Symposium Co-locating Nuclear Plants with Natural Gas Pipelines - - PDF document

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Symposium Co-locating Nuclear Plants with Natural Gas Pipelines - - PDF document

RPI Engineering Symposium Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch, Energy Consultant Co-locating Nuclear Plants with Natural Gas Pipelines 12/15/16 1 Paul Blanch Energy Consultant Indian Point the most


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SLIDE 1

RPI Engineering Symposium

Co-locating Nuclear Plants with Natural Gas Pipelines

12/15/16 1 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

Paul Blanch, Energy Consultant

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SLIDE 2

Indian Point the most threatening nuclear facility in the US

12/15/16 2 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 3

Summary of Problem

  • Co-location of a nuclear power plant and a natural gas pipeline
  • Hasty installation of a 42 inch diameter high pressure natural gas

pipeline at Indian Point nuclear plant

  • Calculation of risk for siting approval used a computational tool

(ALOHA) that is prohibited for a rupture in this configuration.

  • NRC/Entergy calculates 1100 foot blast radius. Independent

engineers calculate greater than 4000 foot blast radius using NRC-approved equations.

  • 4000 foot blast radius will engulf entire nuclear site
  • May disable all site power and back-up safety systems

(Fukushima)

  • A valid risk assessment has not been conducted by the NRC,

Entergy, PHMSA, or NYS of neither the existing pipelines nor Spectra ¡Energy’s ¡Algonquin ¡Incremental ¡Market ¡(AIM) ¡pipeline ¡ at Indian Point

  • No independent risk assessment has been conducted
  • A risk assessment is required by Federal Regulations
  • Failure rate for pipelines is increasing
  • No evacuation protocol for 20 million people in the 50 mile

impact radius

  • No emergency preparedness plan
  • Lack of public awareness

12/15/16 3 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 4

Indian Point Looking West Showing Existing Gas Line Route

12/15/16 4

Aerial Photo taken by Paul Blanch June 2010 Width about 3000 feet

Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 5

AIM Pipeline Path at Indian Point

12/15/16 5 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 6

Indian Point 50 mile Evacuation Zone

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20 million people impacted

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SLIDE 7

12/15/16 7

NRC Equations for Gas Release. Includes heat flux, overpressure and vapor cloud explosions

Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 8

Calculation Assumptions Provided by the NRC FOIA

  • Initial flow from broken line is

376,000Kg/minute

  • TNT energy equivalent is about 12 million

pounds of TNT per minute or about 5 kilotons per minute

  • Gas flow will be terminated within 3 minutes

12/15/16 8 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 9

NRC/Entergy Calculation

12/15/16 9

  • The NRC and Entergy both calculate a damaging blast

radius of about 1100 feet

(Results were Redacted)

Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 10

NRC Calculation

  • NRC used prohibited EPA ALOHA program

to calculate blast without any justification but:

– It apparently provided the answer they desired

  • Calculation not reviewed, signed, dated and

not in accordance with any QA requirements

  • No calculation provided for realistic 60

minute release

12/15/16 10 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 11

Additional Details of Calculation Problems

  • NRC scientist with 8 years nuclear experience

used prohibited EPA program, ALOHA, and calculated 1100 feet blast radius from 42-inch line (850 psi)

  • Calculations performed by four engineers (3 PEs)

with more than 120 years of nuclear experience using data from the NRC/Entergy, independently calculate a blast radius of more than 4000 feet

– Calculations performed in accordance with the intent

  • f quality assurance program required by the NRC

(10 CFR 50 Appendix B)

  • Chairman Burns of the NRC misrepresented blast

calculation to US Congresswoman Lowey (3/24/2015)

  • Approval of ¡project ¡by ¡FERC ¡based ¡on ¡NRC’s ¡

miscalculation

  • FERC ¡never ¡saw ¡a ¡copy ¡of ¡NRC’s ¡calculation

12/15/16 11 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 12

Blast Information

  • Entergy admits in 1997 in communication with the

NRC that a gas event may cause major damage extending ¡for ¡“several ¡thousand ¡meters”

  • Energy released in pipe break is about 3 kilotons per

minute of TNT equivalent although its impact will be much less than 3 kilotons detonating

  • IAEA recommends distance from gas lines to nuclear

facility to be 7-10 km

  • Indian Point main control room is 380 feet from active

gas lines

  • New gas line runs 105 feet from vital structures
  • Shut off valves controlled remotely in Houston, TX
  • NRC used prohibited ALOHA program to miscalculate

damage radius

  • NRC, ¡in ¡response ¡to ¡FOIA ¡request ¡“lost” ¡CD ¡

containing ¡Entergy’s ¡analysis

  • No Entergy procedures to terminate leak or fight fire

12/15/16 12 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 13

Calculation from David Lochbaum

12/15/16 13

Blast Radius of 4200 feet for 3 minute release

Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 14

Calculation Summary from NRC Professional Engineer

12/15/16 14

Blast radius of 4300 feet

Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

Rmin=Z*W 1/3

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SLIDE 15

12/15/16 15

Calculation From DOE Professional Engineer

Blast radius of 4185 feet

Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 16

Calculation by Paul Blanch, PE

12/15/16 16

Blast radius 3000-4000 feet

Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 17

Factors Contributing to Increased Risk

  • Hasty installation
  • Composition of pipeline metal
  • Composition of shale gas obtained by

hydraulic fracturing

  • Insufficient regulatory oversight
  • Non-compliance with regulations

12/15/16 17 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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Risk

  • The product of consequences and probability
  • The calculated probability has been reduced

by the NRC by a factor of 100-1000 without any supporting documentation

  • Consequences may surpass those of

Fukushima due to population density and radioactive spent fuel on site

  • Risk assessments have been requested by

many NYS and US Congressional representatives and the Governor

– None have been produced to date

  • NYS contracted for a risk assessment without

mentioning Indian Point

– Final product required by October 5, 2016

12/15/16 18 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 19

Probability of Gas Line Failure from PHMSA 6.6x10-4/mile-year

12/15/16 19 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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Probability of an Accident

  • Probability of a major release is not clearly

defined however the NRC appears to accept an accident (core damage and release) frequency

  • f about 1 in 10 million (10-7/year) from

Regulatory Guide 1.91

  • While impossible to quantify the estimated

failure rate of the gas lines is in the range of 1 in 10,000/year to 1 in 100,000/year (terrorism excluded)

  • The commercial airline failure rate is about

1 in 20,000,000/flight and includes terrorism

  • The potential consequences of an airline crash

are trivial when compared to Indian Point gas line event

  • The potential of a gas line event is much

greater than a commercial flight and is a continuous risk, 365/24/7

12/15/16 20 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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Potential Consequences

  • Impact on 20 million people
  • Uninhabitable land out to 50+ miles

– Including much of NYC, NJ and CT

  • Impact on US Economy (trillions of $$$)
  • Fukushima on site clean-up costs are

approaching $1 trillion

  • Evacuation of millions for generations
  • Uninsured losses
  • Prompt and latent fatalities
  • loss of infrastructure

– Wall Street, Trump Tower, Water Supplies, Transportation, etc.

  • Anarchy and panic

12/15/16 21 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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Risk Assessment

  • Although aware of the blast radius

miscalculation and other inaccuracies, FERC, PHMSA and NRC have not required a valid risk assessment even though it has been requested by Congressional and NY State representatives

  • Any risk assessment must be independent and

transparent

  • Risk assessment should follow the guidance
  • f OSHA 29 CFR 1910.119 Appendix C.

– “Compliance ¡Guidelines ¡and ¡Recommendations ¡for ¡ Process Safety Management”

12/15/16 22 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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Alleged Wrongdoing by New York State

  • NYS, through formal agreement with PHMSA has

the responsibility to identify and report violations

  • f 49 CFR 192 to PHMSA. No reports available
  • The Governor ordered a risk assessment for the

new pipeline. Does not even include possible collateral damage to Indian Point

– Contract required to be completed by October 5, 2016

  • NYS risk assessment has not been delivered
  • AG and Governor Cuomo were formally notified
  • f potential problem since 2010.

– Response: Not our responsibility!

  • Governor has ordered safety inspection (12/2015)

that was never conducted

  • NYS denied Blanch FOIA requests for risk

assessment information

12/15/16 23 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 24

Alleged Wrongdoing by NRC

  • Denied ¡Blanch ¡petition ¡in ¡2010 ¡due ¡to ¡“security” ¡

concerns

  • Denied Blanch 2014 petition without addressing

any issues

  • Chairman made inaccurate statements in testimony

before US Congresswoman Lowey (3/24/2015)

  • Continues to refuse to discuss differences and

discrepancies (Regulatory Infallibility)

  • Apparently used wrong data, assumptions and

program for blast radius

– But it did provide desired results

  • Did not question unrealistic 3-minute valve closure

time in confirmatory analysis

– NTSB reports nominal isolation times range from 30 to 90 minutes

  • Formally refused to verify content of million

gallon fuel tanks

  • Provided false information to FERC and PHMSA

resulting in final approval of project

12/15/16 24 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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Alleged Wrongdoing by NRC (continued)

  • “Risk ¡Assessment” ¡by ¡Entergy ¡“Lost” ¡per ¡FOIA ¡

response

  • ACRS and NRC have refused public meetings
  • NRC OI refused to investigate alleged criminal

actions by Entergy

  • Has never performed risk assessment on existing

lines located 380 feet from control room

  • NRC/Entergy ¡“risk ¡assessment” ¡used ¡prohibited ¡

EPA ALOHA computer code

  • Closed Blanch petition with 46 open issues in

violation of NRC procedures

  • Violated at least 2 of its Management directives
  • Under investigation by the NRC Inspector

General (Case #16-024)

12/15/16 25 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 26

Alleged Wrongdoing by FERC

  • In its application Spectra certified compliance

with all requirements of 49 CFR 192

  • FERC never confirmed compliance
  • These requirements include risk assessment,

first responders, public education and awareness and hundreds of others

  • FERC approved AIM project without ever

seeing ¡any ¡“risk ¡assessment” ¡from ¡the ¡NRC ¡

  • r Spectra
  • Ignored formal public comments

12/15/16 26 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 27

Alleged Wrongdoing by PHMSA

  • Ignoring Entergy admission that a gas event

may ¡cause ¡major ¡damage ¡for ¡“several ¡ thousand ¡meters”

  • Ignoring NRC use of prohibited ALOHA

program to miscalculate damage

  • Ignoring potential social and economic risks

calculated in the Trillions of $$

  • Ignoring warnings that gas line event may

engulf entire Indian Point site

  • Ignoring warnings that land may be

uninhabitable for generations

  • Ignoring invalid assumed valve closure time
  • Ignoring concerns of terrorism required by 49

CFR 192 and ASME B31.8(s)

12/15/16 27 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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Alleged Wrongdoing by Entergy

  • Provided alleged material false information to

the NRC

– NRC Office of Investigation refused to investigate

  • Provided ¡“risk ¡analysis” ¡inconsistent ¡with ¡any ¡

established engineering principals such as blast radius and valve isolation times

  • Did not consider possibility of explosive

vapor clouds

  • Has no procedures to respond to gas leak or

explosion or notification to Spectra

  • Control room located 380 feet from gas line

has no detection, isolation or emergency

  • procedures. Analysis could not be located
  • Refused to meet in public to discuss

differences and discrepancies

12/15/16 28 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 29

Problems Unresolved by NYS AG and Governor

  • Cuomo states he wants Indian Point closed
  • Missed opportunities
  • Ignored problems during license renewal
  • No action taken after problem formally identified

to his office

  • Has the power/responsibility through the MOU

with PHMSA to identify noncompliances

  • Directed ¡and ¡contracted ¡for ¡“risk ¡assessment” ¡

while never mentioning impact on Indian Point

  • Denied FOIA request (under appeal)
  • Negotiated ¡“deal” ¡with ¡Entergy ¡for ¡upstate ¡

nuclear plants

  • Made inconsistent statements to the public

12/15/16 29 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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Risk vs. Benefit of More Gas Supply Co-located with Indian Point

  • Possible Risks

– Increased CO2 – US Economy could be destroyed – 20 Million inhabitants relocated – Trillions $$$ – Uninsured property

  • Claimed Benefits

– Decreased CO2 – Energy Independence – Lower natural gas prices for New England

  • Actual Benefit

– $$$ to Spectra Energy

12/15/16 30 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 31

What choices do we have to reduce risk?

  • Admit there is a problem
  • Stop new pipeline
  • Reroute gas from existing pipeline
  • Close Indian Point

– Reduces but does not eliminate risks

  • Close Broadway adjacent to Indian Point

removing one terrorist threat

  • Reduce airborne threats
  • DHS needs to evaluate all potential threats

– Airborne, Oklahoma City attack, drones, cyber security, insiders, etc.

12/15/16 31 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 32

Regulatory Infallibility

  • NRC, FERC, and PHMSA decisions cannot be

challenged even in a court of law and only after the fact

  • NRC, FERC and PHMSA will not discuss

differences and discrepancies.

  • No effective Congressional oversight
  • NRC engineers making decisions that impact the

safety of 20 million people do not need to be licensed, be a PE, or any nuclear background

– (One would need a license to cut hair in Connecticut)

  • Similar lack of requirements for other involved

agencies

  • Safety reviews and calculations have no

requirements for Quality Assurance

  • FERC and PHMSA do not review or enforce or

look for regulatory non-compliance

12/15/16 32 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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Tombstone Regulation

  • Regulations will only be enforced after the

tombstones are counted or after a major accident

– Fukushima – Three Mile Island – Exxon Valdez – BP Gulf oil spill – San Bruno – Bridge Failures – Dam Failures – Transportation accidents Examples can be found in numerous NTSB accident reports

12/15/16 33 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 34

Discussion

  • Suggestions from Elected

Officials

  • Suggestions from NRC, Entergy,

FERC, Spectra, PHMSA

  • Suggestions/comments/questions

from Students, Professors, the Public

12/15/16 34 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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Terms and Acronyms

  • NRC - Nuclear Regulatory Commission

– Responsible ¡for ¡protecting ¡the ¡“People ¡and ¡Environment”

  • OIG - NRC’s ¡Office ¡of ¡the ¡Inspector ¡General ¡
  • OI - NRC’s ¡Office ¡of ¡Investigation ¡

– Responsible for investigating licensee wrongdoing and can refer cases to Department of Justice

  • FERC - Federal Energy Regulatory Commission

– Responsible for siting of major energy projects and compliance with Federal Regulations

  • PHMSA - Pipeline and Hazardous Materials Safety

Administration

– Responsible for regulatory compliance and inspection of pipelines (49 CFR 192)

  • CFR - Code of Federal Regulations

– Specifies minimum requirements for all Federal Agencies

  • ACRS - NRC’s ¡Advisory ¡Committee ¡for ¡Reactor ¡

Safety

– Advises Commission on major safety issues facing the nuclear industry

12/15/16 35 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 36

Terms and Acronyms

  • AIM

– Algonquin Incremental Market pipeline

  • Entergy

– Owner and operator of Indian Point Units 1, 2, 3.

  • IPEC

– Indian Point Energy Center- A Limited Liability Corporation

  • perating Indian Point
  • AG

– New York State Attorney General

  • NYS

– New York State

  • IAEA

– International Atomic Energy Agency

  • PE

– Licensed Professional Engineer

  • NTSB

– National Transportation Board

  • FOIA

– Freedom Of Information Act

  • MOU

– Memorandum Of Understanding between NYS and PHMSA

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SLIDE 37

PHMSA Regulation Requiring Risk Assessment

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NRC Regulation Requiring Risk Assessment

§ 50.59 Changes, tests, and experiments.

(C)(2) A licensee shall obtain a license amendment pursuant to § 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would: (i) Result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the final safety analysis report (as updated); (ii) Result in more than a minimal increase in the likelihood of occurrence of a malfunction

  • f a structure, system, or component (SSC) important to safety previously evaluated in the

final safety analysis report (as updated); (iii) Result in more than a minimal increase in the consequences of an accident previously evaluated in the final safety analysis report (as updated); (iv) Result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the final safety analysis report (as updated); (v) Create a possibility for an accident of a different type than any previously evaluated in the final safety analysis report (as updated); (vi) Create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report (as updated); (vii) Result in a design basis limit for a fission product barrier as described in the FSAR (as updated) being exceeded or altered; or (viii) Result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses. 12/15/16 38 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 39

Insanity on Steroids

12/15/16 39

Locating high-pressure gas transmission lines 380 feet from nuclear power plant main control room and within 35 miles of New York City

Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 40

Additional Information

For any additional information such as copies of the presentation, documentation, communications with Federal agencies, FOIA requests and responses, meeting notes with the NRC, etc. Please contact:

pmblanch@comcast.net

12/15/16 40 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant

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SLIDE 41

My personal thanks to the following

  • RPI President Dr. Shirley Jackson
  • RPI Professor Yuri Gorby
  • Congresswoman Nita Lowey and staff
  • Assemblywoman Sandy Galef and staff
  • Congressman Engel and staff
  • Richard Kuprewicz – Pipeline Safety Expert
  • Ellen Weininger
  • Amy Rosmarin
  • Susan Van Dolsen
  • Nancy Vann
  • Riverkeeper
  • David Lochbaum and all of the unnamed NRC

and Entergy personnel providing insights and information

  • Hundreds of people contributing thousands of

hours and dollars to this effort

– even getting arrested for protesting this insanity

12/15/16 41 Co-locating Nuclear Plants with Natural Gas Pipelines Paul Blanch Energy Consultant