ML15090A294
| ML15090A294 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/27/2015 |
| From: | Blanch P Public Commenter |
| To: | Stephen Burns NRC/Chairman |
| Shared Package | |
| ML15090A295 | List: |
| References | |
| LTR-15-0165 | |
| Download: ML15090A294 (4) | |
Text
27 March 2015 Paul M. Blanch Energy Consultant Chairman Stephen G. Burns (Chairman(ii1nrc.gov)
United States Nuclear Regulatory Commission Washington DC 20001
Subject:
Commission Statements made before Congress March 24, 2014 NRC's use ofEPA's ALOHA Program to Evaluate Proposed Gas Transmission Line Explosion Near Indian Point Dear Mr. Chairman I have reviewed your testimony before Congresswoman Nita Lowey on March 24, 2015 on YouTube.
The Congresswoman questioned you on the use ofEPA's ALOHA program to calculate the safe distance from a postulated explosion of the proposed 42-inch gas transmission line.
Your response inferred that Regulatory Guide 1. 91 does not calculate the impact of a vapor cloud explosion, heat flux and/or jet fire. You indicated the staff would get back to the Congresswoman to clarify if required.
On March 24, 2015 Mr. Douglas Tifft provided the following clarification to your statement:
" I did have the chance to check with our headquarters group that performed the analysis. ALOHA is used to calculate the amount of gas that would be released during a pipe break. That amount of gas is converted into pounds of TNT by our technical group. The pounds of TNT is used in the Reg Guide 1.91 formulas to determine the minimum safe distance. "
But page 146 of the ALOHA Manual specifically states:
"You can use ALOHA to model two types of gas pipeline leak March 27, 2015 scenarios:
- A pipeline connected to a very large (infinite) reservoir, so that gas escapes from the broken end of the pipeline at a constant rate for an indefinite period of time,* or
- A finite length of pipeline that is closed-off at the unbroken end (for example, by a shut-off valve). Because the pressure within this section of pipe declines as gas is released, release rate drops over time, and the release continues only until the finite length of pipe is emptied.
ALOHA cannot model gas release from a pipe that has broken in the middle and is leaking from both broken ends." (Emphasis added by EPA)
The NRC issued Revision 2 to Regulatory Guide 1.91 in April 2013. The purpose for this revision was stated as:
"Revision 1 of the guide did not address the effects of explosions from liquids, cryogenically liquefied hydrocarbons, and vapor clouds, (Emphasis added) or for fire and explosions from fixed facilities and pipelines. "
Regulatory Guide 1.91 Revision 2 contains 17 references, some of which may be used to calculate flow rates, vapor cloud explosions, jet fires and heat flux.
It is unclear why the NRC Staff used ALOHA when it is not cited as a reference and contains explicit prohibitions against analyzing this type of event.
Again, I request the Commission direct the NRC Staff to withdraw its approval to FERC. The misapplication of ALOHA strongly suggests the assessment does not conform with the generally accepted guidance in 29 CFR Appendix C to §1910.119- "Compliance Guidelines and Recommendations for Process Safety Management."
The Commission also needs to direct the NRC Staff to endorse a truly independent and transparent study that must include experts and other potentially impacted residents of the Indian Point area.
March 27, 2015 Congresswoman Lowey's questioning seemed focused on why the NRC used the ALOHA program. Your response and its clarification described how the NRC used the program, not addressing why a program explicitly prohibited for this application was used. I also believe you have the responsibility to communicate with Congresswoman Lowey and provide a direct explanation as to why NRC used the ALOHA program, whose misuse may impact the safety of more than 20 million residents of the area.
Sincerely,
~~.#'..L/
Paul M. Blanch 135 Hyde Rd.
West Hartford, CT 06117 860-23 6-03 26 cc:
Senator Schumer Senator Gillibrand Senator Markey Congresswoman Lowey Assemblywoman Galef NRC's Office of the Inspector General
CHAIRMAN Resource From:
Sent:
To:
Cc:
Subject:
Attachments:
Paul Blanch <pmblanch@comcast.net>
Friday, March 27, 2015 1:29 PM CHAIRMAN Resource Paul Blanch; Dana Levenberg; Sara Levine; Shapiro, Geri (Gillibrand); Susan Yan Dolsen; Raspa, Rossana; Spicher, Terri; Peluso, Cody (Schumer); Sandy Galef; Susan Spear; Freedhoff, Michal; Amy Rosmarin; Dave Lochbaum Letter from Paul M Blanch to Chairman 20150327 Letter to Chairman Final.pdf; ATTOOOOl.htm Please see enclosed letter to the Chairman dated today 1