42 inch gas transmission line.
Dear Chairman and Commissioners On October 15, 2014 I filed a 10 CFR 2.206 petition requesting enforcement action against Entergy for submitting inaccurate and incomplete information in violation of 10 CFR 50.5 and 10 CFR 50.9.
NRCs Management Directive 8.11 requires a timeliness goal to 120 days from the date of the acknowledgment letter until the date the proposed director's decision is sent out for comment.
As of todays date it has been about 150 days and I have not even received and acknowledgement letter of my petition and have been informed. I was informed by the NRCs Petition Manager today that I . . .should be hearing from us in the next couple weeks.
This is unacceptable as Indian Point Units 2 and 3 are presently operating in an unanalyzed condition that significantly degrades plant safety. This presumption is based on the fact that Entergy used the same methodology and person for the analysis of the existing gas lines located within the protected area within 600 feet of vital SSCs. This recently released analysis is severely deficient and it is assumed the same methodology was also applied to the existing lines that concluded that a gas line rupture is not considered feasible1 (less than 10e-7 per year).
1 Indian Point Unit 3 2011 UFSAR
March 17, 2015 The new analysis was obtained under appeal of FOIA 2015-0062.
The new analysis now concludes that a gas line rupture of the existing lines is feasible and based on expert analysis the probability of failure is greater than 10e-5 per year and likely greater due to the 50-year age of the existing lines.
Some of the more significant deficiencies in the NRCs analysis of the proposed gas line are:
- 1. The analysis relies on the EPA ALOHA code to predict the probability and consequences of fires, overpressure and radiant heat flux. The EPA document states the following:
ALOHA cannot model gas release from a pipe that has broken in the middle and is leaking from both broken ends.(Bold emphasis added by EPA)
- 2. None of the cited references mention 3 minutes for a gas line rupture but do discuss a 1-hour time to be considered. History and expert opinions demonstrate gas blowdown times range from 30 minutes to many hours.
- 3. Using more realistic gas release of one to two orders of magnitude greater, the blast radius would encompass the city water rank and possibly tanks used for core cooling. The NRC/Entergy analysis stated the switchyard and the diesel oil storage tanks are within the blast radius. Loss of the switchyard and the oil tanks would result in a station blackout (SBO) and the loss of the city water tank would render the Unit 2 SBO diesel inoperable due to loss of SBO diesel generator cooling.
- 4. The city water tank serves to supply back-up water to the Auxiliary Feedwater System used to cool the core during loss of AC power/SBO event.
- 5. The NRC stated in its analysis that the probability of an explosion after a pipe rupture is 5% yet this number is not contained in any of the cited references. Research shows almost 100% of pipe ruptures result in ignition.
March 17, 2015
- 6. The NRC analysis assumes that a total pipe rupture will occur in 1%
of the pipeline accidents whereas the references clearly state this occurs in 20% of the accidents.
- 7. The NRC analysis states: If this release is due to the underground pipe, the frequency of explosion will be further reduced by at least an order of magnitude. (Emphasis added) There is no documentation or reference supporting this non-conservative assumption.
- 8. The analysis for the COLA permit for Turkey Point Units 6 and 7 predict a damage radius of more than 3000 feet from a smaller line operation at a lower pressure. The NRC/Entergy analysis predicts a damage radius of 1155 feet for a line more than double in capacity operating at a higher pressure.
- 9. The cited reference Handbook of Chemical Hazard Analysis Procedures is apparently dated circa 1987 and does not consider subsequent major gas-line explosions such as the San Bruno, CA, Sissonville WV, Cleburne TX, Carlsbad NM, and the Edison, NJ transmission and distribution explosions.
- 10. The NRC calculates the probability of a gas line explosion at 7.5E-7 per year. My calculations and the invalid use of the EPA ALOHA code clearly show the probability of core damage to be orders of magnitude greater than predicted by the NRC/Entergy analysis.
These are but a few of the significant deficiencies and because of the imminent risk to the public, immediate action by the Commission is requested. I have compiled a chronology and a list of significant NRC/Entergy analytical deficiencies that I can make available to the Commission and Staff should there be any interest.
I am requesting the Commission immediately direct the NRC Staff to rescind the NRCs approval provided to FERC stating no increase in risk to Indian Point until the final resolution of my petition.
I further request the Commission to direct the NRC Staff to accelerate this 10 CFR 2.206 process using proper references and updated methodologies.
March 17, 2015 Paul M. Blanch 135 Hyde Rd.
West Hartford, CT 06117 860-236-0326 cc: Senator Schumer Senator Gillibrand Congresswoman Lowey Assemblywoman Galef
CHAIRMAN Resource From: Paul Blanch < pmblanch@Pan,eM.
Sent: Tuesday, March 17, 2015 5:28 PM To: CHAIRMAN Resource B /an ch Cc: Paul Blanch
Subject:
Fwd: Immediate concern with Indian Point analysis Attachments: 20153017 ltr to CommissicJ!1J~s . pdf; ATT00002.htm Consultant Sent to wrong email.
To: Chairmam@nrc.gov, cmrbaren@nrc.gov, cmrsvinicki@nrc.gov, cmrostendorff@nrc.gov 17 March 2015 USNRC Chairman Burns (Chairmam@nrc.gov)
USNRC Commissioner Baren (cmrbaren@nrc.gov)
USNRC Commissioner Svinicki (cmrsvinicki @nrc.gov)
USNRC Commissioner Ostendorff cmrostendorff@nrc.gov
Subject:
Request for expedited 10 CFR 2.206 Directors Decision for proposed Indian Point 42 inch gas transmission line.
Dear Chairman and Commissioners On October 15, 2014 I filed a 10 CFR 2.206 petition requesting enforcement action against Entergy for submitting inaccurate and incomplete information in violation of 10 CFR 50.5 and 10 CFR 50.9.
NRC's Management Directive 8.11 requires a "timeliness goal to 120 days from the date of the acknowledgment letter until the date the proposed director's decision is sent out for comment."
As of today's date it has been about 150 days and I have not even received and acknowledgement letter of my petition and have been informed. I was informed by the NRC's Petition Manager today that I" ... should be hearing from us in the next couple weeks."
This is unacceptable as Indian Point Units 2 and 3 are presently operating in an unanalyzed condition that significantly degrades plant safety. This presumption is based on the fact that Entergy used the same methodology and person for the analysis of the existing gas lines located within the protected area within 600 feet of vital SS Cs. This recently released analysis is severely deficient and it is assumed the same methodology was also applied to the existing lines that concluded that a gas line rupture is "not considered feasible" (less than I Oe-7 per year).
The new analysis was obtained under appeal ofFOIA 2015-0062.
The new analysis now concludes that a gas line rupture of the existing lines is feasible and based on expert analysis the probability of failure is greater than 1Oe-5 per year and likely greater due to the 50-year age of the existing lines.
Some of the more significant deficiencies in the NRC's analysis of the proposed gas line are:
- 1. The analysis relies on the EPA ALOHA code to predict the probability and consequences of fires, overpressure and radiant heat flux. The EPA document states the following:
2
"ALOHA cannot model gas release from a pipe that has broken in the middle and is leaking from both broken ends. "(Bold emphasis added by EPA)
- 2. None of the cited references mention 3 minutes for a gas line rupture but do discuss a I-hour time to be considered. History and expert opinions demonstrate gas blowdown times range from 30 minutes to many hours.
- 3. Using more realistic gas release of one to two orders of magnitude greater, the blast radius would encompass the city water rank and possibly tanks used for core cooling. The NRC/Entergy analysis stated the switchyard and the diesel oil storage tanks are within the blast radius. Loss of the switchyard and the oil tanks would result in a station blackout (SBO) and the loss of the city water tank would render the Unit 2 SBO diesel inoperable due to loss of SBO diesel generator cooling.
- 4. The city water tank serves to supply back-up water to the Auxiliary Feedwater System used to cool the core during loss of AC power/SBO event.
- 5. The NRC stated in its analysis that the probability of an explosion after a pipe rupture is 5% yet this number is not contained in any of the cited references.
Research shows almost I 00% of pipe ruptures result in ignition.
- 6. The NRC analysis assumes that a total pipe rupture will occur in I% of the pipeline accidents whereas the references clearly state this occurs in 20% of the accidents.
- 7. The NRC analysis states: "If this release is due to the underground pipe, the frequency of explosion will be further reduced by at least an order of magnitude." (Emphasis added) There is no documentation or reference supporting this non-conservative assumption.
- 8. The analysis for the COLA permit for Turkey Point Units 6 and 7 predict a damage radius of more than 3000 feet from a smaller line operation at a lower 3
pressure. The NRC/Entergy analysis predicts a damage radius of 1155 feet for a line more than double in capacity operating at a higher pressure.
- 9. The cited reference " Handbook of Chemical Hazard Analysis Procedures" is apparently dated circa 1987 and does not consider subsequent major gas-line explosions such as the San Bruno, CA, Sissonville WV, Cleburne TX, Carlsbad NM, and the Edison, NJ transmission and distribution explosions.
1O.The NRC calculates the probability of a gas line explosion at 7.5E-7 per year. My calculations and the invalid use of the EPA ALOHA code clearly show the probability of core damage to be orders of magnitude greater than predicted by the NRC/Entergy analysis.
These are but a few of the significant deficiencies and because of the imminent risk to the public, immediate action by the Commission is requested. I have compiled a chronology and a list of significant NRC/Entergy analytical deficiencies that I can make available to the Commission and Staff should there be any interest.
I am requesting the Commission immediately direct the NRC Staff to rescind the NRC's approval provided to FERC stating no increase in risk to Indian Point until the final resolution of my petition.
I further request the Commission to direct the NRC Staff to accelerate this 10 CFR 2.206 process using proper references and updated methodologies.
Paul M. Blanch 135 Hyde Rd.
West Hartford, CT 0611 7 4
860-236-0326 cc: Senator Schumer Senator Gillibrand Congresswoman Lowey Assemblywoman Galef 5