ML15044A459

Transcript of 10 CFR 2.206 Petition Review Board Re Indian Point Nuclear Generating, Units 2 and 3, Teleconference January 28, 2015, Pages 1-48

ML15044A459
Person / Time
Site:	Indian Point
Issue date:	01/28/2015
From:	Pickett D Plant Licensing Branch 1
To:
Pickett D
References
2.206, NRC-1342
Download: ML15044A459 (49)

Text

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title: 10 CFR 2.206 Petition Review Board RE Indian Point Nuclear Generating Unit Docket Number: 05000247 and 05000286 Location: teleconference Date: Wednesday, January 28, 2015 Edited by Douglas Pickett Work Order No.: NRC-1342 Pages 1-48 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 (202) 234-4433

1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +

4 10 CFR 2.206 PETITION REVIEW BOARD (PRB) 5 CONFERENCE CALL 6 RE 7 INDIAN POINT 8 + + + + +

9 WEDNESDAY 10 JANUARY 28, 2015 11 + + + + +

12 The conference call was held, Christopher 13 Miller, Chairperson of the Petition Review Board, 14 presiding.

15 16 PETITIONER: PAUL BLANCH 17 18 PETITION REVIEW BOARD MEMBERS 19 Christopher Miller, Chairperson 20 Lee Banic 21 Thomas Setzer 22 Rob Carpenter 23 Dave Beaulieu 24 Dave Cylkowski 25 Ben Beasley NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 1 PETITION REVIEW BOARD MEMBERS (Continued) 2 Paul Prescott 3 Tahirih Solomon 4 Rao Tammara 5 Mike McCoppin 6 Dori Willis 7 Greg Oberson 8 Diane Render 9 Sergiu Basturescu 10 Doug Tifft 11 Stella Opara 12 Doug Pickett 13 Gladys Figueroa 14 Neil Sheehan 15 Sergiu Basturescu 16 Paul Prescott 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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3 1

2 T-A-B-L-E O-F C-O-N-T-E-N-T-S 3 Opening Remarks 4 Doug Pickett......................................4 5 Introductions......................................5 6 Chairman's Remarks 7 Christopher Miller...............................10 8 Presentation by Petitioner 9 Paul Blanch......................................17 10 Richard Kuprewicz................................19 11 Statement from New York Assemblywoman Galef's Office 12 Dana Levenberg...................................34 13 Questions for the Presenters 14 Susan Van Dolsen.................................40 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 P-R-O-C-E-E-D-I-N-G-S 3 MR. PICKETT: Good afternoon. Again, my 4 name is Doug Pickett. I'm the Indian Point project 5 manager in NRR in Rockville, Maryland. We're here 6 today to allow the Petitioner, Mr. Paul Blanch, assisted 7 by Mr. Richard Kuprewicz of Accufacts, Incorporated, to 8 address the Petition Review Board, also referred to as 9 the PRB, regarding the 2.206 petition submitted by Mr.

10 Blanch on October the 15th, 2014. I am the petition 11 manager for the petition and the PRB Chairman is Mr.

12 Christopher Miller.

13 As part of the PRB's review of this petition 14 Mr. Paul Blanch has requested this opportunity to 15 address the PRB. This meeting is scheduled from 2:30 16 to 3:30 this afternoon.

17 The meeting is being recorded by the NRC 18 Operations Center and will be transcribed by a court 19 reporter. The transcript will become a supplement to 20 the petition. The transcripts will also be made 21 publicly available.

22 I'd like to open this meeting with 23 introductions. As we go around the room here in 24 Rockville, Maryland, please be sure to clearly state 25 your name, your position and the office that you work NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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5 1 for within the NRC. We're going to start introductions 2 with myself here in Rockville, Maryland.

3 I'm Doug Pickett, the petition manager.

4 CHAIRMAN MILLER: And I'm Chris Miller.

5 I'm with the Division of License Renewal in the Office 6 of Nuclear Reactor Regulation, and I'll be the PRB 7 Chair.

8 MS. RENDER: I'm Diane Render from the 9 Division of Operating Reactor Licensing, project 10 manager.

11 MR. McCOPPIN: Mike McCoppin. I'm Chief 12 of the Radiation Protection and Accident Consequences 13 Branch, Office of New Reactors.

14 MR. TAMMARA: My name is Rao Tammara. I'm 15 the technical reviewer, NRO.

16 MR. COLYER: Eddie Colyer, project 17 manager, Health Quality and Rulemaking.

18 MS. Banic: Lee Banic, NRR petition 19 coordinator.

20 MR. BLANCH: Yes, could people speak up a 21 little bit? I'm having trouble hearing.

22 PARTICIPANT: Can't hear.

23 MR. CYLKOWSKI: David Cylkowski. I'm an 24 attorney in the Office of General Counsel.

25 MS. SOLOMON: Tahririh Solomon, the senior NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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6 1 special agent with the Office of Investigations.

2 MR. CARPENTER: Rob Carpenter, Office of 3 Enforcement, enforcement specialist.

4 MR. BEASLEY: Ben Beasley. I'm a branch 5 chief in the Division of Operating Reactor Licensing.

6 MS. WILLIS: Dori Willis. I'm the team 7 lead for Allegations and Enforcement in NRR.

8 MR. Harris: Brian Harris, project 9 manager, DPR.

10 MR. OBERSON: Greg Oberson, materials 11 engineer, Office of Nuclear Regulatory Research.

12 MS. SPIRA: Mattie Spira, Office of 13 Enforcement.

14 MS. OPARA: Stella Opara, NRR, allegations 15 specialist.

16 MR. PICKETT: We have completed the 17 introductions in the NRC headquarters. You can tell 18 we've got quite a few people in a lot of areas of 19 expertise being represented.

20 At this time we'd like to know is there 21 anybody else from NRC headquarters on the phone?

22 MR. PRESCOTT: Yes, Paul Prescott from the 23 Office of NRO, Quality and Vendor Inspection Branch.

24 MR. BASTURESCU: Sergiu Basturescu, NRR, 25 Technical Review.

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7 1 MR. PICKETT: Okay. Anyone else from NRC 2 headquarters?

3 (No audible response) 4 MR. PICKETT: And is there anyone from NRC 5 from the regional office on the phone?

6 MR. SHEEHAN: Neal Sheehan, Office of --

7 (Simultaneous speaking) 8 MR. PICKETT: I'm sorry, we heard Neal 9 Sheehan and who else?

10 MR. BURRITT: Art Burritt.

11 MR. PICKETT: Okay.

12 MR. SETZER: Doug, Tom Setzer, Region I.

13 MR. PICKETT: Okay. And the Licensee, 14 Entergy, could you please introduce who you have on the 15 phone?

16 MR. WALPOLE: Sure, Doug. It's Bob 17 Walpole, Manager; Steve Prussman from Regulatory 18 Assurance; and Rich Drake, our civil engineering 19 supervisor.

20 MR. PICKETT: Okay. Mr. Blanch, Mr.

21 Kuprewicz, would you please introduce yourselves along 22 with anyone else that's with you for the record?

23 MR. BLANCH: Yes, this is Paul Blanch.

24 I'm an energy consultant and the Petitioner. I'd like 25 to introduce Rick Kuprewicz, who will be also making a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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8 1 statement. I'd like to thank Jerry Shapiro of Senator 2 Gillibrand's office; Dana Levenberg, who will also be 3 making a brief statement; and Sara Levine of 4 Assemblywoman Lowey's office. And I'd like to say hi 5 to old friends Bob Walpole and Paul from Morgan Lewis.

6 MR. PICKETT: Okay. It's not required for 7 members of the public to introduce themselves for this 8 call, however, if there are members of the public; and 9 I understand there are, could you please identify 10 yourself at this time?

11 MS. CLAIRE: Paula Claire, Garrison, New 12 York.

13 MS. GLIDDEN: Susanna Glidden, North 14 Salem, New York.

15 MS. ROSEMARY: Emily Rosemary, 16 councilwoman, Town of North Salem.

17 MS. McDONALD: Susan McDonald, New York.

18 MS. VAN DOLSEN: Susan Van Dolsen, 19 Harrison, New York.

20 MR. PICKETT: Could we do those again, the 21 last two. Susan McDonald I heard and --

22 MS. VAN DOLSEN: Susan Van Dolsen, 23 Harrison, New York.

24 MR. PICKETT: Thank you.

25 MS. VANN: Nancy Vann, Peekskill, New NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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9 1 York.

2 MR. HOUSTON: William Houston, 3 Binghamton, New York.

4 MR. BESSETTE: Paul Bessette, Morgan 5 Lewis.

6 MS. WISER: Ellen Wiser, White Plains, New 7 York.

8 MS. SPEAR: Susan Spear, Office of U.S.

9 Senator Kirsten Gillibrand.

10 MR. LOCHBAUM: Dave Lochbaum, Union of 11 Concerned Scientists.

12 MR. PICKETT: Okay.

13 MS. LEVENBERG: Dana Levenberg, New York 14 State Assemblywoman Sandy Galef's office.

15 MS. LEVINE: Sara Levine, Congresswoman 16 Nita Lowey's office.

17 MR. PICKETT: Okay. If there's no one 18 else, I'd like to emphasize that we each need to speak 19 clearly and loudly to make sure that the court reporter 20 can accurately transcribe this meeting. If you have 21 something to say, we'd like you to first state your name.

22 For those dialing into the meeting, please remember to 23 mute your phones to minimize any background noise or 24 distractions. If you do not have a mute button, you can 25 do this by pressing the star, six buttons. To un-mute, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 1 press the star, six keys again.

2 At this time I'll turn this over to the PRB 3 Chairman, Chris Miller.

4 COURT REPORTER: Mr. Pickett, this is the 5 court reporter. Before you proceed with the call this 6 afternoon, at the conclusion of the call could you 7 provide me with a service list of the names of everyone 8 on the call? People that registered to speak and party 9 members.

10 MR. PICKETT: I can certainly give the 11 names of the NRC folks. I was hoping to rely on you to 12 get the names of everybody else.

13 COURT REPORTER: So do you have a list of 14 people who are registered to speak?

15 MR. PICKETT: This call is also being 16 recorded by the NRC Operation Center, so we can go back 17 over the recording.

18 COURT REPORTER: All right. Thank you.

19 MR. PICKETT: I'll help you out with that.

20 COURT REPORTER: Sure. Thanks.

21 MR. PICKETT: Okay.

22 CHAIRMAN MILLER: Thank you. And good 23 afternoon, everyone. Thanks for convening with us 24 today and agreeing to provide information. Thank you, 25 Mr. Blanch and Mr. Kuprewicz. I'm Chris Miller and I'm NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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11 1 looking forward to hearing the information you have to 2 provide for us.

3 I'd like to first share some background on 4 the process that we're using. Section 2.206 of Title 5 10 of the Code of Federal Regulations process is the 6 primary mechanism for the public to request enforcement 7 action by the NRC in a public process. This process 8 permits anyone to petition the NRC to take 9 enforcement-type action related to NRC licensees or 10 licensed activities. Depending on the results of its 11 evaluation, the NRC could modify, suspend or revoke an 12 NRC-issued license or take any other appropriate 13 enforcement action to resolve a problem. The staff 14 guidance for the disposition of this 2.206 petition 15 request is in Management Directive 8.11, which is 16 publicly available on our Web site.

17 Today's meeting's purpose is to give the 18 Petitioner, Mr. Blanch, an opportunity to provide any 19 additional explanation or support for the petition 20 before the Petition Review Board's initial 21 consideration and recommendation.

22 So we have the initial documents that you 23 sent, and I believe you supplemented with some 24 additional items, Mr. Blanch, today. They came to us 25 at the last minute and I don't know if everybody on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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12 1 Board has gotten a chance to look at all of them, but 2 we do have them and we'll take them into consideration 3 when the Panel meets.

4 So, a couple of things. This meeting is 5 not a hearing. It's not an opportunity for the 6 Petitioner to question the NRC or the PRB about the 7 merits of the issues presented in the petition request.

8 It's really an opportunity for you to give us a fuller 9 picture, us, the members of the Board, a fuller picture 10 that we can work from in making our deliberations.

11 No decisions regarding the merits of this 12 petition will be made at this meeting.

13 Following the meeting the Petition Review 14 Board will conduct its internal deliberations and then 15 the outcome of the internal meeting will be discussed 16 with the Petitioner, Mr. Blanch.

17 The Petition Review Board typically 18 consists of a chairman, usually a manager at the senior 19 executive level who serves with the NRC. And you've 20 heard some of the other -- that's myself. And then a 21 petition manager, which is Doug, and a PRB coordinator.

22 Other members of the Board are determined by the NRC 23 staff based on the content of the information in the 24 petition request.

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13 1 ask clarifying questions in order to better understand 2 the Petitioner's presentation and reach a reasoned 3 decision whether to accept or reject the Petitioner's 4 request for review under the 2.206 process. And we'll 5 try to do that at the end of the call. We'll listen to 6 everything that you and your speakers have, Mr. Blanch, 7 and then we'll try to ask if there's any clarifying 8 questions or any additional information that we think 9 that members of the Board may need to ask of you.

10 With that being said, I want to summarize 11 the scope of the petition under consideration and the 12 NRC activities to date. On October 15th Mr. Blanch 13 submitted a 2.206 petition to the NRC regarding the 10 14 CFR 50.59 site hazards analysis prepared by Entergy 15 Nuclear Operations, the Licensee, for Indian Point 16 Nuclear Generating Stations 2 and 3.

17 The 50.59 analysis was performed by the 18 Licensee to determine the safety impact on the Indian 19 Point plant due to Spectra Energy's proposed 42-inch 20 diameter natural gas pipeline that has plans to traverse 21 a portion of the owner-controlled property at the Indian 22 Point facility.

23 In the petition Mr. Blanch requests that 24 the NRC take the following enforcement actions against 25 Entergy, the Licensee, for the following violations:

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14 1 Violation of 10 CFR 50.59, Completeness and Accuracy of 2 Information, for providing inaccurate and incomplete 3 information in the 50.59 site hazards analysis; 4 violation of 10 CFR 50, Appendix B, Quality Assurance 5 Criteria for Nuclear Plants and Fuel Reprocessing 6 Plants, for relying on a contractor who was not 7 qualified in accordance to Appendix B requirements, was 8 not qualified in accordance with Entergy Quality 9 Assurance Program, and, as a result, was not qualified 10 to perform an analysis for such significant 11 safety-related issue; and violation of 10 CFR 50.59, 12 Changes, Tests and Experiments, for failing to perform 13 the necessary safety evaluation requirements.

14 Furthermore, in the petition, Mr. Blanch 15 requested that the NRC issue a demand for information 16 against Entergy for the following: Demand an 17 explanation from Entergy seeking an explanation as to 18 why the previously identified violations do not also 19 constitute a violation of 10 CFR 50.5, Deliberate 20 Misconduct; demand that Entergy seek the results of a 21 new and realistic risk hazard analysis consistent with 22 the guidance providing in OSHA Appendix C, Section 23 1910.119, Compliance Guidelines and Recommendations 24 for Process Safety Management; and demand that Entergy 25 attest to the completeness and accuracy of Entergy NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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15 1 Report IP-PRT-08-00032, prepared in August 2008 that 2 assessed the safety impact of the existing 26 and 3 30-inch diameter natural gas pipelines that traverse 4 the owner-controlled property in Indian Point.

5 That report was performed by the same 6 contractor that performed the current site hazards 7 analysis for Entergy. In addition, the report from 8 August 2008 contributed to NRC's rejection of a previous 9 2.206 petition submitted by Mr. Blanch concerning the 10 existing natural gas pipelines.

11 The Petitioner has also supplemented his 12 original petition with the following: The Town of 13 Cortlandt, New York contracted with Accufacts, 14 Incorporated to perform a review and analysis of the 15 proposed Spectra Energy natural gas pipeline and how it 16 may affect Cortlandt.

17 The Blanch petition is supplemented by the 18 Accufacts letter dated November 3rd, 2014 that is 19 critical of Entergy's 50.59 site hazards analysis and 20 characterizes it as seriously deficient, inadequate and 21 under-representing the real risks.

22 Point 2, the Petitioner letter dated 23 November 11th, 2014 discusses the proposed West Point 24 Partners' construction of a high voltage direct current 25 transmission cable that may run near or adjacent to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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16 1 proposed natural gas pipelines before tying into the 2 Buchanan Switchyard. This letter also supplements the 3 Blanch petition. The Petitioner has expressed concern 4 that stray DC currents emanating from the high voltage 5 cable could adversely impact the existing gas 6 pipelines, the new gas pipelines, and underground 7 safety-related components at the Indian Point facility.

8 And if I may discuss the NRC activities to 9 date, on November 24th, 2014 the petition manager 10 contacted the Petitioner to discuss the 2.206 process 11 and to offer the Petitioner an opportunity to address 12 the PRB by phone or in person. Petitioner requested to 13 address PRB by phone prior to its internal meeting to 14 make the initial recommendation to accept or reject the 15 petition for review.

16 As a reminder for the phone participants, 17 please identify yourself if you make any remarks as this 18 will help in the preparation of the meeting transcript 19 that will be made publicly available. And thank you.

20 Mr. Blanch, I'll turn to over to you and Mr.

21 Kuprewicz to provide any information you believe the PRB 22 should consider as part of this petition.

23 MR. BLANCH: Okay. This is Paul Blanch 24 speaking again. With your introduction, which I 25 appreciate, I'm sorry, that was Charles Miller is your NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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17 1 name?

2 CHAIRMAN MILLER: Chris Miller.

3 MR. BLANCH: Chris Miller?

4 CHAIRMAN MILLER: Yes.

5 MR. BLANCH: Okay. You stated obviously 6 that this is being conducted in accordance with 10 CFR 7 2.206 and guidance provided by Management Directive 8 8.11. And you made a statement that this is not an 9 opportunity for questions by the Petitioner. I'm not 10 sure where that statement originated. I've reviewed 11 Management Directive 8.11 and it's clear certainly that 12 the Licensee is allowed to ask questions and the NRC can 13 ask questions and it does not prohibit the Petitioner 14 from asking questions. Again, we don't have to get into 15 the details of the Management Directive.

16 But secondly, this meeting is somewhat a 17 follow up of a telephone conversation the NRC had in 18 early December with various congressional 19 representatives of the New York and Westchester area, 20 and during that meeting and confirmed by a Mr. Doug 21 Tifft, T-I-F-F-T, that Mr. Blanch would have an 22 opportunity with meetings with the NRC staff and those 23 meetings would include this conversation. So the 24 inference there was that I myself would be able to 25 address technical issues, and that's my primary NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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18 1 interest. And the reason for my interest is primarily 2 to decide whether I further want to amend my petition 3 or take any other subsequent action, including -- well, 4 whatever action I decide to take.

5 Again, I filed a Freedom of Information Act 6 request for various documents related to the analysis, 7 which has been totally redacted except for an 8 introduction and one single reference, that reference 9 being the submittal by Entergy of August 21st. We and 10 the experts are extremely interested because we suspect 11 there contains inaccurate information within the 12 analysis, and I'll get into that a little bit later.

13 And other federal agencies, and Richard can 14 expound on this. There's a process which I sent to you.

15 It's called CEII, which allows members of the public and 16 technical experts to sign an agreement to review various 17 documents that are proprietary, confidential or could 18 endanger the health and safety of the public, and so on 19 and so forth. We'd like the NRC to consider entering 20 into some type of agreement where our experts could 21 review the Entergy and the NRC analysis, because we 22 certainly believe that it contains questionable 23 information at first, at best.

24 Our main concern, and there are many 25 concerns; and Richard is probably the most qualified to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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19 1 speak on that, but in the summary of the analysis 2 provided August 21st by Entergy there was an assumption 3 that the gas flow would be terminated within three 4 minutes of its initiation. And I don't mean detection, 5 but initiation. And based on historical experience and 6 research we certainly question that. And I'd like to 7 stick with that primary point and have Richard speak to 8 that, if that's okay.

9 Now, Richard, if you would like to speak on 10 that particular three-minute isolation time.

11 MR. KUPREWICZ: Sure. Maybe my preamble 12 is, because I haven't spoken up before, and if I'm not 13 getting clear, please speak up because it's hard over 14 the phone on conference.

15 Let me just give you a brief background 16 here. I won't spend a lot of time. I don't usually 17 waste a lot of time selling myself, but I've got over 18 40 years experience in the energy industry, especially 19 in incident investigations related to major pipeline 20 failures. I've spent many years trying to improve 21 pipeline safety regulations, especially after the 22 terrible pipeline ruptures in Bellingham in '99 and in 23 Carlsbad in 2001. That was a gas transmission line was 24 the latter one. And in Bellingham it was a liquid line.

25 Multiple loss of life, near loss of the city in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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20 1 Bellingham, and obviously a tragic loss of life in 2 Carlsbad, a very remote area. It killed 12 people, 5 3 of them children.

4 Anyway, I have assisted over many years in 5 the improvement of pipeline safety regulation, trying 6 to work with industry and various other parties, 7 regulators as well as the public, usually representing 8 the public as members on various committees. Many of 9 those served in the development of pipeline safety 10 regulation regarding integrity management, especially 11 for transmission pipelines. And also in the area that 12 may be very relevant to this particular subject, in the 13 area of pipeline control room management. And those 14 regulations have been promulgated and are now in 15 regulation. And as again in all regulation, there's 16 always a series of compromises, but hopefully you move 17 the ball forward.

18 And I spent over 40 years trying to improve 19 the area of control room management for not only 20 refineries and chemical plants, but also in pipelines.

21 I have very little tolerance for trying to blame the 22 pipeline control room operator for some of these 23 terrible incidents you've been seeing lately in the last 24 10 or 15 or so years.

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21 1 you can get my CV. It's in the public domain. That 2 will cover most of my documents that are in public. The 3 investigations I've been brought into, that are 4 hypersensitive are not in public domain, may involve 5 criminal investigations, and I will not discuss any of 6 that stuff. And I can bring lots of attorneys in on both 7 sides of the fence that will try to protect that 8 neutrality.

9 I am also a very experience HAZOP team 10 leader, and I only mention that because a HAZOP team 11 leader used to carry under law under OSHA a requirement 12 that you had to be field experienced, operational 13 experience to lead the team. I don't know if that's in 14 the current regulations, but that doesn't mean a couple 15 years. So again, the experience requirement is there 16 to assure you're asking the right questions and then the 17 parties can reach a rational reasonable conclusion.

18 Now, let me focus in on the specific issue 19 of the claimed three-minute closure time for the valves.

20 I think the report that I've seen that's in public 21 indicates that they'll close the valves in three minutes 22 under the impression that that will actually stop the 23 gas burning, or the gas explosions, more likely 24 explosions than gas burning, within a three-minute time 25 period. And I'll just tell you that my extensive NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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22 1 experience in this area, you won't even necessarily 2 recognize this within three minutes, much less within 3 a control room many, many miles away, take the 4 appropriate actions to try to initiate actions to shut 5 down, close -- shut some compressors and close valves.

6 That can go for quite some time.

7 Now, in all fairness I need to point out in 8 the San Bruno pipeline rupture, a slightly different 9 animal, smaller line, lower pressure, not necessarily 10 remote-operated valves, but that burned for over 90 11 minutes. Okay? And in that particular location the 12 fire department was several hundred yards down the 13 street. Okay? So my point is in these terrible 14 tragedies -- nobody wants a pipeline rupture, but in 15 these large diameter pipeline ruptures all kinds of 16 dynamics and noise interfere so that what happens is a 17 guy in a control room may or may not get information in 18 a manner allowing him to make what I'll call executive 19 decisions to take the appropriate action to handle a gas 20 pipeline rupture. So time can go very quickly in a 21 control room.

22 And so in this particular case I would say 23 the illusion of a closure time in three minutes is -- it 24 may be after you push the buttons to do that, you may 25 be designed to do that, but the real relevant issue that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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23 1 this Panel I think needs to consider is the actual 2 dynamics that in the event of a pipeline rupture in this 3 sensitive location,the system dynamics will 4 substantially delay the recognition and the appropriate 5 shutoff and responses such that gas will explode and 6 burn for quite a period of time. Right?

7 I need to just comment on one other issue 8 that's often confusing, and that is in federal pipeline 9 safety regulation there's an animal called the 10 potential impact radius that's used to decide what we 11 think might be the potential impact from a gas 12 transmission pipeline rupture. That animal was never, 13 ever intended -- and FERC knows this. I've said this 14 in enough cases under oath, that that was a screening 15 tool to help define high consequence areas. And I've 16 also said under oath in other cases that the PIR was 17 meant to help identify high consequence areas and should 18 not be used to cite the consequences of pipeline 19 ruptures.

20 As it turns out, the larger the diameter of 21 the pipeline, the potential impact radius moves in the 22 right direction, but the actual impact radius can be 23 much larger. And I have said to PHMSA on more than one 24 occasion, trying to go through a cycle to improve the 25 regulations for larger diameter pipelines, that became NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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24 1 very evident -- that there was a problem in the federal 2 regulations that became very evident after the San Bruno 3 rupture. And even the NTSB acknowledges this, there's 4 something not quite right with this PIR equation for 5 larger diameter pipelines.

6 Now with that said, I think the fundamental 7 issue here from my perspective is if the pipeline were 8 to rupture either as a 30-inch or a 42-inch; because the 9 issues goes beyond just the 42-inch, would it generate 10 blast? And the answer probably is mostly likely, 11 though there are ruptures that don't generate blasts.

12 They're rare. When I say "blasts," I mean blasts from 13 the ignition of the gas cloud that is mixed with the 14 turbulent action. And most likely in a rupture you'll 15 get multiple blasts.

16 From what I have seen of the layout; and 17 again, I haven't seen a complete detail of the layout, 18 I don't expect blast forces because -- like major damage 19 to like the reactor buildings or anything, because 20 they're pretty reinforced, but the question would be 21 would possible blast generated cause damage to 22 structures that might be what I'd call safety- critical 23 that would interfere with the possibility of having the 24 fail-safe shutdown of the Reactors 2 and 3? And I don't 25 have an answer to that one. I'll be very frank with you.

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25 1 I would tell you this: Blast forces tend 2 to dissipate. They're situation-specific. And from 3 what I've seen I would expect that there are blast 4 forces. While they will kill, they wouldn't 5 necessarily damage a lot of structure because they 6 dissipate quickly with distance. So the controlling 7 issue regarding this from my perspective and experience 8 is the tremendous amount of heat flux generated from 9 these high-tonnage release gas transmission pipeline 10 ruptures that have ignited.

11 And what happens is the higher the heat 12 flux, the longer the duration, the more damage that can 13 occur. I would expect extensive damage to auxiliary 14 equipment such as transmission pipelines and equipment 15 that might be related to fail-safe shutdown of the 16 reactor facilities themselves.

17 And that's where I brought the very simple 18 question in my report. In the event of a rupture of a 19 sustained duration; it's going to be longer than three 20 minutes given the transient dynamics on this system, 21 what equipment would be affected and would it interfere 22 with the fail-safe shutdown of the plant? I don't have 23 an answer for you on that. I can tell you the burns will 24 be substantially longer than three minutes with 25 significantly high heat fluxes.

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26 1 That's about it for me.

2 MR. BLANCH: Thank you very much, Richard.

3 Does anyone have any questions for what Richard just 4 said?

5 Mr. PICKETT: Excuse me. I just take it 6 -- I do have a question for Mr. Kuprewicz. And I am 7 no --

8 MR. KUPREWICZ: Who's speaking?

9 MR. PICKETT: Doug Pickett. I am no pipe 10 expert like you are, Mr. Kuprewicz, but in layman's 11 terms, and I think I probably represent a lot of the 12 people in the room here, when we think about a 42-inch 13 gas line breaking, we would imagine a major explosion, 14 but after that we would think this would be like 15 effectively a torch and it wouldn't matter whether the 16 valve closed in three minutes or three hours. Now am 17 I wrong in my thinking?

18 MR. KUPREWICZ: Well, first of all, 19 there's no dumb question, so please do not hesitate to 20 ask, if you can. If I'm not clear, then please ask.

21 I'm not here to give a speech.

22 That's a fair question you ask. The 23 tonnage release on these, especially these large 24 diameter pipelines are such that you can expect to see 25 multiple detonations, multiple blasts. The initial NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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27 1 blast will probably be the highest force one. And so 2 when you do site-specific blast pressure waves from the 3 tonnage release and time to ignition, usually the 4 initial blast ignition will have the greatest force.

5 But then what will happen, because the gas releases are 6 so great and the air cloud mixture is so turbulent, 7 you'll see multiple secondary blasts, but they won't be 8 as significant as the first one.

9 But those blast pressure waves will 10 -- again, the science will tell you they dissipate quite 11 quickly with distance. So if you're in a real congested 12 area, that will contribute to the blast forces. But 13 from what I've seen of the structure spacing, I think 14 if you sat down and went through the detail of the layout 15 of the critical structures at Indian Point, while blasts 16 can be an issue of concern, my less-than-informed 17 opinion at this stage given the limited information that 18 can be made public is that while blasts can damage 19 structures and actually cause some building failures, 20 I don't think it will necessarily -- it won't interfere 21 with the reactors structures. They're pretty 22 hardcore.

23 So you'll get multiple blast explosions, 24 but that's not the controlling factor. The controlling 25 factor is the tremendous heat flux and the duration of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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28 1 that heat flux. I have seen the heat fluxes so high that 2 they will liquify steel at a distance and vaporize 3 aluminum. And I'm not saying that to scare anybody. I 4 just want everybody to understand if that occurs, what's 5 that do to the equipment that could be used to fail-safe 6 the plant? If it can't affect the plant and the plants 7 can still be fail-safed, then even in a tremendous 8 tragedy such as a rupture the plant is protected. And 9 then I'd have to say I don't like rupture, but I can tell 10 you that the plant would be protected. But I can't say 11 that. I can't come to that conclusion from what I've 12 seen to date.

13 DR. GAVIN: Well, I'm just trying to get a 14 better understanding of the difference between the 15 valves closing in three minutes versus three hours.

16 And it sounds like the heat flux is the limiting factor.

17 MR. KUPREWICZ: Well, I think that --

18 Well, no, no. Let me be real clear here: There's more 19 than just the time to close the valves. You have to 20 recognize that while you have a rupture; and it won't 21 be pressure drop, okay, the dynamics of where this pipe 22 is located in proximity to the compressor station you 23 would most likely not see pressure drop. So you won't 24 see pressure drop alarms for quite a while in the control 25 room that may be 1,000 miles away. And that's not the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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29 1 control room operator's fault. Okay?

2 The dynamics, the way the rupture will 3 work, the way a pipeline ruptures, it unzips in a 4 microsecond. It totally casts out pipe steel in all 5 directions and forms these huge craters and then the gas 6 roars at the speed of sound coming out of the pipe and 7 the gas, the speed of the sound and the gas, which is 8 higher than the velocity of the speed of sound and air.

9 That's why you hear these roars and nobody can figure 10 out what it is.

11 So my point is that if you had a rupture, 12 it's going to be awhile before somebody in a control room 13 gets the word that you might have a rupture. And that's 14 going to be more than probability. If you ran the 15 transient dynamics and you were trying to figure this 16 out, you were trying to estimate how much time would it 17 take before we'd understand we had a rupture and gave 18 the command to close valves, it may be many, many 19 minutes.

20 Mr. Pickett: Okay. Thank you.

21 MR. BLANCH: Yes, and this is Paul 22 following up. We do have other structures. We have 23 the gas turbine fuel oil tanks that are located in a very 24 close proximity which hold hundreds, maybe millions of 25 gallons of jet fuel oil which would flow downhill. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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30 1 have other vital structures. We have the switchyard.

2 We have transformers. We have vital tanks that are used 3 for cooling which are in the high-heat flux and blast 4 radius.

5 We also have information that the flow in 6 the existing lines, the 26 and 36-inch lines, may in fact 7 be changed through this modification. We do not know 8 if this has been addressed.

9 MR. KUPREWICZ: Yes, and that's a good 10 point. And I didn't mention this, but Paul has brought 11 up a good point. If that jet fuel tank is part of your 12 fail-safe system, and if I understand it's within 150 13 feet of this pipeline, blast radius will take the tank 14 out. Okay?

15 Now, if you don't need it to fail-safe the 16 plant, it'll burn, it may even explode, but it won't 17 necessarily -- if you don't need it to fail-safe the 18 plant, then from my perspective I don't like it, but it's 19 not going to jeopardize the plant.

20 MR. BLANCH: Well, it will burn -- it will 21 be hundreds of thousands of gallons of burning fuel 22 flowing down into safe-related structures.

23 MR. KUPREWICZ: Okay. If you know the 24 detail, because I don't --

25 (Simultaneous speaking)

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31 1 MR. BLANCH: That's why I --

2 (Simultaneous speaking) 3 MR. KUPREWICZ: -- the risk analysis would 4 look at.

5 MR. BLANCH: That's why I sent you the plan 6 view of a site showing elevations and distances. And 7 you can see it flows right down near safety-related 8 structures, which we all know what they are. The 9 switchyard will be taken out. There are other vital 10 components that will be taken out.

11 The bottom line here is that none of us know 12 everything about this. I certainly don't. Richard 13 will admit he doesn't know everything about nuclear 14 safety, and we all have our shortcomings. And we 15 desperately need to have the ability to review this 16 analysis and FERC has a procedure for allowing it called 17 CEII, which I don't know what means, but we can sign 18 confidentiality agreements for the very purpose that 19 you said we can't have it.

20 I have security clearance. I have worked 21 at Indian Point and other plants. Richard has security 22 clearance. Any other experts that we decide to bring 23 on would have the security clearance to review the 24 analysis and make sure it's complete and considered 25 everything.

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32 1 We have significant safety issues, and 2 we're not talking like in Connecticut where it killed 3 seven people. We are talking tens of millions of people 4 that could be endangered by releases from Indian Point.

5 And we cannot take this lightly.

6 We cannot believe for instance the 7 three-minute closure time, the fact that vital 8 structures will not be jeopardized. Flow in the 9 existing lines, which you said before in the final 10 safety analysis report that the rupture of those lines 11 is not feasible, yet it is feasible in the new lines.

12 I mean, either you're telling me the truth now or 13 something is amiss here. We have a probability of zero 14 for one line and a finite probability for another.

15 We absolutely need an independent 16 assessment of the analysis, and that is what we're 17 questioning. And I think that we need to pursue this, 18 that the NRC has to check with its management for an 19 independent review, whether we do it in cooperation with 20 Spectra, Entergy, NRC. That's fine with us. We'd love 21 to hear all inputs. But it's an absolute necessity that 22 further review be done by the experts in these various 23 disciplines, especially Richard, and including myself, 24 who has knowledge of Indian Point Nuclear Power, 25 knowledge of the regulations, knowledge of the risks.

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33 1 I have met with the chairman's office on 2 issues similar to this where the chairman at the time 3 allowed me to meet and shared with me information that 4 is not necessarily publicly available. That is what we 5 are asking in addition to the requests of the 2.206 6 petitions.

7 Again, I think that's pretty much what I 8 want to say, and I would like to hear from Congresswoman 9 Lowey's office by way of Dana Levenberg and hear some 10 of her statements, if she is ready to make some 11 statements. Dana?

12 MS. LEVENBERG: Sorry, I was on mute. Hi, 13 I'm sorry. Just to clarify, Dana Levenberg, 14 L-E-V-E-N-B-E-R-G, and I'm from New York State 15 Assemblywoman Sandy Galef's office, so a state 16 representative, not a congressional representative.

17 I just wanted to reiterate the 18 assemblywoman has as recently as January 15th submitted 19 a letter to the Secretary of FERC, as well as the 20 chairman of the NRC underscoring her extreme concern 21 that this independent risk assessment that was done both 22 by Entergy and -- I mean, that the assessment that was 23 done both by Entergy and NRC has experts like Rick and 24 Paul overseeing it, looking at it, reviewing it, or even 25 conducting their own analysis with the relevant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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34 1 pertinent information that has been provided. And 2 again, Paul laid out some possibilities. I'm not sure 3 what the one that would be best for NRC is. She's 4 extremely concerned that the issues that have been 5 brought forth by these two experts preclude the safe 6 siting of a larger pipeline so close to Indian Point.

7 She also wanted to make sure that as she 8 understands it there's no precedent for this type of 9 proximity and this size of gas line to be so close to 10 a nuclear power plant. And this is the most critical 11 nuclear power plant in our nation, one that has the NRC's 12 -- maybe the most eyes on this plant, more so than maybe 13 any other because its proximity to New York City.

14 And the radius of the impact of a blast and 15 additionally the heat that would create these other 16 issues that Mr. Kuprewicz has pointed out, based on the 17 fact that this three-minute assumption that was used and 18 that was articulated by the NRC expert on a phone call 19 that the assemblywoman organized with some 20 congressional offices, is sort of the most important 21 issue that has come up, in her opinion, that precludes 22 this from actually making any sense for this pipeline 23 to be sited so close to Indian Point.

24 It is really a great and dire concern for 25 her and for the safety and well-being of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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35 1 constituents she represents in the 95th Assembly 2 District, which includes Montrose, Buchanan, the Town 3 of Cortlandt, Croton, Peekskill and many of the other 4 areas that would be directly impacted by any sort of 5 rupture or an issue with the gas line that would impact 6 Indian Point. So she really wants to make sure that 7 some sort of analysis, an independent assessment of the 8 analysis with cooperation of these types of experts be 9 undertaken and either looking at again -- once again 10 either looking at what's already been done with these 11 experts or starting from scratch and undertaking 12 something that's truly independent. That's 13 it.

14 MR. KUPREWICZ: I might just want to 15 interject here a process risk analysis doesn't take like 16 man months, so that's just the basic --

17 (Simultaneous speaking) 18 PARTICIPANT: Sir, could you state your 19 name?

20 MR. KUPREWICZ: -- probably thinks this 21 is --

22 MS. LEVENBERG: I don't know what that 23 means.

24 MR. KUPREWICZ: It's something that you 25 get the right players in a room and they're cooperative NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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36 1 and open. Then you can get there fairly quickly. It 2 doesn't take weeks. It doesn't even take a day if you 3 really get the right people together.

4 MS. LEVENBERG: I'm sorry. Who's 5 speaking?

6 MR. KUPREWICZ: Nor am I advocating that it 7 has to be me. I'm not --

8 MS. LEVENBERG: Oh, is this Rick? Is this 9 Rick? I didn't know who was speaking. Okay.

10 MR. KUPREWICZ: Oh, I'm sorry. I don't --

11 MS. LEVENBERG: It's Rick.

12 MR. KUPREWICZ: -- the problem with cell 13 phones.

14 MS. LEVENBERG: Yes.

15 MR. KUPREWICZ: This is Rick Kuprewicz.

16 MS. LEVENBERG: Okay.

17 MR. KUPREWICZ: So, the right players in a 18 room, including the Government folks, if they want to 19 be there, you get the right questions addressed with the 20 right information and then that hazard analysis or 21 something like that can go very quickly. Again though, 22 we know that some of this will be hypersensitive, and 23 so everybody has to respect that, too. Anyway --

24 (Simultaneous speaking) 25 MR. BLANCH: And I think it's safe to say NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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37 1 -- this is Paul Blanch -- safe to say that, speaking for 2 myself, we would more than be willing to involve the 3 experts from the NRC, the experts from Spectra and from 4 Entergy such that we could hear all sides.

5 MR. KUPREWICZ: Fair call.

6 MS. GLIDDEN: This is Susanna Glidden.

7 Congresswoman Lowey's aid is ready to say something, 8 too.

9 MS. LEVINE: Well, actually, thank you, 10 but this is Sara from Congresswoman's Lowey's office, 11 Sara Levine, L-E-V-I-N-E. I am unfortunately not 12 making a statement today. I'm here just to listen and 13 observe. But thank you.

14 MS. GLIDDEN: Well, thank you, Sara.

15 MR. BLANCH: Dave Lochbaum, do you have any 16 comments?

17 (No audible response) 18 MR. BLANCH: I guess not.

19 CHAIRMAN MILLER: Thank you, Paul. Is 20 there any other information you want to pass before I 21 ask the Panel and those listening in if they have any 22 questions?

23 MR. BLANCH: Yes, there's one other 24 statement that I want to make. Again, my petition is 25 alleging wrongdoing on behalf of Entergy in submitting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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38 1 inaccurate incomplete information, and it appears to me 2 the NRC has already made a determination in its 3 inspection report that this information is accurate.

4 And how can we be assured of an independent assessment 5 of this petition if it's the same chain of command that 6 has already approved and said this information is 7 accurate? That's an outstanding question and I'm not 8 sure how we can get true independence. And according 9 to Management Directive 8.11; and I know there was 10 someone from the Office of Investigation, if there is 11 an allegation of wrongdoing, which there is, the Office 12 of Investigations has to be heavily involved with this 13 assessment of the 2.206 petition.

14 CHAIRMAN MILLER: So, Paul, this is Chris 15 Miller, and I just wanted to give you my short discussion 16 of one of the things that the Panel is going to consider 17 is if there's any allegations that we need to look at 18 and move forward, if we move forward with any 19 allegations from the material provided, the Office of 20 Investigations will be a part of that, will be in on 21 those discussions. That's how we do it in our normal 22 allegation process. So the 2.206 Board will actually 23 look and see if there are any new allegations that come 24 up as a result of this.

25 MR. BLANCH: And I personally am not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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39 1 advocating the treatment of this 2.206 as an allegation.

2 CHAIRMAN MILLER: Okay. Thank you.

3 Anything else that you want to provide to the Board 4 before we go around for questions?

5 MR. BLANCH: I think again I'd like to 6 reemphasize the possibility of an independent analysis 7 which would include the parties that I mentioned before 8 and some process where we could sign some type of 9 confidentiality agreement to have access to the 10 information that the NRC has restricted.

11 And the other question I have is for this 12 three-minute isolation time. In the response to my 13 FOIA request the references were not redacted, however, 14 there was no reference to how this three-minute time was 15 come up with, and I would like to see the reference for 16 how the NRC determined that the three-minute time is 17 sufficient.

18 CHAIRMAN MILLER: Okay. I've got that 19 note. Let me ask around the table here at headquarters 20 first. Is there anyone that has questions for Mr.

21 Blanch or any of the presenters?

22 (No audible response) 23 CHAIRMAN MILLER: Seeing none, anybody 24 from the regions?

25 MR. SETZER: Thank you, no, Chris.

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40 1 CHAIRMAN MILLER: Okay. Anyone from 2 members of the public that have questions for Mr.

3 Kuprewicz or Mr. Blanch or the presenters?

4 MS. VAN DOLSEN: This is Susan Van Dolsen.

5 I'm a member of the public. I just was wondering about 6 the precedent. There was evidently some sort of 7 independent risk assessment done for the Vermont Yankee 8 plant in 2008. And so there was something 9 commissioned. I think it was through the State of 10 Vermont. Would it require like someone at the state 11 level to do this, or is this something -- I just was 12 curious as how to proceed forward if you were not willing 13 to do it, if there's another way we could try to go 14 forward.

15 MR. PICKETT: Can you help us out? Are you 16 talking about a natural gas pipeline at Vermont Yankee 17 or something --

18 MS. VAN DOLSEN: No, an assessment. Just 19 an independent assessment. There was a team put 20 together. So there's a precedent for putting together 21 an assessment.

22 MR. BLANCH: I think it was called the CVA, 23 and it's some vertical assessment that was done at 24 Vermont Yankee. And there was also one done at Indian 25 Point at the request of Senator Clinton and other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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41 1 Congressional reps, again back in the same time frame, 2 2008-2010. So this request for an independent 3 assessment is not without precedence.

4 MS. VAN DOLSEN: And have any been done 5 near a gas pipeline? So, that's another question. I 6 see this one, but I don't know if there has been an 7 assessment independently done to do a risk assessment 8 near a natural gas pipeline.

9 MR. BLANCH: The only one I could think is 10 the one that was conducted by AREVA in Eunice, New Mexico 11 maybe five, six years ago for a 16-inch line operating 12 at 50 pounds. I have a copy of that assessment that was 13 done.

14 MS. VAN DOLSEN: And how many nuclear 15 plants operate near a gas pipeline in the proximity of 16 the one that we're talking about in this case?

17 MR. BLANCH: Well, the closest one, even 18 closer than Indian Point, is Turkey Point, which has 19 never been analyzed.

20 CHAIRMAN MILLER: So I'm going to try to 21 turn our direction back towards what we're trying to do 22 in this call -- is to try to get any additional 23 information for the Panel to consider in their 24 deliberations. So I would ask is there any other 25 questions that we want to ask of those who presented that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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42 1 the Panel should consider for this issue?

2 MS. LEVENBERG: I'm sorry. This is Dana 3 again from Assemblywoman Sandy Galef's office, and I 4 just wanted to point out that we had received a response 5 from the NRC related to the technical basis behind the 6 assumptions that valves will close an isolated gas leak 7 within three minutes, and that came directly from 8 Resource Report 11, Reliability and Safety, filed with 9 FERC by Algonquin in February of 2014 related to the AIM 10 project. And it was Section 11.4.3.2. And it was 11 specifically again from Algonquin. That was where it 12 came from. And it was specifically about the pressure 13 drops that would be noted from the remote -- the gas 14 control center in Houston, Texas. And again, that was 15 provided to me by the NRR office, by Doug Tifft at the 16 NRC.

17 So again, I think that we continue to have 18 concern based on Mr. Kuprewicz' review of this 19 three-minute assumption that is so critical because it 20 came from Algonquin, or Spectra, I guess.

21 MR. BLANCH: And that three-minute 22 assumption is what they are basing this safety of Indian 23 Point upon.

24 MS. LEVENBERG: Right.

25 MR. KUPREWICZ: Yes, this Rick Kuprewicz.

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43 1 And it kind of gets down to -- if I recall -- again, I 2 look at a lot of gas pipelines, but even if you close 3 the valve in three minutes, which you will not, because 4 a transient study for rupture in this particular 5 location will clearly indicate that that's not the case 6 -- even if you were to close those valves, it is still 7 going to burn for many minutes at high heat flux, because 8 that's what the laws of science, the laws of 9 thermodynamics will dictate. If I recall, the valve 10 spacings are 15 miles. If you have 15 miles of 11 high-pressure gas pipeline, it's not going to go to zero 12 pressure. It's going to burn for a long time at high 13 heat flux.

14 So, if I were to comment on this, what the 15 NRC has to think about is what is the actual -- the 16 transient dynamics of a pipeline rupture in this 17 location approximately three miles away from a 18 compressor station and how long will this burn at heat 19 fluxes that can affect equipment? End of subject.

20 It isn't I can close the valves in three 21 minutes. It might be 20 minutes before you recognize 22 that. So, that's the fundamental issue that you folks 23 have to see if someone has done that.

24 MR. PICKETT: This is Doug Pickett again.

25 When you first started your presentation I thought I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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44 1 heard you say something like the fellow who's going to 2 be in Houston monitoring the pressure would not see a 3 pressure drop if a pipe ruptured, and I was a little 4 confused on that. Can you go into that again? What 5 would he see?

6 MR. KUPREWICZ: Yes, most likely he's in 7 the control room getting all kinds of alarms. If you've 8 ever -- well, you guys have NRC control rooms, but 9 pipelines get a lot more alarms. And so he's got to 10 figure out how he's monitoring this and checking on 11 this, and he may get an alarm. He may say, hey, 12 something has changed, but I don't know what it is. But 13 for a rupture release in which you've blown these pipes, 14 the 42-inch pipe is going to shrapnel and come out of 15 the line, out of the ground. Big crater. Huge gas 16 velocities.

17 But the laws of thermodynamics dictate the 18 rate at which the gas can be released out the full-bore 19 ruptures from both ends. Okay? And that's limited to 20 the speed of sound of the gas, the speed of the sound 21 of the gas within the gas. Not in air. So it's 22 roaring. But it limits the mass rate. It limits how 23 much it releases.

24 So bottom line is in layman's terms the 25 pressures don't drop as fast as you'd think. It's not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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45 1 a balloon burst.

2 MR. PICKETT: Okay.

3 MR. KUPREWICZ: And if you close the valves 4 and they're 15 miles apart, there are plenty of 5 documents in the public domain that will show you it 6 takes many, many minutes before the flames really start 7 to decline. And so the real issue here is if you get 8 a gas pipeline rupture, how long will this burn at heat 9 fluxes that can affect equipment that is important? If 10 the answer is there's no equipment there, then that's 11 fine. Move on. But from what I'm seeing, that's not 12 necessarily the case.

13 MR. BLANCH: And adding to that, NRC 14 regulations dictates that we have to assume a single 15 failure at the valve --

16 (Simultaneous speaking) 17 MR. KUPREWICZ: Yes, let me also point out 18 to the NRC, don't feel like anybody's criticizing you 19 folks because you don't understand this stuff. There 20 are gas pipeline operators that we have to sit in a room 21 and great detail and explain this. And they're closer 22 to this and they don't get it until someone shows it to 23 them. So don't think like I'm saying, oh, you missed 24 this and it's your fault. That's not what I'm doing 25 here. Please.

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46 1 CHAIRMAN MILLER: Thank you. I wanted to 2 ask is there anyone from the Licensee that would like 3 to ask any questions of the presenters?

4 MR. WALPOLE: No, thank you, Chris.

5 CHAIRMAN MILLER: Okay. Any other 6 questions, concerns? Did I go to the regions?

7 Anything from the region?

8 (No audible response) 9 CHAIRMAN MILLER: Okay. Good. Well, I 10 --

11 MR. BLANCH: And how long can we expect to 12 have to wait for a transcript of this session?

13 MR. PICKETT: Doug Pickett here again.

14 We've requested the transcript to be within a week, so 15 then we have to review the transcript and make sure it's 16 accurate. And hopefully within a few weeks you'll be 17 able to see the transcript.

18 MR. BLANCH: Okay.

19 CHAIRMAN MILLER: Okay. Do you another 20 question, Mr. Blanch?

21 MR. BLANCH: No, that's all I have.

22 CHAIRMAN MILLER: Okay. Well, I wanted to 23 thank you and Mr. Kuprewicz. Good informative session.

24 I got a lot of information covered. So thanks for 25 taking your time. We'll continue with our process.

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47 1 Before we close, does the court reporter 2 need anything additional before we close the meeting, 3 close the transcript?

4 COURT REPORTER: Yes. Mr. Kuprewicz, 5 could you spell your last name for me?

6 MR. KUPREWICZ: Gee, I've never been asked 7 that before.

8 MR. BLANCH: Yes. Right.

9 MR. KUPREWICZ: It's K-U-P-R-E-W-I, C as 10 in cat, Z as in zebra.

11 COURT REPORTER: Got it. That's all.

12 (Whereupon, the above-entitled matter went 13 off the record at 3:34 p.m.)

14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

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NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433