ML20099F775
| ML20099F775 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/09/2020 |
| From: | Margaret Doane NRC/EDO |
| To: | Jeff Baran, Stephen Burns, Annie Caputo, Kristine Svinicki, David Wright NRC/Chairman, NRC/OCM |
| Haney B | |
| References | |
| Download: ML20099F775 (4) | |
Text
April 9, 2020 MEMORANDUM TO:
Chairman Svinicki Commissioner Baran Commissioner Caputo Commissioner Wright FROM:
Margaret M. Doane Executive Director for Operations
SUBJECT:
CONCERNS PERTAINING TO GAS TRANSMISSION LINES NEAR THE INDIAN POINT NUCLEAR POWER PLANT -
EXPERT TEAM EVALUATION This memorandum forwards the report of the U.S. Nuclear Regulatory Commission (NRC)
Expert Evaluation Team on Concerns Pertaining to Gas Transmission Lines Near the Indian Point Nuclear Power Plant, dated April 8, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20100F635). In addition, this memorandum highlights the Teams findings, recommendations, and describes the actions I will take in response to these recommendations.
The Team was established following a February 24, 2020, memorandum from the Chairman (ADAMS Accession No. ML20057E265). This memorandum directed me to address matters raised in the NRCs Office of the Inspector General (OIG) Event Inquiry Report, Concerns Pertaining to Gas Transmission Lines at the Indian Point Nuclear Power Plant, (Case No.16-024) dated February 13, 2020 (ADAMS Accession No. ML20056F095).
In response to the Chairmans February 24, 2020, memorandum, I tasked David Skeen to lead a team of experts (Team) to respond to the matters raised in the NRCs OIG report (ADAMS Accession No. ML20058E354). As directed, all team members were independent from the previous work described in the Event Inquiry. The Team included both NRC staff and external members with expertise in fields pertaining to the issues identified by the OIG.
In summary, the Team concluded that Entergy (the plant owner) and the NRC used optimistic assumptions in analyzing the potential impacts to the Indian Point site from a postulated rupture of the 42-inch Alognquin Incremental Market (AIM) natural gas transmission pipeline.
Despite this finding, the Team performed its own evaluation and determined that the Indian Point reactors would remain safe in the unlikely event of a pipe rupture.
CONTACT: David Skeen, Team Lead 301-287-9056 Margaret M.
Doane Digitally signed by Margaret M. Doane Date: 2020.04.09 15:21:06
-04'00'
The Commissioners 2
Specifically, the Team determined that a rupture of the 42-inch natural gas transmission pipeline that runs near Indian Point is unlikely. This pipeline was installed using modern techniques, stringent quality standards, and construction precautions that limit the likelihood of later pipeline damage. This stretch of pipeline was designated as a high consequence area under Department of Transportation requirements, meaning that additional inspection, integrity threat assessment, pipe remediation, and documentation requirements apply. However, if a rupture occurred on the section of that 42-inch pipeline, the equipment needed to safely shut down the reactors and maintain them in a safe condition would be protected and remain available. The Team also found that the robust concrete structures housing the spent fuel pool and dry fuel storage containers would withstand the heat and pressure impacts of an explosion or fire that could follow a pipeline rupture.
The Team also reviewed the NRC practices and processes used to analyze the pipe rupture and recommends several improvements to the NRCs current approach. The recommendations include reviewing the processes and practices used for technical reviews, inspection support, petition reviews, pipeline analysis, and coordination with other agencies. Further, because the assumptions in Entergys analysis of the 42-inch AIM pipeline were found to be optimistic, the Team recommends that Entergy revisit the assumptions it used to identify the risk posed by a postulated rupture of the 42-inch pipeline near Indian Point. Specifically, Entergy should be asked to assess the importance of these assumptions to its original conclusions and update its hazards analysis, if needed.
I have reviewed the Teams report and found it to be thorough and well documented. I accept all of its recommendations and conclusions. I take the Teams recommendations very seriously, so I will direct three actions in response to their findings.
First, I will task Mr. Skeen to work through the Office of Nuclear Reactor Regulation to request that Entergy revisit the assumptions it made regarding the consequences of a postulated rupture of the 42-inch AIM pipeline and update its analysis, if needed. I will also task Mr. Skeen to lead agency efforts to address the NRC process and practice issues identified in the report.
Mr. Skeen will continue to have access to both NRC staff, and external members to the extent that might be helpful and depending on their availability.
Second, to ensure a rapid response to these issues, I will direct that Offices take immediate action to improve processes and procedures within their areas of responsibility pending the full implementation of the Teams recommendations. Offices will be asked to focus on documenting confirmatory analyses and 2.206 petitions; performing peer reviews; and formalizing and documenting interactions with other agencies when NRCs expertise or decisions will be cited by another agency.
Third, I will task Mr. Skeen to lead the agencys efforts to address the issues noted in Section 6.3, Future Analysis and Activities, of the report. This section lists several requests by outside parties for the NRC or other entities to take action beyond the scope of the Teams 45-day review.
I am appreciative of the work of Mr. Skeen, Team Lead, Ms. Theresa Clark, Deputy Team Lead, and all Team members, especially those external to the NRC. The Team assembled on very short notice and compiled a detailed and extensive report in a relatively short time, concurrent with the agencys coronavirus response. The report provides significant information and analysis, bringing more clarity to the safety questions at issue with the pipeline. The Teams
The Commissioners 3
product will prove very useful in the future as we strive to enhance our approach to regulatory oversight by improving our processes and procedures.
Enclosure:
Report of the U.S. Nuclear Regulatory Commission Expert Evaluation Team on Concerns Pertaining to Gas Transmission Lines Near the Indian Point Nuclear Power Plant cc: SECY OGC OCA OPA CFO
Pkg: ML20100F609, Ltr: ML20099F775, Rpt: ML20100F635 OFFICE EDO NAME MDoane DATE 4/9/2020