Call on FERC to Ban Additional Natural Gas Capacity on the Algonquin Pipelines
Written By: Stratton Report
July 12, 2018
The New York Division of Homeland Security and Emergency Services, and the Departments of Public Service, Environmental Conservation, and Health had issued a letter to the Federal Energy Regulatory Commission with the results of a recently completed, independent risk analysis addressing a portion of the Algonquin natural gas pipelines located near the Indian Point nuclear facility in Westchester County. In their letter, the Agencies urge FERC — the federal agency with siting regulatory authority over interstate gas pipelines — to take additional action to minimize risks and protect public safety.
“Our consultant’s assessment informs logical next steps that must be taken by FERC to reduce the risk profile of Algonquin’s natural gas pipelines in the vicinity of Indian Point, and has identified areas that require further review,” said the Agencies. “While the probability of pipeline incidents is low, the proximity to the Indian Point nuclear plant makes the potential consequences of such an event very significant. Additional scrutiny and monitoring to better understand and reduce risks associated with the Algonquin pipelines is warranted. FERC must engage in further action to mitigate and investigate potential risks.”
The report identified areas of potential concern that should be used to inform appropriate regulatory activities designed to further reduce the risk profile during the remaining operating life of Indian Point, the transfer of spent nuclear fuel to dry cask storage, and decommissioning activities. In its letter (see below) to FERC, the Agencies called upon FERC to take the following immediate steps:
FERC should not allow any additional natural gas capacity on the Algonquin pipelines. Given high demand in the Northeast for additional natural gas capacity, and the large diameter of the Algonquin Incremental Market pipeline near Indian Point, there is potential that pipeline owner Enbridge, Inc. may request approval to send additional gas over the pipeline at higher pressures. The safety analyses relied upon by FERC when approving the AIM project were based on current maximum operating pressures on the pipeline. The State has remaining questions about the safety assessments of AIM and the original Algonquin pipelines, and it is important to not increase the risk profile of the pipelines while questions remain and Indian Point is still operational.
FERC should require regular testing of Enbridge’s ability to remotely close valves on the 42-inch, 30-inch, and 26-inch pipelines in the vicinity of Indian Point within three minutes of an event. This valve closure time was noted by FERC when it approved the AIM pipeline, but it must be regularly confirmed for all three pipeline segments, the original Algonquin pipelines and the AIM pipeline.
FERC must work with NRC to coordinate a review of Indian Point-owner Entergy Corp.’s decommissioning plan when filed to determine potential impacts to the original Algonquin pipelines and the AIM pipeline. Given the heavy excavator work that will be part of decommissioning, FERC may need to require Enbridge to temporarily cease gas operations during the decommissioning activities that may threaten the pipeline integrity. The Department of Public Service, which is delegated by the federal government to ensure compliance with federal gas pipeline safety standards, has already enhanced monitoring of the pipelines in the vicinity of Indian Point. The Agencies recommend more regular communications between Enbridge and Entergy on incident prevention activities and emergency preparedness.
The Agencies also called on FERC to re-evaluate whether the NRC and Entergy analyses relied on by FERC during the review of the AIM project were sufficient. The NRC and Entergy analyses concluded that the Indian Point reactors could safely shut down if there were a pipeline incident, but they may not have fully considered all necessary and appropriate factors, including for example the different design characteristics of the buildings housing the spent nuclear fuel cooling pools.
The State commissioned the report by HDR Engineering, Inc., which assessed the potential risks of pipeline incidents in the vicinity of Indian Point. The report concludes that the upcoming closure of Indian Point’s nuclear reactors and the removal of spent nuclear fuel from the spent fuel pools to on-site dry cask storage will reduce the risks related to a potential pipeline incident. Since it discusses critical infrastructure and the risk profiles of collocated gas pipelines and nuclear power reactors, the Agencies requested that FERC protect the confidential nature of the complete study.
According to sources, after Indian Point shuts down, thousands of spent fuel rods will remain housed in cement dry casks on the property and will likely remain there for decades until the federal government comes up with a solution for storing the nation’s nuclear waste.
To date the Nuclear Regulatory Commissions original assessment has not changed.
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