ML15044A459
| 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 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 10 CFR 2.206 PETITION REVIEW BOARD (PRB) 4 CONFERENCE CALL 5
RE 6
INDIAN POINT 7
+ + + + +
8 WEDNESDAY 9
JANUARY 28, 2015 10
+ + + + +
11 The conference call was held, Christopher 12 Miller, Chairperson of the Petition Review Board, 13 presiding.
14 15 PETITIONER: PAUL BLANCH 16 17 PETITION REVIEW BOARD MEMBERS 18 Christopher Miller, Chairperson 19 Lee Banic 20 Thomas Setzer 21 Rob Carpenter 22 Dave Beaulieu 23 Dave Cylkowski 24 Ben Beasley 25
2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 PETITION REVIEW BOARD MEMBERS (Continued) 1 Paul Prescott 2
Tahirih Solomon 3
Rao Tammara 4
Mike McCoppin 5
Diane Render 8
Sergiu Basturescu 9
Doug Tifft 10 Stella Opara 11 Doug Pickett 12 Gladys Figueroa 13 Neil Sheehan 14 Sergiu Basturescu 15 Paul Prescott 16 17 18 19 20 21 22 23 24 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 1
T-A-B-L-E O-F C-O-N-T-E-N-T-S 2
Opening Remarks 3
Doug Pickett......................................4 4
Introductions......................................5 5
Chairman's Remarks 6
Christopher Miller...............................10 7
Presentation by Petitioner 8
Paul Blanch......................................17 9
Richard Kuprewicz................................19 10 Statement from New York Assemblywoman Galef's Office 11 Dana Levenberg...................................34 12 Questions for the Presenters 13 Susan Van Dolsen.................................40 14 15 16 17 18 19 20 21 22 23 24 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 1
P-R-O-C-E-E-D-I-N-G-S 2
MR. PICKETT: Good afternoon. Again, my 3
name is Doug Pickett. I'm the Indian Point project 4
manager in NRR in Rockville, Maryland. We're here 5
today to allow the Petitioner, Mr. Paul Blanch, assisted 6
by Mr. Richard Kuprewicz of Accufacts, Incorporated, to 7
address the Petition Review Board, also referred to as 8
the PRB, regarding the 2.206 petition submitted by Mr.
9 Blanch on October the 15th, 2014. I am the petition 10 manager for the petition and the PRB Chairman is Mr.
12 As part of the PRB's review of this petition 13 Mr. Paul Blanch has requested this opportunity to 14 address the PRB. This meeting is scheduled from 2:30 15 to 3:30 this afternoon.
16 The meeting is being recorded by the NRC 17 Operations Center and will be transcribed by a court 18 reporter. The transcript will become a supplement to 19 the petition. The transcripts will also be made 20 publicly available.
21 I'd like to open this meeting with 22 introductions. As we go around the room here in 23 Rockville, Maryland, please be sure to clearly state 24 your name, your position and the office that you work 25
5 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 for within the NRC. We're going to start introductions 1
with myself here in Rockville, Maryland.
2 I'm Doug Pickett, the petition manager.
3 CHAIRMAN MILLER: And I'm Chris Miller.
4 I'm with the Division of License Renewal in the Office 5
of Nuclear Reactor Regulation, and I'll be the PRB 6
Chair.
7 MS. RENDER: I'm Diane Render from the 8
Division of Operating Reactor Licensing, project 9
manager.
10 MR. McCOPPIN: Mike McCoppin. I'm Chief 11 of the Radiation Protection and Accident Consequences 12 Branch, Office of New Reactors.
13 MR. TAMMARA: My name is Rao Tammara. I'm 14 the technical reviewer, NRO.
15 MR. COLYER: Eddie Colyer, project 16 manager, Health Quality and Rulemaking.
17 MS. Banic: Lee Banic, NRR petition 18 coordinator.
19 MR. BLANCH: Yes, could people speak up a 20 little bit? I'm having trouble hearing.
21 PARTICIPANT: Can't hear.
22 MR. CYLKOWSKI: David Cylkowski. I'm an 23 attorney in the Office of General Counsel.
24 MS. SOLOMON: Tahririh Solomon, the senior 25
6 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 special agent with the Office of Investigations.
1 MR. CARPENTER: Rob Carpenter, Office of 2
Enforcement, enforcement specialist.
3 MR. BEASLEY: Ben Beasley. I'm a branch 4
chief in the Division of Operating Reactor Licensing.
5 MS. WILLIS: Dori Willis. I'm the team 6
lead for Allegations and Enforcement in NRR.
7 MR. Harris: Brian Harris, project 8
manager, DPR.
9 MR. OBERSON: Greg Oberson, materials 10 engineer, Office of Nuclear Regulatory Research.
11 MS. SPIRA: Mattie Spira, Office of 12 Enforcement.
13 MS. OPARA: Stella Opara, NRR, allegations 14 specialist.
15 MR. PICKETT: We have completed the 16 introductions in the NRC headquarters. You can tell 17 we've got quite a few people in a lot of areas of 18 expertise being represented.
19 At this time we'd like to know is there 20 anybody else from NRC headquarters on the phone?
21 MR. PRESCOTT: Yes, Paul Prescott from the 22 Office of NRO, Quality and Vendor Inspection Branch.
23 MR. BASTURESCU: Sergiu Basturescu, NRR, 24 Technical Review.
25
7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. PICKETT: Okay. Anyone else from NRC 1
headquarters?
2 (No audible response) 3 MR. PICKETT: And is there anyone from NRC 4
from the regional office on the phone?
5 MR. SHEEHAN: Neal Sheehan, Office of --
6 (Simultaneous speaking) 7 MR. PICKETT: I'm sorry, we heard Neal 8
Sheehan and who else?
9 MR. BURRITT: Art Burritt.
10 MR. PICKETT: Okay.
11 MR. SETZER: Doug, Tom Setzer, Region I.
12 MR. PICKETT: Okay. And the Licensee, 13 Entergy, could you please introduce who you have on the 14 phone?
15 MR. WALPOLE: Sure, Doug. It's Bob 16 Walpole, Manager; Steve Prussman from Regulatory 17 Assurance; and Rich Drake, our civil engineering 18 supervisor.
19 MR. PICKETT: Okay. Mr. Blanch, Mr.
20 Kuprewicz, would you please introduce yourselves along 21 with anyone else that's with you for the record?
22 MR. BLANCH: Yes, this is Paul Blanch.
23 I'm an energy consultant and the Petitioner. I'd like 24 to introduce Rick Kuprewicz, who will be also making a 25
8 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 statement. I'd like to thank Jerry Shapiro of Senator 1
Gillibrand's office; Dana Levenberg, who will also be 2
making a brief statement; and Sara Levine of 3
Assemblywoman Lowey's office. And I'd like to say hi 4
to old friends Bob Walpole and Paul from Morgan Lewis.
5 MR. PICKETT: Okay. It's not required for 6
members of the public to introduce themselves for this 7
call, however, if there are members of the public; and 8
I understand there are, could you please identify 9
yourself at this time?
10 MS. CLAIRE: Paula Claire, Garrison, New 11 York.
12 MS. GLIDDEN: Susanna Glidden, North 13 Salem, New York.
14 MS.
ROSEMARY:
Emily
- Rosemary, 15 councilwoman, Town of North Salem.
16 MS. McDONALD: Susan McDonald, New York.
17 MS. VAN DOLSEN: Susan Van Dolsen, 18 Harrison, New York.
19 MR. PICKETT: Could we do those again, the 20 last two. Susan McDonald I heard and --
21 MS. VAN DOLSEN: Susan Van Dolsen, 22 Harrison, New York.
23 MR. PICKETT: Thank you.
24 MS. VANN: Nancy Vann, Peekskill, New 25
9 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 York.
1 MR.
HOUSTON:
William
- Houston, 2
Binghamton, New York.
3 MR. BESSETTE: Paul Bessette, Morgan 4
Lewis.
5 MS. WISER: Ellen Wiser, White Plains, New 6
York.
7 MS. SPEAR: Susan Spear, Office of U.S.
8 Senator Kirsten Gillibrand.
9 MR. LOCHBAUM: Dave Lochbaum, Union of 10 Concerned Scientists.
11 MR. PICKETT: Okay.
12 MS. LEVENBERG: Dana Levenberg, New York 13 State Assemblywoman Sandy Galef's office.
14 MS. LEVINE: Sara Levine, Congresswoman 15 Nita Lowey's office.
16 MR. PICKETT: Okay. If there's no one 17 else, I'd like to emphasize that we each need to speak 18 clearly and loudly to make sure that the court reporter 19 can accurately transcribe this meeting. If you have 20 something to say, we'd like you to first state your name.
21 For those dialing into the meeting, please remember to 22 mute your phones to minimize any background noise or 23 distractions. If you do not have a mute button, you can 24 do this by pressing the star, six buttons. To un-mute, 25
10 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 press the star, six keys again.
1 At this time I'll turn this over to the PRB 2
Chairman, Chris Miller.
3 COURT REPORTER: Mr. Pickett, this is the 4
court reporter. Before you proceed with the call this 5
afternoon, at the conclusion of the call could you 6
provide me with a service list of the names of everyone 7
on the call? People that registered to speak and party 8
members.
9 MR. PICKETT: I can certainly give the 10 names of the NRC folks. I was hoping to rely on you to 11 get the names of everybody else.
12 COURT REPORTER: So do you have a list of 13 people who are registered to speak?
14 MR. PICKETT: This call is also being 15 recorded by the NRC Operation Center, so we can go back 16 over the recording.
17 COURT REPORTER: All right. Thank you.
18 MR. PICKETT: I'll help you out with that.
19 COURT REPORTER: Sure. Thanks.
20 MR. PICKETT: Okay.
21 CHAIRMAN MILLER: Thank you. And good 22 afternoon, everyone. Thanks for convening with us 23 today and agreeing to provide information. Thank you, 24 Mr. Blanch and Mr. Kuprewicz. I'm Chris Miller and I'm 25
11 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 looking forward to hearing the information you have to 1
provide for us.
2 I'd like to first share some background on 3
the process that we're using. Section 2.206 of Title 4
10 of the Code of Federal Regulations process is the 5
primary mechanism for the public to request enforcement 6
action by the NRC in a public process. This process 7
permits anyone to petition the NRC to take 8
enforcement-type action related to NRC licensees or 9
licensed activities. Depending on the results of its 10 evaluation, the NRC could modify, suspend or revoke an 11 NRC-issued license or take any other appropriate 12 enforcement action to resolve a problem. The staff 13 guidance for the disposition of this 2.206 petition 14 request is in Management Directive 8.11, which is 15 publicly available on our Web site.
16 Today's meeting's purpose is to give the 17 Petitioner, Mr. Blanch, an opportunity to provide any 18 additional explanation or support for the petition 19 before the Petition Review Board's initial 20 consideration and recommendation.
21 So we have the initial documents that you 22 sent, and I believe you supplemented with some 23 additional items, Mr. Blanch, today. They came to us 24 at the last minute and I don't know if everybody on the 25
12 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Board has gotten a chance to look at all of them, but 1
we do have them and we'll take them into consideration 2
when the Panel meets.
3 So, a couple of things. This meeting is 4
not a hearing. It's not an opportunity for the 5
Petitioner to question the NRC or the PRB about the 6
merits of the issues presented in the petition request.
7 It's really an opportunity for you to give us a fuller 8
picture, us, the members of the Board, a fuller picture 9
that we can work from in making our deliberations.
10 No decisions regarding the merits of this 11 petition will be made at this meeting.
12 Following the meeting the Petition Review 13 Board will conduct its internal deliberations and then 14 the outcome of the internal meeting will be discussed 15 with the Petitioner, Mr. Blanch.
16 The Petition Review Board typically 17 consists of a chairman, usually a manager at the senior 18 executive level who serves with the NRC. And you've 19 heard some of the other -- that's myself. And then a 20 petition manager, which is Doug, and a PRB coordinator.
21 Other members of the Board are determined by the NRC 22 staff based on the content of the information in the 23 petition request.
24 As described in our process, the staff may 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 ask clarifying questions in order to better understand 1
the Petitioner's presentation and reach a reasoned 2
decision whether to accept or reject the Petitioner's 3
request for review under the 2.206 process. And we'll 4
try to do that at the end of the call. We'll listen to 5
everything that you and your speakers have, Mr. Blanch, 6
and then we'll try to ask if there's any clarifying 7
questions or any additional information that we think 8
that members of the Board may need to ask of you.
9 With that being said, I want to summarize 10 the scope of the petition under consideration and the 11 NRC activities to date. On October 15th Mr. Blanch 12 submitted a 2.206 petition to the NRC regarding the 10 13 CFR 50.59 site hazards analysis prepared by Entergy 14 Nuclear Operations, the Licensee, for Indian Point 15 Nuclear Generating Stations 2 and 3.
16 The 50.59 analysis was performed by the 17 Licensee to determine the safety impact on the Indian 18 Point plant due to Spectra Energy's proposed 42-inch 19 diameter natural gas pipeline that has plans to traverse 20 a portion of the owner-controlled property at the Indian 21 Point facility.
22 In the petition Mr. Blanch requests that 23 the NRC take the following enforcement actions against 24 Entergy, the Licensee, for the following violations:
25
14 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Violation of 10 CFR 50.59, Completeness and Accuracy of 1
Information, for providing inaccurate and incomplete 2
information in the 50.59 site hazards analysis; 3
violation of 10 CFR 50, Appendix B, Quality Assurance 4
Criteria for Nuclear Plants and Fuel Reprocessing 5
Plants, for relying on a contractor who was not 6
qualified in accordance to Appendix B requirements, was 7
not qualified in accordance with Entergy Quality 8
Assurance Program, and, as a result, was not qualified 9
to perform an analysis for such significant 10 safety-related issue; and violation of 10 CFR 50.59, 11 Changes, Tests and Experiments, for failing to perform 12 the necessary safety evaluation requirements.
13 Furthermore, in the petition, Mr. Blanch 14 requested that the NRC issue a demand for information 15 against Entergy for the following: Demand an 16 explanation from Entergy seeking an explanation as to 17 why the previously identified violations do not also 18 constitute a violation of 10 CFR 50.5, Deliberate 19 Misconduct; demand that Entergy seek the results of a 20 new and realistic risk hazard analysis consistent with 21 the guidance providing in OSHA Appendix C, Section 22 1910.119, Compliance Guidelines and Recommendations 23 for Process Safety Management; and demand that Entergy 24 attest to the completeness and accuracy of Entergy 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Report IP-PRT-08-00032, prepared in August 2008 that 1
assessed the safety impact of the existing 26 and 2
30-inch diameter natural gas pipelines that traverse 3
the owner-controlled property in Indian Point.
4 That report was performed by the same 5
contractor that performed the current site hazards 6
analysis for Entergy. In addition, the report from 7
August 2008 contributed to NRC's rejection of a previous 8
2.206 petition submitted by Mr. Blanch concerning the 9
existing natural gas pipelines.
10 The Petitioner has also supplemented his 11 original petition with the following: The Town of 12 Cortlandt, New York contracted with Accufacts, 13 Incorporated to perform a review and analysis of the 14 proposed Spectra Energy natural gas pipeline and how it 15 may affect Cortlandt.
16 The Blanch petition is supplemented by the 17 Accufacts letter dated November 3rd, 2014 that is 18 critical of Entergy's 50.59 site hazards analysis and 19 characterizes it as seriously deficient, inadequate and 20 under-representing the real risks.
21 Point 2, the Petitioner letter dated 22 November 11th, 2014 discusses the proposed West Point 23 Partners' construction of a high voltage direct current 24 transmission cable that may run near or adjacent to the 25
16 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 proposed natural gas pipelines before tying into the 1
Buchanan Switchyard. This letter also supplements the 2
Blanch petition. The Petitioner has expressed concern 3
that stray DC currents emanating from the high voltage 4
cable could adversely impact the existing gas 5
pipelines, the new gas pipelines, and underground 6
safety-related components at the Indian Point facility.
7 And if I may discuss the NRC activities to 8
date, on November 24th, 2014 the petition manager 9
contacted the Petitioner to discuss the 2.206 process 10 and to offer the Petitioner an opportunity to address 11 the PRB by phone or in person. Petitioner requested to 12 address PRB by phone prior to its internal meeting to 13 make the initial recommendation to accept or reject the 14 petition for review.
15 As a reminder for the phone participants, 16 please identify yourself if you make any remarks as this 17 will help in the preparation of the meeting transcript 18 that will be made publicly available. And thank you.
19 Mr. Blanch, I'll turn to over to you and Mr.
20 Kuprewicz to provide any information you believe the PRB 21 should consider as part of this petition.
22 MR. BLANCH: Okay. This is Paul Blanch 23 speaking again. With your introduction, which I 24 appreciate, I'm sorry, that was Charles Miller is your 25
17 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 name?
1 CHAIRMAN MILLER: Chris Miller.
2 MR. BLANCH: Chris Miller?
3 CHAIRMAN MILLER: Yes.
4 MR. BLANCH: Okay. You stated obviously 5
that this is being conducted in accordance with 10 CFR 6
2.206 and guidance provided by Management Directive 7
8.11. And you made a statement that this is not an 8
opportunity for questions by the Petitioner. I'm not 9
sure where that statement originated. I've reviewed 10 Management Directive 8.11 and it's clear certainly that 11 the Licensee is allowed to ask questions and the NRC can 12 ask questions and it does not prohibit the Petitioner 13 from asking questions. Again, we don't have to get into 14 the details of the Management Directive.
15 But secondly, this meeting is somewhat a 16 follow up of a telephone conversation the NRC had in 17 early December with various congressional 18 representatives of the New York and Westchester area, 19 and during that meeting and confirmed by a Mr. Doug 20 Tifft, T-I-F-F-T, that Mr. Blanch would have an 21 opportunity with meetings with the NRC staff and those 22 meetings would include this conversation. So the 23 inference there was that I myself would be able to 24 address technical issues, and that's my primary 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 interest. And the reason for my interest is primarily 1
to decide whether I further want to amend my petition 2
or take any other subsequent action, including -- well, 3
whatever action I decide to take.
4 Again, I filed a Freedom of Information Act 5
request for various documents related to the analysis, 6
which has been totally redacted except for an 7
introduction and one single reference, that reference 8
being the submittal by Entergy of August 21st. We and 9
the experts are extremely interested because we suspect 10 there contains inaccurate information within the 11 analysis, and I'll get into that a little bit later.
12 And other federal agencies, and Richard can 13 expound on this. There's a process which I sent to you.
14 It's called CEII, which allows members of the public and 15 technical experts to sign an agreement to review various 16 documents that are proprietary, confidential or could 17 endanger the health and safety of the public, and so on 18 and so forth. We'd like the NRC to consider entering 19 into some type of agreement where our experts could 20 review the Entergy and the NRC analysis, because we 21 certainly believe that it contains questionable 22 information at first, at best.
23 Our main concern, and there are many 24 concerns; and Richard is probably the most qualified to 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 speak on that, but in the summary of the analysis 1
provided August 21st by Entergy there was an assumption 2
that the gas flow would be terminated within three 3
minutes of its initiation. And I don't mean detection, 4
but initiation. And based on historical experience and 5
research we certainly question that. And I'd like to 6
stick with that primary point and have Richard speak to 7
that, if that's okay.
8 Now, Richard, if you would like to speak on 9
that particular three-minute isolation time.
10 MR. KUPREWICZ: Sure. Maybe my preamble 11 is, because I haven't spoken up before, and if I'm not 12 getting clear, please speak up because it's hard over 13 the phone on conference.
14 Let me just give you a brief background 15 here. I won't spend a lot of time. I don't usually 16 waste a lot of time selling myself, but I've got over 17 40 years experience in the energy industry, especially 18 in incident investigations related to major pipeline 19 failures. I've spent many years trying to improve 20 pipeline safety regulations, especially after the 21 terrible pipeline ruptures in Bellingham in '99 and in 22 Carlsbad in 2001. That was a gas transmission line was 23 the latter one. And in Bellingham it was a liquid line.
24 Multiple loss of life, near loss of the city in 25
20 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Bellingham, and obviously a tragic loss of life in 1
Carlsbad, a very remote area. It killed 12 people, 5 2
of them children.
3 Anyway, I have assisted over many years in 4
the improvement of pipeline safety regulation, trying 5
to work with industry and various other parties, 6
regulators as well as the public, usually representing 7
the public as members on various committees. Many of 8
those served in the development of pipeline safety 9
regulation regarding integrity management, especially 10 for transmission pipelines. And also in the area that 11 may be very relevant to this particular subject, in the 12 area of pipeline control room management. And those 13 regulations have been promulgated and are now in 14 regulation. And as again in all regulation, there's 15 always a series of compromises, but hopefully you move 16 the ball forward.
17 And I spent over 40 years trying to improve 18 the area of control room management for not only 19 refineries and chemical plants, but also in pipelines.
20 I have very little tolerance for trying to blame the 21 pipeline control room operator for some of these 22 terrible incidents you've been seeing lately in the last 23 10 or 15 or so years.
24 On the issue that may be very relevant here, 25
21 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 you can get my CV. It's in the public domain. That 1
will cover most of my documents that are in public. The 2
investigations I've been brought into, that are 3
hypersensitive are not in public domain, may involve 4
criminal investigations, and I will not discuss any of 5
that stuff. And I can bring lots of attorneys in on both 6
sides of the fence that will try to protect that 7
neutrality.
8 I am also a very experience HAZOP team 9
leader, and I only mention that because a HAZOP team 10 leader used to carry under law under OSHA a requirement 11 that you had to be field experienced, operational 12 experience to lead the team. I don't know if that's in 13 the current regulations, but that doesn't mean a couple 14 years. So again, the experience requirement is there 15 to assure you're asking the right questions and then the 16 parties can reach a rational reasonable conclusion.
17 Now, let me focus in on the specific issue 18 of the claimed three-minute closure time for the valves.
19 I think the report that I've seen that's in public 20 indicates that they'll close the valves in three minutes 21 under the impression that that will actually stop the 22 gas burning, or the gas explosions, more likely 23 explosions than gas burning, within a three-minute time 24 period. And I'll just tell you that my extensive 25
22 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 experience in this area, you won't even necessarily 1
recognize this within three minutes, much less within 2
a control room many, many miles away, take the 3
appropriate actions to try to initiate actions to shut 4
down, close -- shut some compressors and close valves.
5 That can go for quite some time.
6 Now, in all fairness I need to point out in 7
the San Bruno pipeline rupture, a slightly different 8
animal, smaller line, lower pressure, not necessarily 9
remote-operated valves, but that burned for over 90 10 minutes. Okay? And in that particular location the 11 fire department was several hundred yards down the 12 street. Okay? So my point is in these terrible 13 tragedies -- nobody wants a pipeline rupture, but in 14 these large diameter pipeline ruptures all kinds of 15 dynamics and noise interfere so that what happens is a 16 guy in a control room may or may not get information in 17 a manner allowing him to make what I'll call executive 18 decisions to take the appropriate action to handle a gas 19 pipeline rupture. So time can go very quickly in a 20 control room.
21 And so in this particular case I would say 22 the illusion of a closure time in three minutes is -- it 23 may be after you push the buttons to do that, you may 24 be designed to do that, but the real relevant issue that 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 this Panel I think needs to consider is the actual 1
dynamics that in the event of a pipeline rupture in this 2
sensitive location,the system dynamics will 3
substantially delay the recognition and the appropriate 4
shutoff and responses such that gas will explode and 5
burn for quite a period of time. Right?
6 I need to just comment on one other issue 7
that's often confusing, and that is in federal pipeline 8
safety regulation there's an animal called the 9
potential impact radius that's used to decide what we 10 think might be the potential impact from a gas 11 transmission pipeline rupture. That animal was never, 12 ever intended -- and FERC knows this. I've said this 13 in enough cases under oath, that that was a screening 14 tool to help define high consequence areas. And I've 15 also said under oath in other cases that the PIR was 16 meant to help identify high consequence areas and should 17 not be used to cite the consequences of pipeline 18 ruptures.
19 As it turns out, the larger the diameter of 20 the pipeline, the potential impact radius moves in the 21 right direction, but the actual impact radius can be 22 much larger. And I have said to PHMSA on more than one 23 occasion, trying to go through a cycle to improve the 24 regulations for larger diameter pipelines, that became 25
24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 very evident -- that there was a problem in the federal 1
regulations that became very evident after the San Bruno 2
rupture. And even the NTSB acknowledges this, there's 3
something not quite right with this PIR equation for 4
larger diameter pipelines.
5 Now with that said, I think the fundamental 6
issue here from my perspective is if the pipeline were 7
to rupture either as a 30-inch or a 42-inch; because the 8
issues goes beyond just the 42-inch, would it generate 9
blast? And the answer probably is mostly likely, 10 though there are ruptures that don't generate blasts.
11 They're rare. When I say "blasts," I mean blasts from 12 the ignition of the gas cloud that is mixed with the 13 turbulent action. And most likely in a rupture you'll 14 get multiple blasts.
15 From what I have seen of the layout; and 16 again, I haven't seen a complete detail of the layout, 17 I don't expect blast forces because -- like major damage 18 to like the reactor buildings or anything, because 19 they're pretty reinforced, but the question would be 20 would possible blast generated cause damage to 21 structures that might be what I'd call safety-critical 22 that would interfere with the possibility of having the 23 fail-safe shutdown of the Reactors 2 and 3? And I don't 24 have an answer to that one. I'll be very frank with you.
25
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 I would tell you this: Blast forces tend 1
to dissipate. They're situation-specific. And from 2
what I've seen I would expect that there are blast 3
forces. While they will kill, they wouldn't 4
necessarily damage a lot of structure because they 5
dissipate quickly with distance. So the controlling 6
issue regarding this from my perspective and experience 7
is the tremendous amount of heat flux generated from 8
these high-tonnage release gas transmission pipeline 9
ruptures that have ignited.
10 And what happens is the higher the heat 11 flux, the longer the duration, the more damage that can 12 occur. I would expect extensive damage to auxiliary 13 equipment such as transmission pipelines and equipment 14 that might be related to fail-safe shutdown of the 15 reactor facilities themselves.
16 And that's where I brought the very simple 17 question in my report. In the event of a rupture of a 18 sustained duration; it's going to be longer than three 19 minutes given the transient dynamics on this system, 20 what equipment would be affected and would it interfere 21 with the fail-safe shutdown of the plant? I don't have 22 an answer for you on that. I can tell you the burns will 23 be substantially longer than three minutes with 24 significantly high heat fluxes.
25
26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 That's about it for me.
1 MR. BLANCH: Thank you very much, Richard.
2 Does anyone have any questions for what Richard just 3
said?
4 Mr. PICKETT: Excuse me. I just take it 5
-- I do have a question for Mr. Kuprewicz. And I am 6
no --
7 MR. KUPREWICZ: Who's speaking?
8 MR. PICKETT: Doug Pickett. I am no pipe 9
expert like you are, Mr. Kuprewicz, but in layman's 10 terms, and I think I probably represent a lot of the 11 people in the room here, when we think about a 42-inch 12 gas line breaking, we would imagine a major explosion, 13 but after that we would think this would be like 14 effectively a torch and it wouldn't matter whether the 15 valve closed in three minutes or three hours. Now am 16 I wrong in my thinking?
17 MR. KUPREWICZ: Well, first of all, 18 there's no dumb question, so please do not hesitate to 19 ask, if you can. If I'm not clear, then please ask.
20 I'm not here to give a speech.
21 That's a fair question you ask. The 22 tonnage release on these, especially these large 23 diameter pipelines are such that you can expect to see 24 multiple detonations, multiple blasts. The initial 25
27 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 blast will probably be the highest force one. And so 1
when you do site-specific blast pressure waves from the 2
tonnage release and time to ignition, usually the 3
initial blast ignition will have the greatest force.
4 But then what will happen, because the gas releases are 5
so great and the air cloud mixture is so turbulent, 6
you'll see multiple secondary blasts, but they won't be 7
as significant as the first one.
8 But those blast pressure waves will 9
-- again, the science will tell you they dissipate quite 10 quickly with distance. So if you're in a real congested 11 area, that will contribute to the blast forces. But 12 from what I've seen of the structure spacing, I think 13 if you sat down and went through the detail of the layout 14 of the critical structures at Indian Point, while blasts 15 can be an issue of concern, my less-than-informed 16 opinion at this stage given the limited information that 17 can be made public is that while blasts can damage 18 structures and actually cause some building failures, 19 I don't think it will necessarily -- it won't interfere 20 with the reactors structures. They're pretty 21 hardcore.
22 So you'll get multiple blast explosions, 23 but that's not the controlling factor. The controlling 24 factor is the tremendous heat flux and the duration of 25
28 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that heat flux. I have seen the heat fluxes so high that 1
they will liquify steel at a distance and vaporize 2
aluminum. And I'm not saying that to scare anybody. I 3
just want everybody to understand if that occurs, what's 4
that do to the equipment that could be used to fail-safe 5
the plant? If it can't affect the plant and the plants 6
can still be fail-safed, then even in a tremendous 7
tragedy such as a rupture the plant is protected. And 8
then I'd have to say I don't like rupture, but I can tell 9
you that the plant would be protected. But I can't say 10 that. I can't come to that conclusion from what I've 11 seen to date.
12 DR. GAVIN: Well, I'm just trying to get a 13 better understanding of the difference between the 14 valves closing in three minutes versus three hours.
15 And it sounds like the heat flux is the limiting factor.
16 MR. KUPREWICZ: Well, I think that --
17 Well, no, no. Let me be real clear here: There's more 18 than just the time to close the valves. You have to 19 recognize that while you have a rupture; and it won't 20 be pressure drop, okay, the dynamics of where this pipe 21 is located in proximity to the compressor station you 22 would most likely not see pressure drop. So you won't 23 see pressure drop alarms for quite a while in the control 24 room that may be 1,000 miles away. And that's not the 25
29 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 control room operator's fault. Okay?
1 The dynamics, the way the rupture will 2
work, the way a pipeline ruptures, it unzips in a 3
microsecond. It totally casts out pipe steel in all 4
directions and forms these huge craters and then the gas 5
roars at the speed of sound coming out of the pipe and 6
the gas, the speed of the sound and the gas, which is 7
higher than the velocity of the speed of sound and air.
8 That's why you hear these roars and nobody can figure 9
out what it is.
10 So my point is that if you had a rupture, 11 it's going to be awhile before somebody in a control room 12 gets the word that you might have a rupture. And that's 13 going to be more than probability. If you ran the 14 transient dynamics and you were trying to figure this 15 out, you were trying to estimate how much time would it 16 take before we'd understand we had a rupture and gave 17 the command to close valves, it may be many, many 18 minutes.
19 Mr. Pickett: Okay. Thank you.
20 MR. BLANCH: Yes, and this is Paul 21 following up. We do have other structures. We have 22 the gas turbine fuel oil tanks that are located in a very 23 close proximity which hold hundreds, maybe millions of 24 gallons of jet fuel oil which would flow downhill. We 25
30 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 have other vital structures. We have the switchyard.
1 We have transformers. We have vital tanks that are used 2
for cooling which are in the high-heat flux and blast 3
radius.
4 We also have information that the flow in 5
the existing lines, the 26 and 36-inch lines, may in fact 6
be changed through this modification. We do not know 7
if this has been addressed.
8 MR. KUPREWICZ: Yes, and that's a good 9
point. And I didn't mention this, but Paul has brought 10 up a good point. If that jet fuel tank is part of your 11 fail-safe system, and if I understand it's within 150 12 feet of this pipeline, blast radius will take the tank 13 out. Okay?
14 Now, if you don't need it to fail-safe the 15 plant, it'll burn, it may even explode, but it won't 16 necessarily -- if you don't need it to fail-safe the 17 plant, then from my perspective I don't like it, but it's 18 not going to jeopardize the plant.
19 MR. BLANCH: Well, it will burn -- it will 20 be hundreds of thousands of gallons of burning fuel 21 flowing down into safe-related structures.
22 MR. KUPREWICZ: Okay. If you know the 23 detail, because I don't --
24 (Simultaneous speaking) 25
31 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. BLANCH: That's why I --
1 (Simultaneous speaking) 2 MR. KUPREWICZ: -- the risk analysis would 3
look at.
4 MR. BLANCH: That's why I sent you the plan 5
view of a site showing elevations and distances. And 6
you can see it flows right down near safety-related 7
structures, which we all know what they are. The 8
switchyard will be taken out. There are other vital 9
components that will be taken out.
10 The bottom line here is that none of us know 11 everything about this. I certainly don't. Richard 12 will admit he doesn't know everything about nuclear 13 safety, and we all have our shortcomings. And we 14 desperately need to have the ability to review this 15 analysis and FERC has a procedure for allowing it called 16 CEII, which I don't know what means, but we can sign 17 confidentiality agreements for the very purpose that 18 you said we can't have it.
19 I have security clearance. I have worked 20 at Indian Point and other plants. Richard has security 21 clearance. Any other experts that we decide to bring 22 on would have the security clearance to review the 23 analysis and make sure it's complete and considered 24 everything.
25
32 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 We have significant safety issues, and 1
we're not talking like in Connecticut where it killed 2
seven people. We are talking tens of millions of people 3
that could be endangered by releases from Indian Point.
4 And we cannot take this lightly.
5 We cannot believe for instance the 6
three-minute closure time, the fact that vital 7
structures will not be jeopardized. Flow in the 8
existing lines, which you said before in the final 9
safety analysis report that the rupture of those lines 10 is not feasible, yet it is feasible in the new lines.
11 I mean, either you're telling me the truth now or 12 something is amiss here. We have a probability of zero 13 for one line and a finite probability for another.
14 We absolutely need an independent 15 assessment of the analysis, and that is what we're 16 questioning. And I think that we need to pursue this, 17 that the NRC has to check with its management for an 18 independent review, whether we do it in cooperation with 19 Spectra, Entergy, NRC. That's fine with us. We'd love 20 to hear all inputs. But it's an absolute necessity that 21 further review be done by the experts in these various 22 disciplines, especially Richard, and including myself, 23 who has knowledge of Indian Point Nuclear Power, 24 knowledge of the regulations, knowledge of the risks.
25
33 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 I have met with the chairman's office on 1
issues similar to this where the chairman at the time 2
allowed me to meet and shared with me information that 3
is not necessarily publicly available. That is what we 4
are asking in addition to the requests of the 2.206 5
petitions.
6 Again, I think that's pretty much what I 7
want to say, and I would like to hear from Congresswoman 8
Lowey's office by way of Dana Levenberg and hear some 9
of her statements, if she is ready to make some 10 statements. Dana?
11 MS. LEVENBERG: Sorry, I was on mute. Hi, 12 I'm sorry. Just to clarify, Dana Levenberg, 13 L-E-V-E-N-B-E-R-G, and I'm from New York State 14 Assemblywoman Sandy Galef's office, so a state 15 representative, not a congressional representative.
16 I
just wanted to reiterate the 17 assemblywoman has as recently as January 15th submitted 18 a letter to the Secretary of FERC, as well as the 19 chairman of the NRC underscoring her extreme concern 20 that this independent risk assessment that was done both 21 by Entergy and -- I mean, that the assessment that was 22 done both by Entergy and NRC has experts like Rick and 23 Paul overseeing it, looking at it, reviewing it, or even 24 conducting their own analysis with the relevant 25
34 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 pertinent information that has been provided. And 1
again, Paul laid out some possibilities. I'm not sure 2
what the one that would be best for NRC is. She's 3
extremely concerned that the issues that have been 4
brought forth by these two experts preclude the safe 5
siting of a larger pipeline so close to Indian Point.
6 She also wanted to make sure that as she 7
understands it there's no precedent for this type of 8
proximity and this size of gas line to be so close to 9
a nuclear power plant. And this is the most critical 10 nuclear power plant in our nation, one that has the NRC's 11
-- maybe the most eyes on this plant, more so than maybe 12 any other because its proximity to New York City.
13 And the radius of the impact of a blast and 14 additionally the heat that would create these other 15 issues that Mr. Kuprewicz has pointed out, based on the 16 fact that this three-minute assumption that was used and 17 that was articulated by the NRC expert on a phone call 18 that the assemblywoman organized with some 19 congressional offices, is sort of the most important 20 issue that has come up, in her opinion, that precludes 21 this from actually making any sense for this pipeline 22 to be sited so close to Indian Point.
23 It is really a great and dire concern for 24 her and for the safety and well-being of the 25
35 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 constituents she represents in the 95th Assembly 1
District, which includes Montrose, Buchanan, the Town 2
of Cortlandt, Croton, Peekskill and many of the other 3
areas that would be directly impacted by any sort of 4
rupture or an issue with the gas line that would impact 5
Indian Point. So she really wants to make sure that 6
some sort of analysis, an independent assessment of the 7
analysis with cooperation of these types of experts be 8
undertaken and either looking at again -- once again 9
either looking at what's already been done with these 10 experts or starting from scratch and undertaking 11 something that's truly independent. That's 12 it.
13 MR. KUPREWICZ: I might just want to 14 interject here a process risk analysis doesn't take like 15 man months, so that's just the basic --
16 (Simultaneous speaking) 17 PARTICIPANT: Sir, could you state your 18 name?
19 MR. KUPREWICZ: -- probably thinks this 20 is --
21 MS. LEVENBERG: I don't know what that 22 means.
23 MR. KUPREWICZ: It's something that you 24 get the right players in a room and they're cooperative 25
36 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and open. Then you can get there fairly quickly. It 1
doesn't take weeks. It doesn't even take a day if you 2
really get the right people together.
3 MS. LEVENBERG: I'm sorry. Who's 4
speaking?
5 MR. KUPREWICZ: Nor am I advocating that it 6
has to be me. I'm not --
7 MS. LEVENBERG: Oh, is this Rick? Is this 8
Rick? I didn't know who was speaking. Okay.
9 MR. KUPREWICZ: Oh, I'm sorry. I don't --
10 MS. LEVENBERG: It's Rick.
11 MR. KUPREWICZ: -- the problem with cell 12 phones.
13 MS. LEVENBERG: Yes.
14 MR. KUPREWICZ: This is Rick Kuprewicz.
15 MS. LEVENBERG: Okay.
16 MR. KUPREWICZ: So, the right players in a 17 room, including the Government folks, if they want to 18 be there, you get the right questions addressed with the 19 right information and then that hazard analysis or 20 something like that can go very quickly. Again though, 21 we know that some of this will be hypersensitive, and 22 so everybody has to respect that, too. Anyway --
23 (Simultaneous speaking) 24 MR. BLANCH: And I think it's safe to say 25
37 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
-- this is Paul Blanch -- safe to say that, speaking for 1
myself, we would more than be willing to involve the 2
experts from the NRC, the experts from Spectra and from 3
Entergy such that we could hear all sides.
4 MR. KUPREWICZ: Fair call.
5 MS. GLIDDEN: This is Susanna Glidden.
6 Congresswoman Lowey's aid is ready to say something, 7
too.
8 MS. LEVINE: Well, actually, thank you, 9
but this is Sara from Congresswoman's Lowey's office, 10 Sara Levine, L-E-V-I-N-E. I am unfortunately not 11 making a statement today. I'm here just to listen and 12 observe. But thank you.
13 MS. GLIDDEN: Well, thank you, Sara.
14 MR. BLANCH: Dave Lochbaum, do you have any 15 comments?
16 (No audible response) 17 MR. BLANCH: I guess not.
18 CHAIRMAN MILLER: Thank you, Paul. Is 19 there any other information you want to pass before I 20 ask the Panel and those listening in if they have any 21 questions?
22 MR. BLANCH: Yes, there's one other 23 statement that I want to make. Again, my petition is 24 alleging wrongdoing on behalf of Entergy in submitting 25
38 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 inaccurate incomplete information, and it appears to me 1
the NRC has already made a determination in its 2
inspection report that this information is accurate.
3 And how can we be assured of an independent assessment 4
of this petition if it's the same chain of command that 5
has already approved and said this information is 6
accurate? That's an outstanding question and I'm not 7
sure how we can get true independence. And according 8
to Management Directive 8.11; and I know there was 9
someone from the Office of Investigation, if there is 10 an allegation of wrongdoing, which there is, the Office 11 of Investigations has to be heavily involved with this 12 assessment of the 2.206 petition.
13 CHAIRMAN MILLER: So, Paul, this is Chris 14 Miller, and I just wanted to give you my short discussion 15 of one of the things that the Panel is going to consider 16 is if there's any allegations that we need to look at 17 and move forward, if we move forward with any 18 allegations from the material provided, the Office of 19 Investigations will be a part of that, will be in on 20 those discussions. That's how we do it in our normal 21 allegation process. So the 2.206 Board will actually 22 look and see if there are any new allegations that come 23 up as a result of this.
24 MR. BLANCH: And I personally am not 25
39 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 advocating the treatment of this 2.206 as an allegation.
1 CHAIRMAN MILLER: Okay. Thank you.
2 Anything else that you want to provide to the Board 3
before we go around for questions?
4 MR. BLANCH: I think again I'd like to 5
reemphasize the possibility of an independent analysis 6
which would include the parties that I mentioned before 7
and some process where we could sign some type of 8
confidentiality agreement to have access to the 9
information that the NRC has restricted.
10 And the other question I have is for this 11 three-minute isolation time. In the response to my 12 FOIA request the references were not redacted, however, 13 there was no reference to how this three-minute time was 14 come up with, and I would like to see the reference for 15 how the NRC determined that the three-minute time is 16 sufficient.
17 CHAIRMAN MILLER: Okay. I've got that 18 note. Let me ask around the table here at headquarters 19 first. Is there anyone that has questions for Mr.
20 Blanch or any of the presenters?
21 (No audible response) 22 CHAIRMAN MILLER: Seeing none, anybody 23 from the regions?
24 MR. SETZER: Thank you, no, Chris.
25
40 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 CHAIRMAN MILLER: Okay. Anyone from 1
members of the public that have questions for Mr.
2 Kuprewicz or Mr. Blanch or the presenters?
3 MS. VAN DOLSEN: This is Susan Van Dolsen.
4 I'm a member of the public. I just was wondering about 5
the precedent. There was evidently some sort of 6
independent risk assessment done for the Vermont Yankee 7
plant in 2008. And so there was something 8
commissioned. I think it was through the State of 9
Vermont. Would it require like someone at the state 10 level to do this, or is this something -- I just was 11 curious as how to proceed forward if you were not willing 12 to do it, if there's another way we could try to go 13 forward.
14 MR. PICKETT: Can you help us out? Are you 15 talking about a natural gas pipeline at Vermont Yankee 16 or something --
17 MS. VAN DOLSEN: No, an assessment. Just 18 an independent assessment. There was a team put 19 together. So there's a precedent for putting together 20 an assessment.
21 MR. BLANCH: I think it was called the CVA, 22 and it's some vertical assessment that was done at 23 Vermont Yankee. And there was also one done at Indian 24 Point at the request of Senator Clinton and other 25
41 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Congressional reps, again back in the same time frame, 1
2008-2010. So this request for an independent 2
assessment is not without precedence.
3 MS. VAN DOLSEN: And have any been done 4
near a gas pipeline? So, that's another question. I 5
see this one, but I don't know if there has been an 6
assessment independently done to do a risk assessment 7
near a natural gas pipeline.
8 MR. BLANCH: The only one I could think is 9
the one that was conducted by AREVA in Eunice, New Mexico 10 maybe five, six years ago for a 16-inch line operating 11 at 50 pounds. I have a copy of that assessment that was 12 done.
13 MS. VAN DOLSEN: And how many nuclear 14 plants operate near a gas pipeline in the proximity of 15 the one that we're talking about in this case?
16 MR. BLANCH: Well, the closest one, even 17 closer than Indian Point, is Turkey Point, which has 18 never been analyzed.
19 CHAIRMAN MILLER: So I'm going to try to 20 turn our direction back towards what we're trying to do 21 in this call -- is to try to get any additional 22 information for the Panel to consider in their 23 deliberations. So I would ask is there any other 24 questions that we want to ask of those who presented that 25
42 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the Panel should consider for this issue?
1 MS. LEVENBERG: I'm sorry. This is Dana 2
again from Assemblywoman Sandy Galef's office, and I 3
just wanted to point out that we had received a response 4
from the NRC related to the technical basis behind the 5
assumptions that valves will close an isolated gas leak 6
within three minutes, and that came directly from 7
Resource Report 11, Reliability and Safety, filed with 8
FERC by Algonquin in February of 2014 related to the AIM 9
project. And it was Section 11.4.3.2. And it was 10 specifically again from Algonquin. That was where it 11 came from. And it was specifically about the pressure 12 drops that would be noted from the remote -- the gas 13 control center in Houston, Texas. And again, that was 14 provided to me by the NRR office, by Doug Tifft at the 15 NRC.
16 So again, I think that we continue to have 17 concern based on Mr. Kuprewicz' review of this 18 three-minute assumption that is so critical because it 19 came from Algonquin, or Spectra, I guess.
20 MR. BLANCH: And that three-minute 21 assumption is what they are basing this safety of Indian 22 Point upon.
23 MS. LEVENBERG: Right.
24 MR. KUPREWICZ: Yes, this Rick Kuprewicz.
25
43 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And it kind of gets down to -- if I recall -- again, I 1
look at a lot of gas pipelines, but even if you close 2
the valve in three minutes, which you will not, because 3
a transient study for rupture in this particular 4
location will clearly indicate that that's not the case 5
-- even if you were to close those valves, it is still 6
going to burn for many minutes at high heat flux, because 7
that's what the laws of science, the laws of 8
thermodynamics will dictate. If I recall, the valve 9
spacings are 15 miles. If you have 15 miles of 10 high-pressure gas pipeline, it's not going to go to zero 11 pressure. It's going to burn for a long time at high 12 heat flux.
13 So, if I were to comment on this, what the 14 NRC has to think about is what is the actual -- the 15 transient dynamics of a pipeline rupture in this 16 location approximately three miles away from a 17 compressor station and how long will this burn at heat 18 fluxes that can affect equipment? End of subject.
19 It isn't I can close the valves in three 20 minutes. It might be 20 minutes before you recognize 21 that. So, that's the fundamental issue that you folks 22 have to see if someone has done that.
23 MR. PICKETT: This is Doug Pickett again.
24 When you first started your presentation I thought I 25
44 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 heard you say something like the fellow who's going to 1
be in Houston monitoring the pressure would not see a 2
pressure drop if a pipe ruptured, and I was a little 3
confused on that. Can you go into that again? What 4
would he see?
5 MR. KUPREWICZ: Yes, most likely he's in 6
the control room getting all kinds of alarms. If you've 7
ever -- well, you guys have NRC control rooms, but 8
pipelines get a lot more alarms. And so he's got to 9
figure out how he's monitoring this and checking on 10 this, and he may get an alarm. He may say, hey, 11 something has changed, but I don't know what it is. But 12 for a rupture release in which you've blown these pipes, 13 the 42-inch pipe is going to shrapnel and come out of 14 the line, out of the ground. Big crater. Huge gas 15 velocities.
16 But the laws of thermodynamics dictate the 17 rate at which the gas can be released out the full-bore 18 ruptures from both ends. Okay? And that's limited to 19 the speed of sound of the gas, the speed of the sound 20 of the gas within the gas. Not in air. So it's 21 roaring. But it limits the mass rate. It limits how 22 much it releases.
23 So bottom line is in layman's terms the 24 pressures don't drop as fast as you'd think. It's not 25
45 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 a balloon burst.
1 MR. PICKETT: Okay.
2 MR. KUPREWICZ: And if you close the valves 3
and they're 15 miles apart, there are plenty of 4
documents in the public domain that will show you it 5
takes many, many minutes before the flames really start 6
to decline. And so the real issue here is if you get 7
a gas pipeline rupture, how long will this burn at heat 8
fluxes that can affect equipment that is important? If 9
the answer is there's no equipment there, then that's 10 fine. Move on. But from what I'm seeing, that's not 11 necessarily the case.
12 MR. BLANCH: And adding to that, NRC 13 regulations dictates that we have to assume a single 14 failure at the valve --
15 (Simultaneous speaking) 16 MR. KUPREWICZ: Yes, let me also point out 17 to the NRC, don't feel like anybody's criticizing you 18 folks because you don't understand this stuff. There 19 are gas pipeline operators that we have to sit in a room 20 and great detail and explain this. And they're closer 21 to this and they don't get it until someone shows it to 22 them. So don't think like I'm saying, oh, you missed 23 this and it's your fault. That's not what I'm doing 24 here. Please.
25
46 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 CHAIRMAN MILLER: Thank you. I wanted to 1
ask is there anyone from the Licensee that would like 2
to ask any questions of the presenters?
3 MR. WALPOLE: No, thank you, Chris.
4 CHAIRMAN MILLER: Okay. Any other 5
questions, concerns? Did I go to the regions?
6 Anything from the region?
7 (No audible response) 8 CHAIRMAN MILLER: Okay. Good. Well, I 9
10 MR. BLANCH: And how long can we expect to 11 have to wait for a transcript of this session?
12 MR. PICKETT: Doug Pickett here again.
13 We've requested the transcript to be within a week, so 14 then we have to review the transcript and make sure it's 15 accurate. And hopefully within a few weeks you'll be 16 able to see the transcript.
17 MR. BLANCH: Okay.
18 CHAIRMAN MILLER: Okay. Do you another 19 question, Mr. Blanch?
20 MR. BLANCH: No, that's all I have.
21 CHAIRMAN MILLER: Okay. Well, I wanted to 22 thank you and Mr. Kuprewicz. Good informative session.
23 I got a lot of information covered. So thanks for 24 taking your time. We'll continue with our process.
25
47 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Before we close, does the court reporter 1
need anything additional before we close the meeting, 2
close the transcript?
3 COURT REPORTER: Yes. Mr. Kuprewicz, 4
could you spell your last name for me?
5 MR. KUPREWICZ: Gee, I've never been asked 6
that before.
7 MR. BLANCH: Yes. Right.
8 MR. KUPREWICZ: It's K-U-P-R-E-W-I, C as 9
in cat, Z as in zebra.
10 COURT REPORTER: Got it. That's all.
11 (Whereupon, the above-entitled matter went 12 off the record at 3:34 p.m.)
13 14 15 16 17 18 19 20 21 22 23 24 25
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