ML20087M164
| ML20087M164 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/19/2020 |
| From: | Theresa Clark, Yueh-Li Li, David Skeen Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, NRC/OIP |
| To: | Entergy Nuclear Operations |
| Clark T | |
| References | |
| NRC-0863, OIG 16-024 | |
| Download: ML20087M164 (69) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Gas Transmission Lines at Indian Point Nuclear Plant OIG Case Number: 16-024 Location:
teleconference Date:
Thursday, March 19, 2020 Work Order No.:
NRC-0863 Pages 1-68 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 STAFF'S RESPONSE 4
x 5
In the Matter of: :
6 CONCERNS PERTAINING TO GAS :
7 TRANSMISSION LINES AT : OIG Case No.16-024 8
INDIAN POINT NUCLEAR POWER :
9 PLANT :
10
x 11 Thursday, March 19, 2020 12 13 Teleconference 14 15 NRC STAFF PRESENT:
16 DAVID SKEEN, Team Lead; Deputy Director of Internal 17 Programs 18 THERESA CLARK, Program Manager 19 DR. YUEH-LI "RENE'E" LI, Office of Nuclear Reactor 20 Regulation 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 ALSO PRESENT:
1 RICHARD KUPREWICZ, President, Accufacts, Inc.
2 STEVE NANNEY, Pipeline and Hazardous Materials 3
Safety Administration, DOT 4
JAMAL MOHMAND, Sandia National Laboratories 5
6 7
8 9
10 11 12 13 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.
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3 P-R-O-C-E-E-D-I-N-G-S 1
1:04 p.m.
2 MR. SKEEN: All right, so maybe we'll get 3
started and if other folks join in that's fine.
4 They'll just have to introduce themselves as they come 5
along.
6 But for now, just let me start. Again, I 7
am David Skeen, I'm leading this team that was put 8
together to look into the IG event inquiry findings 9
concerning the gas pipeline, the 42-inch gas pipeline 10 that is on Indian Point's property.
11 Who just joined please?
12 MR. NANNEY: Steve Nanney with PHMSA.
13 MR. SKEEN: All right, great. Thanks, 14 Steve. We have a court reporter on the line 15 transcribing the meeting. Could you give your name 16 and spell it for him please?
17 MR. NANNEY: Steve, S-T-E-V-E, Nanney, N-18 A-N-N-E-Y.
19 MR. SKEEN: All right, thank you very 20 much, Steve, appreciate that.
21 So, to continue with the introductions 22 again. We were put together, the Chairman looked at 23 the event inquiry report and she asked our executive 24 director for operations to put together a team that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 would be independent from folks who have worked on 1
this project up to this point within the NRC.
2 And also, to get some external expertise 3
help to look at some of the concerns that were raised 4
by the Inspector General. So, that's what we are.
5 I'm the team leader for this. My 6
background was, I've been with the NRC about 29 years.
7 And I had done the Japan lessons learned after the 8
Fukushima event in 2011.
9 I worked with a group, a special projects 10 group, for about three years at the time. And so the 11 executive director asked me to put together a team, 12 assemble a team of internal and external experts to 13 kind of look at what the IG findings had put forward.
14 So what's what I've done.
15 We have several, you've heard some of the 16 team members on the line. The internal team members 17 we have Theresa Clark and Suzanne Dennis, Rene'e Li, 18 Brian Harris, who is an attorney, who is not on the 19 call today but I'm sure we can back-brief him on 20 whatever our discussion is.
21 And then externally, because we wanted to 22 make sure we got expertise, technical expertise in gas 23 pipeline issues, we were able to get Steve Nanney from 24 DOT to be part of our team as well to help us with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 that part of the evaluation.
1 And then we also have Sandia National Labs 2
who is looking at some of the fire and explosion risks 3
for us. So that's the basic, our team that we have.
4 I just want to make sure you knew that.
5 And so, we do have on the line with us 6
both Steve Nanney from, P-H-M-S-A, we say PHMSA, as 7
well as Sandia National Labs are on with us too.
8 Jamal is on from Sandia.
9 So, I
know that's a
long-winded 10 introduction but I just want to make sure you 11 understood who is on the phone and what our purpose is 12 here.
13 So, if you're okay with that, what we've 14 been doing with folks as we've interviewed them is 15 just kind of have them talk about what's been their 16 involvement in the process. So whatever they can 17 remember from that.
18 And then we have some specific questions.
19 But a lot of time when whoever we're talking with just 20 kind of says here's what they've been doing, they 21 answer a lot of our questions so that we don't have to 22 go through those.
23 And if we miss --
24 DR. LI: This is Rene'e Li. Sorry.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 MR. SKEEN: Oh, sorry. So, Rene'e, is 1
that you?
2 If you could please give your name and 3
spell it for the court reporter please?
4 DR. LI: Yes. Rene'e Li. My official 5
name is Yueh-Li, Y-U-E-H, dash, L-I, and last name Li, 6
L-I.
7 MR. SKEEN: Okay, thank you very much.
8 Did you get that court reporter, please?
9 COURT REPORTER: Yes, sir. Thank you.
10 MR. SKEEN: Okay, thank you very much.
11 And so, Rene'e is our piping and structural expert 12 within the NRC. So that's who just joined us as well.
13 MR. SKEEN: So, anyway, Rick, if you want 14 to just kind of talk about what your involvement has 15 been in the whole process. I know it's going back a 16 few years, but if you can talk about that.
17 And then maybe we'll have some questions 18 for you when you get through kind of describing what 19 your involvement has been.
20 MR. KUPREWICZ: No problem. And let me 21 know if my voice starts trailing off here. Don't get 22 real old is all I can tell you folks.
23 MR. SKEEN: Okay.
24 MR. KUPREWICZ: My involvement probably 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 initiated with the town of Portland, New York, in the 1
original AIM applications with FERC. And there is 2
documents in the FERC process that will show that I 3
did some analysis for them and raised some questions.
4 And then there is a local group of people, 5
and I don't know who they are, who have asked for some 6
technical expertise on the specialized issues related 7
to gas transmission.
8 I'm with Accufacts Incorporated. It's my 9
own company. And Steve Nanney knows me. I got a lot 10 of respect for Steve.
11 Steve and I go back interacting on various 12 PHMSA committees. And so it's good to see Steve on 13 the team, let me put it that way. I figure he didn't 14 need the work.
15 So, I guess a couple of quick things. So 16 there is back and forth documents related to the FERC 17 application. And also sometime after that, I did met 18 with members of the NRC after building in Washington, 19 I don't remember what year that was, and kind of 20 outlined some issues related to gas transmission, 21 failure dynamics. Especially in regards to rupture.
22 And basically I just said, look, the issue 23 here from a 42-inch pressure gas transmission line is 24 if the line ruptures can you basically, you're going 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 to lose the power plant most likely if it ruptures in 1
the wrong location. So you're coming down.
2 And my question to the NRC was, you have 3
to demonstrate to somebody that if the gas pipeline 4
ruptures you can, basically, what I call a cold shut 5
down. You can bring the plant down.
6 And yes, I didn't know the answer to that.
7 I didn't want to get into all the secret details. But 8
as a process safety manager background, that's a 9
simple question to me.
10 And so they did their thing. And then the 11 last couple of years the Office of the Inspector 12 General has interviewed me a couple of times while 13 they were going through that process. And so I gave 14 them my feedback on that, and that's about it.
15 MR. SKEEN: Okay. Well, I appreciate 16 that. And certainly we agree. I mean, we want to 17 make sure that the plant gets shut down safely if 18 there is a rupture to that gas line.
19 And I guess the questions stem from, how 20 did you look into evaluating that and what did our 21 staff do, and did they do appropriate or was it 22 inappropriate what we did? So we're relying on you as 23 an expert is certainly something that we want to get 24 your thoughts on that.
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9 MR. KUPREWICZ: Well, let me just 1
interject again. I've got no dog in this hunt. And 2
Steve can speak up if he thinks I'm off-tangent here, 3
but I try to stay neutral and objective. I'm not the 4
judge or jury.
5 People bring me in to ask the right 6
questions and then they'll evaluate whether those 7
questions have been adequately addressed. And I don't 8
advertise because I don't need the business.
9 So, in this particular case I would 10 suggest to your team that the OAG, and I didn't see 11 the report till just the other day, has raised many 12 issues that I find relevant. Let me leave it that 13 way.
14 MR. SKEEN: Yes, I understand. So, okay.
15 Well, with that, maybe we can go through some 16 questions and maybe that will help us if you can 17 provide some more information to us.
18 So, one of the first things we looked at 19 was, of any of the issues you raised during the time 20 that you were consulting for them, have any of them 21 been resolved?
22 Any of the issues at all that you raised?
23 Are you comfortable with any of them that 24 they have been resolved?
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10 MR. KUPREWICZ: No. And it's not, and 1
again, in the little room we got to talk and be very 2
frank. I want to respect everybody's approaches and 3
all that.
4 It was clear that, from my perspective, 5
the people evaluating this -- and again, the NRC 6
aren't gas transmission failure experts. It's not 7
your area of expertise. And that became obvious.
8 So, I would just suggest a couple of 9
things. One, not overwork the issue of leak versus 10 rupture.
11 They carry, and Steve can speak up if I'm 12 missing this, rupture carries a special meaning in 13 transmission pipelines. And while you have to talk 14 about leaks, the reality is that leaks are not a bona 15 fide threat here. Even if the line developed a leak.
16 It's the case -- the base case here is, 17 has this been adequately evaluated for gas 18 transmission pipeline rupture. Even though it may be 19 a low probability event, the consequences of such an 20 event in a certain location, and it won't matter if 21 the pipe is underground or above ground, all right.
22 And so, I would suggest, be careful how 23 the use of the word leak is used when you really are, 24 if you're talking about rupture, use the word rupture.
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11 MR. SKEEN: Okay. And can you help me 1
with that? So can you maybe tell us what's the 2
difference in rupture and leak then so we can --
3 MR. KUPREWICZ: Rupture is an imperfection 4
that is in the pipeline that causes almost 5
instantaneously the mechanical failure of the pipe.
6 Either at the weld or at the pipe body.
7 The failure occurs in microseconds.
8 Depending on the type of pipe, it can promulgate down 9
the pipeline. But basically, rupture is the pipe 10 fractures in tremendous force.
11 With tremendous force because of the 12 compressible nature of the gas. And so you generate 13 these huge craters and pipe shrapnel that may or may 14 not ignite. More likely it will ignite. It can 15 generate its own ignition source.
16 But you end up with the releases of 17 massive force that generate, you know, it will throw 18 tons of dirt and pipe steel around. And then it will 19 end up generating usually a fireball.
20 And it's fed by, because the pipe is 21 basically, completely fractured, it's fed by two full-22 bore ruptures from each end of the failure site.
23 MR. SKEEN: Okay. That's very helpful --
24 MR. KUPREWICZ: And ironically, you're not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 likely to see pressure drop right away. So, yes.
1 MR. SKEEN: Right. Well, thanks, that's 2
helpful.
3 MR. KUPREWICZ: And Steve he's got this --
4 again, Steve, I don't want to put you on the spot, but 5
you can help them fill in the details.
6 MR. NANNEY: Yes, Rick, just to tell you 7
I have been, and so, I have been going through this 8
with them.
9 MR. KUPREWICZ: Good. Good. So if I'm 10 repeating, shut me down because all I'm doing is 11 losing my voice.
12 (Laughter.)
13 MR. SKEEN: Okay. All right. So, maybe 14 we should get focused on the particular issues I think 15 that you had raised in some of your dealings with the 16 NRC or some of the problems you had.
17 So, let's talk first about the one to 18 three minutes. If you can try to talk about that just 19 a little bit.
20 And if the one to three minutes isn't the 21 right value to use, what would be the right value to 22 use if you could give us some thoughts on that.
23 MR. KUPREWICZ: Well, it's system-24 specific. And I don't know all the details of the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 control that Enbridge has got in there, this has a 1
pump, a compression station, excuse me, a compression 2
station fairly close to the plant upstream.
3 And so I don't know the specific details 4
of how they're designed to remotely monitor that 5
compressor station and how they are measuring the 6
various parameters along that pipeline for the segment 7
that could affect the nuke plant, okay.
8 But what tends to happen is the laws of 9
thermal dynamics. Even though these show up as two 10 full-bore ruptures, the laws of thermal dynamics 11 control.
12 And so you are more than likely not to see 13 a loss of pressure for a while. By the time you see 14 pressure loss, damage has already been done. Okay?
15 MR. SKEEN: Okay.
16 MR. KUPREWICZ: And so what you want to 17 know, and Steve may be able to point you to some 18 people, you want to have an expert that's an expert in 19 pipeline in transient analysis that says, okay, pipes 20 just failed at this point, and given this system, 21 what's going to happen.
22 And what's going to happen is, you're 23 probably not going to see changes in pressure for a 24 while. A few minutes at least.
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14 And more likely what you'll see is funny 1
things happening in the compressor facility. And 2
given all the information that the SCADA control room 3
operator in Houston is looking at, he may not 4
understand that he just got the indicators of a 5
possible rupture.
6 So my point is, the remote monitoring, and 7
without more detail, it could be many minutes before 8
the control room knows they actually have a pipeline 9
rupture. Okay?
10 So, there's quite a span in time before he 11 would have to determine that there is an actual 12 rupture and then order the valves closed. Because I 13 assume on a 42-inch they're not putting in automatic 14 closure valves. I don't know that, but I don't 15 remember them doing that.
16 MR. SKEEN: Yes, our understanding is they 17 are remote actuated valves but they are not automatic.
18 That the control room has to recognize there is a 19 problem and then push the buttons to isolate the 20 valves. To close the valves.
21 MR. KUPREWICZ: That would not be a 22 surprise to me. That's a fairly responsible approach.
23 I think one of the things that you might 24 want to talk about in trying to figure out what's the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 time when the actual rupture occurs between that and 1
the time to order the valve closed, one pre-factor 2
that I always tend to, when I talk to operators that 3
have had ruptures in rupture investigations, it's not 4
so much pressure loss that shows up, it's some sort of 5
massive rate change.
6 And they may or may not be set up to see 7
the rates. Now, as close as this compressor station 8
is, I would think that these things, Enbridge might 9
have some parameters that would say, if you get this 10 signal you better be looking for a rupture. You don't 11 know it's there, but this is a precursor to indicate.
12 MR. SKEEN: Okay.
13 MR. KUPREWICZ: Does that make sense?
14 MR. SKEEN: Yes, it does. And maybe you 15 can help us with this. So does the operator have to 16 have some alarm procedure or isolation procedure that 17 says -- we're used to nuclear power plant operators, 18 right, we have procedures for everything, so if 19 they're control room do they say, this is your alarm 20 procedure, that if you get this then you check this 21 parameter, that parameter and if all those check out 22 then you isolate the --
23 MR. KUPREWICZ: Yes, that's something that 24 I think Steve wants to probably chase down. Now, my 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 suspicion would be, on a 42-inch running this high of 1
pressure in this sensitive area, they probably have 2
procedures. But having procedures and getting 3
everybody to follow them is a different animal.
4 I think the point is will be, on a 42-inch 5
you just don't go out and say, somebody calls you and 6
says we got a rupture, the control room isn't going to 7
shut the buttons right away until he's got 8
confirmation. So there is some lag there between the 9
actual event and the order to close the valve.
10 MR. SKEEN: Yes. So, would you have a 11 ballpark of what would be normal?
12 Is it five minutes, ten minutes --
13 MR. KUPREWICZ: No.
14 (Laughter.)
15 MR. KUPREWICZ: I'm not laughing at you 16 guys, I'm laughing, you know, you're more likely 15 17 minutes to half an hour.
18 MR. SKEEN: Okay.
19 MR. KUPREWICZ: Now, and let me tell you, 20 as a person whose actually been in incidences in the 21 control room, those minutes can move extremely quick 22 or they can be dramatically slow, all right, during a 23 real emergency.
24 So this is not something I want to pin on 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 the poor control room operator, it's a tough job.
1 MR. SKEEN: Sure. Thank you. I 2
understand.
3 MR. KUPREWICZ: The industry will try to 4
say, you know, well, it's not a few minutes, but when 5
you start talking 15 minutes or half an hour, they get 6
a little nervous.
7 And, you know, because people then start 8
challenging them. And the answer is, it's hard. It's 9
really difficult.
10 And it's pretty system-specific. But if 11 Enbridge has got certain parameters that are focusing 12 on, all of a sudden your compressor is acting weird 13 because it's trying to run out on its curve because 14 the resistance in the pipeline has gone to zip because 15 of a rupture -- then that's a good indication of a 16 rupture 17 But given the size of this line, it would 18 be a reasonable for the pipeline operator, they just 19 don't hit this button to shut everything down, they've 20 got to really, it's not unusual to say, confirm these 21 informations that you're getting and then take an 22 action.
23 They may have the authority to shut down, 24 but this is a 42-inch gas pipeline, you got to be, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 there is a reason they didn't put in automatic control 1
shutdown valves.
2 (Laughter.)
3 MR. SKEEN: Yes.
4 MR. KUPREWICZ: Make sense?
5 MR. SKEEN: Yes. You don't want nuisance 6
tripping for sure, I understand. On lines that large, 7
you don't want nuisance tripping your isolating gas 8
lines when you don't need to.
9 MR. KUPREWICZ: Yes. A few more minutes, 10 from a pipeline operator, isn't going to make a lot of 11 difference.
12 Now, the question is going to be the 13 facilities at risk, it's back to, you know, at Indian 14 Point your reactors are in a big old concrete salter 15 but all your auxiliary equipment, is anything there 16 required that you would need to bring that plant down 17 into a safe situation, right?
18 And if there is, then you can either, and 19 this is, I had discussions with them in the meetings 20 saying, look, I don't need to get into details.
21 You've got pieces of equipment that are at risk, even 22 though it's one out of a million.
23 Murphy said the one out of a million is 24 going to occur. If this keeps you from bringing that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 plant down safely, either you move that facility or 1
you harden it. Make sense?
2 MR. SKEEN: Yes. Yes, I understand that.
3 That's something we're trying to get to the bottom of.
4 So, that leads me to another thing about 5
the distance. The potential impact radius that you 6
can calculate with the DOT equation.
7 MR. KUPREWICZ: That, again, and this is 8
where Steve and I are probably going to diverge. On 9
a 42, the PIR's intent was not to be a citing tool, it 10 was kind of used to help identify high consequence 11 areas. Understanding that it was a compromise, all 12 right?
13 And so, my experience is this. When you 14 start getting into larger diameter, high pressure 15 transmission pipelines, other factors kick in that 16 make the empirical formula, and I don't want to take 17 away from PHMSA and what they are trying to do with 18 the temp regulations. Those are good things.
19 But large diameter pipelines, you can give 20 PIRs, well, the actual impact zone can be much 21 greater. All right.
22 And I don't say that to scare you, I'm 23 just saying, I wouldn't overwork the PIR equation.
24 You'll pretty well, just say, if I have a rupture at 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 this location, even if it's underground, it isn't 1
going to matter.
2 MR. SKEEN: Okay.
3 MR. KUPREWICZ: What would a rational 4
person say? What sensitive nuclear facilities are in 5
that zone.
6 And you don't have to, whether it's 1,500 7
feet or 2,000 feet isn't going to make any difference.
8 Does that make sense?
9 MR.
SKEEN:
- Well, I'm trying to 10 understand. So if the calculation comes down, let's 11 say it's 900 feet, you're saying it could be much 12 greater than that?
13 MR. KUPREWICZ: Yes. Because another 14 factor kicks in that's not in the PIR. It's called 15 turbulence.
16 MR. SKEEN: Okay. Can you talk about that 17 a little bit?
18 MR. KUPREWICZ: Well, it's the mixing of 19 the gas in the air, then what happens is, not only do 20 you get one explosion -- these aren't modeled well, 21 these are tough things to model. And so, what you 22 have is a unique situation where they put a large 23 diameter, high pressure pipeline next to a very 24 sensitive facility.
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21 So you're trying to get this tied down.
1 And so, this is stuff that your other experts can try 2
to work out. And there are various ways to do this.
3 We know ALOHA is not the tool. And so OIG 4
was -- they figured that out all on their own. But 5
there are other ways to calculate the transient 6
releases from two ends of a pipeline. And that will 7
give you the mass of the gas. And then you can 8
decide, you know, does it ignite right away or not.
9 I'm just saying, you know, if it says you 10 got a 2,000 foot zone and whether it's 2,000 or 1,500 11 and you got a piece of critical equipment that needs 12 to either be moved or hardened, that's what you're 13 after.
14 As engineers, we all think we can 15 calculate these things to a decimal point when the 16 reality is, the assumptions are throwing you all off.
17 MR. SKEEN: Okay. So --
18 MR. KUPREWICZ: So there are no real good 19 tools to tell you the actual impact zone. But for a 20 42-inch pipeline operating this MAOP (phonetic), it's 21 going to release a lot of tonnage.
22 Especially, you're more likely -- Enbridge 23 is saying, I think six minutes. I'm not saying 24 they're wrong with the six minutes. Six minutes could 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 easily be 15 and 15 could be 30.
1 But you know, in trying to calculate this 2
stuff you'd like to tie it down, it's a tough one. So 3
you probably want to think about, here's our base case 4
and here's the sensitivity case.
5 MR. SKEEN: Right. When you talked about 6
having facilities hardened, if our components are 7
inside a, let's say an 18-inch or two footer or three 8
foot thick reinforced steel concrete structure --
9 MR. KUPREWICZ: No problem.
10 (Simultaneous speaking) 11 MR. SKEEN: -- from hardening?
12 MR.
KUPREWICZ:
- Yes, you're fine.
13 Concrete, you know, it's going to handle the blast and 14 the blast pressure, your own experts will help you out 15 here, it dissipates very quickly with distance. And 16 so the concrete is going to withstand that within 17 reason.
18 The thermal radiation is what takes out 19 your power lines and forces you into the power, you 20 know, brings the plant, you can't get the power out 21 the plant is coming down. That's what I told them in 22 the Washington, D.C., meeting.
23 Come on, you guys. The fireballs generate 24 so much thermal flux. I've seen it liquefy aluminum 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 or vaporize aluminum and liquefy steel. It's hotter 1
than hell. And Steve knows all this stuff.
2 Where you get into discussion is, that can 3
be disagreement is, well, how quickly does it 4
dissipate. Well, heat radiation doesn't dissipate a 5
whole lot with distance. Right? Your experts will 6
tell you that.
7 MR. SKEEN: Right. Thank you. But like 8
I say, if the components, because there's lots of 9
components, it's a nuclear power plant, right?
10 MR. KUPREWICZ: Yes.
11 MR. SKEEN: I think you've seen from the 12 maps or drawings, they talk about the different 13 equipment that might be taken out by the blast or the 14 heat flux. What we've seen so far is that the closest 15 components that could be impacted, that we rely on for 16 safe shutdown of the plant are probably at least 1,800 17 from the closest point of the pipe rupture.
18 And those buildings are all maybe two 19 feet, or more than two --
20 MR. KUPREWICZ: You're on the right track.
21 Again, that's the kind of detail that maybe you can't 22 make public. And I didn't know all of -- I didn't 23 have a listing of all the sensitive shutdown 24 equipment, nor did I need to have it. But I said, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 look, concrete can handle the blast forces, it can 1
handle the thermal radiation.
2 If you've got a listing of that equipment, 3
whether it's 1,800 feet or 2,000 or 2,500, here's your 4
base case and they say, well, if this turns out to be 5
3,000, do I have anything else that's sensitive, and 6
you say no, because I've got it reinforced and all 7
that, then it's off the agenda, you're fine.
8 MR. SKEEN: Okay. Well, that's very 9
helpful because that's what we've been trying to 10 struggle with is when we talk about if the PIR is more 11 than what you calculate through the DOT equation or 12 even other equations, what is the impact on reinforced 13 concrete structures because in nuclear power plants 14 that's generally the really important to safety things 15 that are relied on to shut down the plant. We call it 16 safety related equipment.
17 That is all housed in very robust 18 buildings. It's designed against hurricanes and 19 tornados and the missiles that they can generate.
20 MR. KUPREWICZ: I think you're on the 21 right tack. I would just, if you're telling me you're 22 using the PIR then I'm going to come at you and say, 23 that's in the regulation but that's not its intent.
24 And I don't want to do that.
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25 MR. SKEEN: Okay.
1 MR. KUPREWICZ: I just want to be sure 2
that, okay, if you use the PIR and you said, well, you 3
know, because this is not really a technically citing 4
tool. It was developed to be sure that pipeline 5
operators would be -- you know, do things to be sure 6
their pipeline would not rupture.
7 Now, understanding you can't guarantee 8
everything. And we've seen too many pipeline ruptures 9
even after inspections --- assessments.
10 But it was a kind of a, use this as a 11 starting point. So you can use PIR but then throw in 12 a, let's do a PIR 1.5 and see, that's a sensitivity 13 case.
14 And if you do that, someone can criticize 15 you for saying, well, it wasn't big enough. But no, 16 you tried to get the right away and you can't get away 17 the criticism from the PIR.
18 MR. SKEEN: Yes. Well, and basically 19 we're probably at two times the PIR for the components 20 to nuclear plants that could possibly be impacted, 21 right?
22 MR. KUPREWICZ: And that may be -- and 23 that would be a good thing. And now you're into, 24 okay, your kind of removing he criticism that appears 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 to be reversed engineering to get the answer that you 1
wanted rather than just do what you think the science 2
is. And that's what I think you guys are trying to 3
do.
4 MR. SKEEN: Yes.
5 MR. KUPREWICZ: I don't have all the 6
answers but I've got a lot of experience in this area.
7 And so, just know the limits of your tools and if you, 8
and you've stated a limit but not necessarily known 9
whether it's absolute. Because engineers like to 10 think we're actually calculating exactitude.
11 But thrown in another, and so if you go to 12 two times and it's still covered, that's a defendable 13 action.
14 MR. NANNEY: Hey, this is Steve Nanney.
15 I've got to get off the phone. I'm just trying to let 16 you all know.
17 Rick, good hearing from you today.
18 MR. KUPREWICZ: Yes, good, Steve. And you 19 hang in there. You got a good man over there. And 20 he'll answer your questions. And so --
21 MR. NANNEY: And just to let you know, I 22 can't be answering the questions for you, but I am 23 giving them the correct information they need to look 24 at, so.
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27 MR. KUPREWICZ: Because I -- it's in good 1
hands, let me put it that way. Good luck, Steve.
2 MR. SKEEN: Well, I appreciate that. And, 3
Steve, before you drop off, is there any questions you 4
wanted to ask or anything you wanted to get from Rick 5
before you drop off?
6 MR. NANNEY: No, if you don't mind, the 7
thing that you said they've heard from me on all of 8
those topics.
9 MR. KUPREWICZ: I wouldn't disagree 10 they've been much different. Doesn't mean that we're 11 necessarily both right, we could be both wrong.
12 MR. NANNEY: And just a, if you all don't 13 mind, just to tell you what I had told them is that I 14 had expected, with the remote control valves, my 15 experience told me that they need between ten and 20 16 minutes to, after the rupture, to identify and close 17 the valves with them being remote control, with 18 probably 15 minutes being what I think the average 19 number would be.
20 MR. KUPREWICZ: I wouldn't disagree with 21 that, but it's kind of like a balloon, you squish it 22 here and pops it.
23 MR. NANNEY: Yes.
24 MR. KUPREWICZ: Yes, we're on a very 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 similar, real world experience would tell you that 1
control rooms are funny animals.
2 MR. NANNEY: And also, I gave them our 3
proposed rule language for remote control valves --
4 MR. KUPREWICZ: Good.
5 MR. NANNEY: -- to see and see some of the 6
issues in there so that they can read about it. So 7
they do have that information too.
8 MR. KUPREWICZ: And the other data point 9
I'd give you, not that I'm here to pick sides, but 10 just on some of the OIG statements about Enbridge, 11 clearly Enbridge is trying to be truthful here so 12 that's a positive step.
13 MR. NANNEY: But the questions I have to 14 answer, I gave to Theresa to ask. But Rick may cover 15 them without asking. So Theresa has the ones I needed 16 asking.
17 MR. KUPREWICZ: Okay, Steve, well you take 18 care and don't be flying.
19 (Laughter.)
20 MR. NANNEY: I don't plan to. And you 21 all, and Rick and everybody else on the phone, take 22 care.
23 MR. SKEEN: All right, thanks, Steve.
24 Appreciate your help.
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29 MR. NANNEY: Yes.
1 MR. KUPREWICZ: Steve's a good man. You 2
got a good one there.
3 MR. SKEEN: Yes, we're very pleased to 4
have Steve as part of our team. So this is good so 5
far.
6 Let me move on to, one of the things I 7
think you raised was -- so it wasn't just the three 8
minutes issue it was how long the event could occur 9
and even if you shut the valves the gas is going to be 10 released for a consider period of time. And you 11 suggested a transient graph of mass release versus 12 time.
13 Can you talk a little bit more about that?
14 Is that what you would normally do in your evaluations 15 of a line rupture?
16 MR. KUPREWICZ: Yes, we would. Though 17 normally we're not dealing with such a sensitive area.
18 You follow the laws of thermal dynamics 19 with two pipe ends blowing. And for a 42-inch running 20 about 850 pounds, and I think Enbridge is saying that 21 the valves that we would more reasonably close are 14 22 miles apart.
23 You're probably taking 20 to 30 minutes to 24 de-pressure that line segment. Now you can, depending 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 on how your transient guys set up the models, they got 1
to follow the laws of science. And the laws of 2
thermal dynamics are the controlling factor.
3 And so the line is going to burn for quite 4
some time but the massive heat flux, with possible 5
explosions and high thermal radiation, probably occur 6
in the first five or ten minutes.
7 MR. SKEEN: Okay, that's helpful. Explain 8
that a little bit more.
9 MR. KUPREWICZ: Well, what happens is, and 10 you'll see this if you search the literature and 11 enough places are out there. Let's just say you got 12 one pipe end with full-bore rupture. The laws of 13 thermal dynamics are going to release at the speed of 14 sound in the gas. Which is over 4,000 feet a second.
15 That's why they'll sound like a rocket 16 engine blowing off, you can't tell direction. And the 17 heat flux is so high you can't tell the direction of 18 the heat. All right.
19 So what happens is, on this particular 20 one, the pipe has got a full-bore rupture. Let's talk 21 about the end that's feeding it from the compressor 22 station.
23 All of a sudden, let's say you had three 24 or four miles of pipe resistance there that went up to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 40 miles to the next compressor station let's say.
1 But now you only got three or four miles.
2 The compressor is going to try, depending 3
how they've controlled that, going to try to take --
4 compensate for the reduced system curve pressure drop.
5 Now I'm getting too techie, I'm probably losing you 6
here.
7 But what happens is --
8 MR. SKEEN: This is --
9 MR. KUPREWICZ: -- the compressor tries to 10 make up for the reduce resistance in the pipe.
11 MR. SKEEN: Okay, I understand.
12 MR. KUPREWICZ: And so, you get an 13 increase in gas flow rate out the bore of the pipe.
14 The mass goes up. The mass rate of release goes up 15 but the velocity doesn't. It's set by laws of thermal 16 dynamics.
17 And so you'll get a spike in gas mass 18 release. All right. At that one end. You'll get the 19 same thing on the other end, accept it's probably not 20 fed by a compressor.
21 Those two releases on each end of the 22 opposing pipes will come together and then the impact 23 forces negate each other. So you get these huge gas 24 plumes. And if it ignites, then you've got the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 problem of buoyancy. The thermal effects take over.
1 So, what happens basically, let me step 2
back, is you're going to see a massive increase in the 3
tonnage of gas released. But it doesn't sustain that 4
because eventually the compressors catch up or their 5
under control.
6 So you'll see a peak in the gas rate and 7
then it starts to decline.
8 MR. SKEEN: In fact --
9 MR. KUPREWICZ: You can people to argue 10 whether its three minutes or ten minutes. It depends 11 on the system specifics.
12 MR. SKEEN: Okay, thanks, Rick. Did 13 someone else just join the line, I thought I just 14 heard a -- thought I heard a beep?
15 MR. NANNEY: Yes, this is Steve Nanney, I 16 came back on. My other call got cancelled so I 17 decided to come back.
18 MR. SKEEN: Great. Thanks, Steve, I 19 appreciate that. Sorry, Rick, go ahead.
20 MR. KUPREWICZ: Well, I was just saying 21 that depending on how you're set up, your system 22 curves and your transient analysis release, for both 23 ends of the pipes, you'll see different curves when 24 you plot pounds of gas release per time.
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33 But what happens is, you can take a big 1
jump up because the pipe system resistance has dropped 2
way down and the system may or may not compensate for 3
that. But then it starts dropping off.
4 And so it's the first five minutes or so 5
that are the most dangerous. It still can be lethal, 6
but super high heat radiations occur in that early 7
stage.
8 MR. SKEEN: Would you say that --
9 according to you, they usually don't last very long, 10 it's going to last five minutes or so and then it's 11 going to --
12 MR. KUPREWICZ: Well, it will depend on 13 the system. No matter how I answer this, someone is 14 going to come at you.
15 But the key is, it's very lethal. And 16 like I said, it's so high and the blast forces are so 17 great, but the heat radiation is what really gets 18 people. It will vaporize the aluminum. It will 19 liquefy the steel, if you're too close.
20 Now, if you're in concrete structures, 21 that's not a big deal, right?
22 MR. SKEEN: Yes. If I'm in a concrete 23 structure 1,800 feet away you're saying --
24 MR. KUPREWICZ: Oh no, you're -- yes, I've 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 even seen wooden structures survive at those distances 1
but they don't survive very long.
2 MR. SKEEN: Yes.
3 MR. KUPREWICZ: If you don't get the heat 4
down some.
5 MR. SKEEN: Okay. Well now, that's 6
helpful. I appreciate that.
7 So, I guess the next thing, and maybe 8
you've already answered this, one of the other things 9
that I've seen you had raised was by doubling the 10 pipe, you're just going to double-end it guillotine 11 break and say that's conservative, and I think you had 12 said that that was not --
13 MR. KUPREWICZ: Well, I would step back a 14 second. Be careful of the use of conservative because 15 that opens you up to attack.
16 MR. SKEEN: Okay.
17 MR. KUPREWICZ: You may mean well by its 18 application, but if it isn't conservative and they 19 catch you at something that isn't conservative, it 20 undermines your credibility and there's no need to do 21 that.
22 What I would say is a pipe rupture is 23 always a guillotine break. It's a guillotine break 24 from both opposing ends with a big hole in the middle.
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35 And so you may throw a hundred or two 1
hundred feet of pipe steel weighing several tons into 2
shrapnel and then you got a guillotine on one end, 3
guillotine on the other. And they're coming out at 4
the speed of sound in the gas, which is usually a 5
little over 4,000 feet a second.
6 And those forces are hitting each other 7
and they're trying to cancel each other. So it 8
increases the buoyance, the net effect. Again, I'm 9
getting into details, probably putting you to sleep, 10 I'm sorry.
11 MR. SKEEN: No, this is fine, this is 12 good. This is helpful.
13 MR. KUPREWICZ: But it generates big gas 14 clouds. And if they're burning, that's where you see 15 these huge clouds and these big turbulences. And it's 16 hard to model the turbulence.
17 That's the thing that, that's why we 18 agreed on the PIR, let's not overdo this. You know, 19 some of these will work for 42-inches, some it will 20 not. Just don't use it for a citing tool.
21 MR. SKEEN: Okay. Well, thanks for that.
22 So, we talked a little bit about the use of ALOHA.
23 And are you saying that's not the right code to use?
24 MR. KUPREWICZ: Well, no, I don't recall 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 if I told them, you know, they were using them. They 1
said they were using ALOHA and I said, yes, I wouldn't 2
have done that.
3 I did, I think, tell them, again, you're 4
asking from memory and at my age, I don't forget 5
anything, but the recall gets a little fogged up.
6 Basically, and the OIG kind of smoked that out.
7 What tool do you use? And so they may 8
have tried to use a tool, and clearly they've opened 9
up themselves to criticism because it's not 10 appropriate.
11 A pipeline rupture is gas coming out at 12 both ends of the pipes. And it's tough to model that.
13 There are attempts to do that by using mass 14 calculations and thing like that. But it's only going 15 to get you in the ballpark.
16 And that's why I say, try to use your PIR 17 and if you want to double that distance of sensitivity 18 and be sure everything is protected there, you're in 19 real good, you're in defendable course here.
20 MR. SKEEN: Okay. Because what I'm 21 looking at for this, what the team is interested in, 22 is our processes and procedures. And if using ALOHA 23 as part of what our process says to do, if that's not 24 correct, that's what we're trying to understand. Is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 that something that we --
1 MR. KUPREWICZ: Yes, I would say, again, 2
I'm not the ALOHA expert, but I've never, I've seen it 3
used in a couple of different scenarios and it's not 4
appropriate for gas transmission pipeline ruptures.
5 Would be my experience.
6 So I think you need to chase that one down 7
a little more. And you're probably going to have a 8
hard time, well, what do you use.
9 Well, you got to find somebody familiar 10 with transient release dynamics for a gas pipeline 11 rupture that models both ends of the release. And 12 then you try to apply it to a specific site, which is 13 really tough.
14 MR. SKEEN: And are there programs out 15 there that do that?
16 MR. KUPREWICZ: I've not run across, 17 usually I run across guys -- there are models that are 18 out there, I haven't run across too many that I can 19 site.
20 MR. SKEEN: Okay.
21 MR. KUPREWICZ: To be specific. It's a 22 tough nut. A lot of this stuff is very site-specific.
23 MR. SKEEN: Yes. And I don't know, have 24 you seen many 42-inch gas line ruptures?
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38 MR. KUPREWICZ: Well, now you let me think 1
in 50 years --
2 (Laughter.)
3 MR. KUPREWICZ: The answer is not many.
4 You know, the first rule of gas pipeline, especially 5
of 42-inch is, don't rupture. Which is why we've had 6
so much time trying to make the PHMSA temp regulations 7
a little more meaningful.
8 And many companies get it and are staying 9
well ahead of the federal regulations and other 10 companies don't. All right. And there are some 11 things they just can't assess.
12 So I'll warn you this, you need to do what 13 you guys are doing because there is no such thing as 14 an invincible pipeline. And I've been across the 15 table from companies under oath who have tried to 16 explain they put one in, and the answer is, no, you 17 didn't.
18 MR. SKEEN: Yes, so, I guess that leads us 19 into integrity management program. Because there's 20 threats you have to look at, right, under that --
21 MR. KUPREWICZ: You're supposed to look at 22 them, yes. And again, many companies are way ahead of 23 that, other companies are not.
24 We've had -- I don't think it's a problem 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 here but like SCC, stress corrosion cracking, we still 1
don't have an inline inspection tool that reliably 2
identifies that material.
3 Now, the good news is not all gas 4
transmission pipelines have a bona fide threat from 5
6 MR. SKEEN: Right. But if this truly is 7
an HCA and they enhance the piping and the maintenance 8
and all that and they meet that program, does that 9
reduce the probability of --
10 MR. KUPREWICZ: Yes, it does. And the 11 answer to your question, the answer is yes.
12 And I say this many times in public, a 13 pipeline company doing the right thing should have no 14 problem explaining how they are in demonstrating what 15 the right things they are doing to prevent a pipeline 16 from rupturing. Right? It's when they get into 17 secrecy and lack of transparency they start getting 18 into trouble.
19 MR. SKEEN: Okay. Now that's helpful.
20 MR. KUPREWICZ: So just, you just don't 21 want to meet, and Steve will tell you this, the 22 federal mins are minimal so you want to exceed those, 23 especially any lines that are getting around 24, 36, 24 42-inch. Those have big actual impact areas. So 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 don't rupture.
1 MR. SKEEN: Okay, thanks. Thanks, that's 2
helpful. I think we've covered this already but I 3
want to make sure. So when we look at the different 4
aspects of a rupture where there will be detonation at 5
the rupture or jet fire or vapor cloud detonation or 6
the --
7 MR. KUPREWICZ: Let me help you out. It's 8
not going to be a jet fire. No, that sounds like 9
engineers trying to logic it.
10 If they try to say it's kind of like this, 11 it's like a jet fire, they are showing to me that they 12 don't grasp the real dynamics of a true gas 13 transmission pipeline rupture. Yes, it could be jet 14 fires, but they're coming together, all right, 15 neutralizing each other and forming huge clouds of 16 hydrocarbon that are mixing.
17 And so, engineers like to put these things 18 in boxes, and I'm not trying to be critical, it's just 19 that when they try to put those boxes in and they 20 don't apply, they lose credibility. And so, I just 21 warn you about that.
22 MR. SKEEN: Okay. So you would focus more 23 on the detonation itself at the rupture or a vapor 24 cloud detonation or detonation --
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41 MR. KUPREWICZ: Yes, it's probably a 1
detonation. The initial ones are the attention 2
getter. And depending on a 42-inch, it's probably 3
going to have multiple because, think of it as, you 4
had this huge tonnage of gas release. It's coming out 5
at the speed of sound on both ends of the pipe to kind 6
of cancel each other. Not taking it to zero but their 7
opposing forces are cancelling out.
8 And then it's mixing with the air and all 9
this and there's a lot of turbulence. And so the 10 turbulence can cause parts of the gas cloud to hit the 11 area that will support combustion and then you'll get 12 an explosion.
13 Other parts of the gas cloud won't hit 14 that and won't explode. But then they'll re-explode.
15 So it changes that mixing and the complexity and the 16 turbulence is very difficult to model.
17 MR. SKEEN: Okay. But again, we would go 18 back to, if we're twice the distance in the PIR, even 19 with those clouds being formed and exploding, what 20 about structures 1,800 feet away?
21 MR. KUPREWICZ: I would think that would 22 be a defendable action. Now, I can open some 23 criticism, but you've tried to do the best you can 24 with the tools you have.
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42 MR. SKEEN: Okay.
1 MR. KUPREWICZ: And the sensitivity 2
analysis would be defendable.
3 MR. SKEEN: Okay. I appreciate that.
4 MR. KUPREWICZ: Part of the problem may 5
have been not getting straight -- you know, you're 6
kind of using these tools to say it's this impact 7
area. But you may be off. And so it may be two or 8
three times that impact area.
9 And you couldn't really list the 10 structures that were needed to bring that plant down.
11 So that could have been part of it.
12 MR. SKEEN: Yes. Well, I think clearly we 13 can, I think we can identify the structures that we 14 need, the components we need to do safe shutdown of 15 the plant. And --
16 MR. KUPREWICZ: You don't have to list 17 them in a public document but you can demonstrate to 18 your organization that that's due diligence as best 19 you can. Understanding that everybody thinks they can 20 calculate this to the first digit, and the answer is 21 there's a lot of uncertainty here.
22 MR. SKEEN: Yes. I appreciate that.
23 MR. KUPREWICZ: What aggravated this was 24 hearing that they can shut this down in three minutes.
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43 That's not credible.
1 MR. SKEEN: Yes, we're --
2 MR. KUPREWICZ: It may have been they took 3
three minutes to close the valve, but it might take 15 4
minutes to understand you need to close the valve.
5 You get it.
6 MR. SKEEN: Yes, I appreciate that. And 7
we're still trying to track down the three minute 8
issue.
9 Then we look at it, if three minutes is 10 not the answer, then what's a credible amount of time, 11 and even if that credible amount of time is the time 12 that you have the high heat flux, is that going to 13 impact the safe shutdown equipment for the plant?
14 MR. KUPREWICZ: You got it. You've got it 15 right there. And they can argue 15, 20. But you're 16 heading in the right direction there.
17 And that's where all I kept getting was, 18 no, we can do it in three minutes and that's, where 19 did you get this. No, that's three minutes to close 20 the valve, that doesn't mean, yes, you're on the 21 right, you get it. You guys have got it.
22 MR. SKEEN: Okay, thanks, I appreciate 23 that. I'm going to open it up to the other team 24 members I've been talking for a while.
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44 I think I've captured most of the 1
questions and concerns that I had, but others may have 2
thoughts as well. So, Theresa, I'll turn to you and 3
the other team members. If you've got any other 4
questions or anything Rick can clarify for us while 5
he's on the phone.
6 MS. CLARK: Hey, Rick, this is Theresa.
7 Thanks so much, this has already been really, really 8
helpful. And it's, obviously, as you mentioned, 9
confirming a lot of the stuff that we've been hearing 10 from Steve.
11 I wanted to ask you a question about, you 12 talked some about the cloud and the mixing and the 13 turbulence. What impact, in your view, does the 14 topography of the location have on the consequences of 15 a rupture?
16 MR. KUPREWICZ: It's extremely critical 17 for gas. Natural gas.
18 MS. CLARK: Tell me more if you can.
19 MR. KUPREWICZ: Well, the back pressure 20 generated from the blast forces, when the burning goes 21 to detonation, at the velocities or whatever, it's the 22 resistance. And so, like if you got more open 23 structures, more open fields with a few buildings in 24 it, there isn't a lot of resistance to build back 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 pressure, does that make sense?
1 MS. CLARK: Yes, it does.
2 MR. KUPREWICZ: And so, what drives people 3
crazy -- and I'm in some places, like in Pennsylvania 4
they're talking about HDL clouds, which you never want 5
to disrespect, okay. And blast forces and all this.
6 And they got both sides coming at each other.
7 And the answer is, is those blast forces 8
are site specific, all right. And so that's what 9
drive, you got two challenges here.
10 One, the heat radiation that's absolutely 11 going to be just off scale. If you just, if you've 12 ever been in these it will just do terrible things 13 quickly. You don't have many seconds and then if you 14 don't get out of the heat radiation you're dead. Or 15 going to die.
16 The blast forces are a different animal.
17 It's a different level of complication. So, if you've 18 got some uncertainty in trying to model this, I think 19 you got to do blast because you got to do projectile 20 stuff.
21 But even your projectiles, you've got 22 concrete structures, they're going to handle the 23 projectile. Especially if they're reinforced.
24 So, you've got two lines of attack here.
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46 One, the thermal radiation and the other one of the 1
blast forces. And trying to model those are going to 2
be more challenging because they tend to be more site-3 specific.
4 And if you've got fairly flat terrain, 5
that's easier to model. So it's a challenge, that's 6
all I can tell you.
7 MS. CLARK: That's really helpful because 8
we were out at the site last week and it's a pretty 9
hilly site but without a lot of tree cover in the 10 area. They did clear cuts the way they should.
11 MR. KUPREWICZ: Yes.
12 MS. CLARK: But the plant is quite a bit 13 downhill from where the pipeline area is. And in some 14 cases there's a hilly part in between the plant and 15 the pipeline. And then it's downhill from that. So 16 we were trying to grapple with how that effects how 17 things progress.
18 MR. KUPREWICZ: Yes, I think empirically 19 you're in the right direction. The plant is not going 20 to get the, blast forces are hard to calculate and 21 predicate and they're very terrain specific.
22 But the fact that your lower for, is a 23 direction. So you can do a directional thing. My 24 experience would be, not knowing all the details, is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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47 the heat radiation is going to be the real thing 1
that's going to be the real threat for the plant. And 2
if it's protected for that, that's a positive.
3 MS. CLARK: Okay, thanks, Rick. One more 4
clarification and then I'll pass you off to the next 5
person.
6 Very early in our discussion, and I'm only 7
asking this because we have a transcript here, you 8
made a comment like, when this -- if an explosion 9
happens you're going to lose the power plant. I think 10 that you meant like the switch yard and the offsite 11 power that goes to the nuclear station. Is that what 12 you meant there?
13 MR. KUPREWICZ: Yes. Now that's fair.
14 That's a fair call. But when I said explosion, you 15 get this blast force in the microseconds. The force 16 is related to a pipeline rupture on a 42-inch are 17 huge. This is like that concrete overbarrier. That's 18 gone. That's going to be flying someplace.
19 And so when I said blast, it's the -- and 20 I missed, and thank you for trying to get me to 21 clarify that because it's important. You got the 22 force of the actual failure which generates 23 projectiles and massive forces.
24 And then you got other forces generated 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 from the ignition in such a manner that it generates 1
detonation.
And they'd probably do multiple 2
detonations.
3 And that's what makes these things kind of 4
complicated. So, you're covered, if your structures 5
are reinforced and all that, you've got those really 6
covered, then the real factor is, from the ignition, 7
is what's going to happen is the heat flux is so how 8
it's going to melt the high-powered transmission lines 9
which are going to force the plant to come down. Does 10 that make sense?
11 MS. CLARK: Yes, that makes a lot of 12 sense. And certainly we analyze these facilities for 13 losing offsite power because that can happen for any 14 number of reasons.
15 MR. KUPREWICZ: Yes.
16 MS. CLARK: So, if that's what you were 17 saying, then we understand that and how to move 18 forward with that.
19 MR. KUPREWICZ: Well, I don't know if I've 20 clarified that because there's different degrees of, 21 I'm using blast to cover more than one term and that's 22 not fair to you guys.
23 MS. CLARK: No, that's totally fine. And 24 I think when you were saying you meant power in the T-25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 lines.
1 MR. KUPREWICZ: Yes.
2 MS. CLARK: Yes.
3 MR. KUPREWICZ: The plant can't come out, 4
it's got to come down. And in doing that, in bringing 5
those things down is a cold, what I call a cold 6
shutdown, what facilities are required. And if 7
they're covered then you got a defendable position.
8 MS. CLARK: That's fair, thanks. Maybe 9
I'll call on Suzanne next. If you have any questions, 10 Suzanne.
11 MS. DENNIS: No, I think you covered 12 everything that I had questions on. I really 13 appreciate you taking the time to talk with us, this 14 has been so helpful.
15 MR. KUPREWICZ: Well, we're just trying 16 to, yes, no one is looking for demons here. It's easy 17 in today's environment, it seems like somebody has to 18 win and the answer is, let's just do it right. If 19 it's covered, fine.
20 But the OIG report is not a very -- those 21 are the kind of things I don't like seeing because --
22 well, you understand, I'm preaching to the choir.
23 But, you know, they did their job. OIG 24 did their job. And they got some important findings 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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50 there that you folks need to address.
1 MR. SKEEN: No, and that's exactly what 2
we're trying to do. So, again, we appreciate, Rick, 3
that you're forthcoming.
4 MR. KUPREWICZ: Do you think you're going 5
to have a shot at being able to do this in 45 days 6
with all this other stuff going on?
7 MR. SKEEN: Well, we're all working from 8
home right now. None of us are in the office. But 9
we're doing pretty well with communication. So we're 10 hoping to still get something to the Commission within 11 the 45 days.
12 MR. KUPREWICZ: Let me, it's easy for me 13 to say it, because I don't have to deal with, I'm too 14 old and don't agree. Hopefully, I survive the next 60 15 days, but it's very, my advice, it would be very 16 important, if you get hung up for whatever reason and 17 there's a lot of pressure to get this thing done but 18 the last thing you want to do is get rushed and not 19 cover your bases and to find out that you expose 20 yourself.
21 And so it's important to do it right as 22 best you can. And no one, they may criticize you, but 23 it's not going to go very far if you're trying to do 24 the right thing. So don't let time cause you to short 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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51 circuit something.
1 MR. SKEEN: No, we understand that. But 2
again, like I say, talking to people like you, and 3
we're going to talk with Mr. Blanche as well to make 4
sure we understand their concerns.
5 Our role here is to try to figure out if 6
there are weaknesses in our processes and practices 7
that we do --
8 MR. KUPREWICZ: Yes.
9 MR. SKEEN: -- we can make that better 10 with the NRC. And also, we want to ensure that the 11 plant would be able to safely shutdown if there is a 12 problem with that gas line.
13 MR. KUPREWICZ: I had a chance to talk 14 with Paul yesterday. I said, look, I just went 15 through this report, the OIG is pretty dead on and so 16 you've raised, Paul, you raised some serious issues.
17 I don't know the answers to these but the questions 18 are valid.
19 But I did tell him, you know, you got 20 Steve Nanney from PHSMA on this, he's a pretty 21 straight shooter. So, hopefully the team is trying to 22 get to where they need to be.
23 So I'm not here to convince people what's 24 right and wrong, just to be sure the right questions 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 have been asked and the answers are complete. But I 1
think your, it sounds like your heart is in the right 2
place.
3 MS. DENNIS: Hey, this is Suzanne Dennis.
4 I just had a question I wanted to ask.
5 So, one thing we talked about a little is 6
the -- when ignition would occur, and Steve has given 7
us his thoughts. But do you have any thoughts, just 8
from your history working with gas pipelines, of a 9
vapor cloud traveling and then igniting later?
10 Is that something that you think would be 11 credible or something you've ever seen working in the 12 industry?
13 MR. KUPREWICZ: Well, let me state real 14 clear, not all pipeline ruptures ignite, okay. That's 15 a fact.
16 Now, those that ignite usually dose out 17 fairly quickly within 30 seconds or so. In the 18 Carlsbad, New Mexico, case it was 22 seconds. They 19 can tell that from the seismic. That was in 2000, I 20 think. But that was a 36-inch I believe.
21 So I think the odds of having a large gas 22 cloud moving a long distance is probably low. But I 23 can't say it isn't absolute. But my experience has 24 been, if they're going to ignite they tend to ignite 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 within a minute.
1 MS. DENNIS: Okay, great. Thanks.
2 MR. KUPREWICZ: Now, what people do miss 3
is, well, if we ignited once and it's burning like 4
hell over here but it's so great a release that it's 5
generating multiple combustion areas. So, that's what 6
makes modeling really crazy. So, anyway, that's the 7
way it is.
8 MS. DENNIS: Can you expand on that a 9
little bit more?
10 MR. KUPREWICZ: Well, and again, I don't 11 like to get into this too detailed. You guys are 12 okay, but the issue of turbulence with large gas 13 releases aren't modeled by the PIR. That's an 14 empirical developed thing that has limitations to it.
15 And so, people more sophisticated with 16 this stuff who do this for a living might try to model 17 that. But the tonnage is so great and the rate of 18 release is so huge, that you'll get pockets of areas 19 where it burns and other areas it doesn't burn. And 20 then as they mix for various reasons, it will 21 reignite.
22 And so, yes, you can't really, it's hard 23 to model that so you just try to do the best you can 24 and just say, here's what it is and we'll say, it's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 got an ignition of a long time (phonetic).
1 MS. DENNIS: Got it. Thanks.
2 DR. LI: This is Rene'e. I would like to 3
ask you a question. You mentioned earlier when a 4
pipeline break, assuming double-ended break, and then 5
the blowdown from both ends, it generate turbulence 6
and it will have a peak mass release. And then after 7
a couple of minutes it may drop off.
8 In your opinion, that peak mass release, 9
in general, will last about how long?
10 MR. KUPREWICZ: Well --
11 DR. LI: Are we talking about minutes or 12 a couple of minutes?
13 MR. KUPREWICZ: Oh, it's probably a couple 14 of minutes or less. It comes down pretty quick.
15 Why I'm a little hesitant about this is 16 you've got a big gas compressor station a couple of 17 miles upstream, all right. That could take over and 18 actually drive more gas to go down this.
19 Now, that's a thing that Steve and 20 Enbridge can lock down. A couple of years ago I told 21 the industry, if you're looking for a rupture 22 indication you look for flow, not for pressure. The 23 flow rates will go up.
24 So, generally where there is not a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 compressor station nearby, you get this peak and it 1
drops off fairly quickly within the first minute.
2 When you got complexities like compressor 3
stations, it's a couple of minutes.
4 DR. LI: Okay.
5 MR. KUPREWICZ: But --
6 DR. LI: Yes, because the duration of --
7 MR. KUPREWICZ: -- the facility --
8 (Simultaneously speaking.)
9 MR. KUPREWICZ: -- is still pretty long.
10 DR. LI: -- release will affect potential 11 impact radius that we are talking about.
12 MR. NANNEY: That's right.
13 MR. KUPREWICZ: No, you're on the right 14 track. Now, let me be clear here --
15 MR. NANNEY: Hey, this is Steve Nanney.
16 MR. KUPREWICZ: The nature of gas 17 transmission pipeline ruptures, they're always two 18 full-bore ruptures with a bit old hole in the middle.
19 Right?
20 DR. LI: Right.
21 MR. KUPREWICZ: And they don't have a 22 precursor that shows up as a leak, they go right to 23 rupture. The nature of the anomalies go to a point 24 where they fracture. And the pipe is, you know, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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56 fractures apart.
1 So, you know, someone says, well, I want 2
to model it with both bars, the answer is no, that's 3
what actually goes on.
4 (Laughter.)
5 DR. LI: But does it make a difference if 6
the pipe is above ground or underground? Do you also 7
still assume a double-ended break when the pipeline is 8
buried under ground?
9 MR.
KUPREWICZ:
- Yes, it makes no 10 difference. The forces are so huge that your buried 11 pipeline is going to be right above ground when you 12 get done.
13 DR. LI: All right.
14 MR. KUPREWICZ: There's going to be a huge 15 crater. The resistance of the soil, even if with the 16 concrete barriers, isn't going to make any difference.
17 DR. LI: Okay.
18 MR. KUPREWICZ: Now, let me give you a 19 little story a few decades back. It wasn't a gas 20 line, it was another pipeline.
21 And they had put a thick concrete barrier 22 over their pipeline as a safety measure to try to keep 23 people from trying to hit their line. And the people 24 who were working around the pipeline, who didn't 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 bother to call One Call, decided to just go right 1
through that concrete barrier.
2 And so, it sounds real good to have that 3
as a safety, but it can't necessarily be effective.
4 DR. LI: Yes.
5 MR. KUPREWICZ: So that's, again, it's 6
back to all steel transmission pipelines can rupture 7
if you're not respecting them.
8 DR. LI: Okay, thank you.
9 MR. SKEEN: Steve, did you want to jump 10 in, I thought I heard you try to say something?
11 MR. NANNEY: Yes, I was just going to say 12 something. And Rick can answer.
13 Based upon what Rick said, the reason the 14 volume would keep up is normally your gas transmission 15 compressor stations would be on a set pressure because 16 they do not have flow measurement at every compressor 17 station. But the main way to maintain volume is to 18 maintain a set pressure.
19 And that's why Rick said what he did is 20 because they'll have the compressor at the station set 21 to maintain, let's just say 800 pounds or 850 some set 22 pressure. And so if you rupture the line and the 23 pressure starts going down, it's going to start moving 24 more gas initially until it basically deadheads that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 it's not getting enough volume to feed the compressor.
1 MR. KUPREWICZ: Yes, it will trip on such 2
low flow.
3 MR. NANNEY: Yes.
4 MR. KUPREWICZ: Maybe.
5 MR. NANNEY: So that's why Rick made the 6
comment that he did.
7 MR. KUPREWICZ: Yes, Steve is better 8
explaining. I'm too much, I'm too old to be clear I 9
guess. You're dead on, Steve, thank you.
10 Well, I hope this helps.
11 MR. SKEEN: Very helpful. Did anyone else 12 have any questions for Rick?
13 MR. NANNEY: Could I ask just a question 14 or two?
15 MR. SKEEN: Oh yes.
16 MR. NANNEY: Or did you all ask a couple 17 of the questions or the thoughts I gave to Theresa, 18 did you all ask them while I was off the phone?
19 MR. SKEEN: No, we did not get to all 20 those. No.
21 MR. NANNEY: Do you mind if I just ask an 22 item or two?
23 MR. SKEEN: Please do.
24 MR. NANNEY: Okay. As far as if you did 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 have a rupture and everything and you had facilities 1
that were hardened, but if you had any metal 2
facilities that were support facilities for that 3
structure, do you have any comments on it? On those 4
types.
5 MR. KUPREWICZ: Oh, that's an excellent 6
point. Yes, we talked about concrete. And a lot of 7
this is, you know, those are good.
8 But if you've got something that's got, 9
and I take an example, and I don't remember the 10 location, you got a diesel tank outside storing up 11 diesel for backup generators, if it's in within a heat 12 flux zone it's going to blow up, right?
13 Or the tank can fail, all right. Because 14 the metal structures are going to weakened. The heat 15 radiation, depending how close it is to the pipeline, 16 can be incredibly high.
17 MR. SKEEN: Yes. So we had looked at 18 that, and I appreciate that, because that's one of the 19 things we did look at. One of the first things we 20 looked at was that diesel fuel storage tank out there.
21 And while they could lose that tank, the 22 diesels themselves can run for four hours on the tanks 23 that they have internally, inside the building.
24 MR. KUPREWICZ: Yes. I think I remember 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 having that discussing some years ago. That's good.
1 Good to reinforce that.
2 MR. SKEEN: Then they have tanks below, 3
storage tanks that sit underground, underneath the 4
diesels, that are good for seven days. Seven day 5
tanks they call them.
6 And then they have these, they have this 7
tank that sits out on the parameter of the plant.
8 They have a tanker truck, basically, that they fill 9
that up and bring it in to fill up the day tanks is 10 what they try to do, right?
11 So what they've done is they've taken that 12 tanker that used to sit out with the diesel tank and 13 moved it to the other side of the plant. So it's 14 probably 2,000-plus feet, 2,500 feet away from where 15 the diesel tank is now. So further away from the gas 16 pipeline.
17 MR. KUPREWICZ: And I think, I didn't mean 18 to interrupt you, but one of the issues that came up 19 was the control room location. And I don't remember, 20 it's been awhile, is the control room recently 21 protected from any of this or is that --
22 MR. SKEEN: Yes. So the same thing with 23 the control room, it's in the auxiliary building, 24 which is also thick concrete building.
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61 MR. KUPREWICZ: Yes. No, you're totally 1
fine. Okay.
2 MR. SKEEN: It's well-protected too. But 3
there was a concern about the fuel for the diesels.
4 So, they did move that tanker truck to the opposite 5
side, farthest away from the pipeline.
6 And so that gives them additional fuel for 7
the diesels as well. But we did look at that. That 8
was one of the first things we looked at was that 9
diesel fuel tank out there that was sitting near the 10 perimeter of the plant.
11 MR. KUPREWICZ: Good.
12 MS. DENNIS: And, Dave, just to be clear, 13 I think the fuel that co-located with the diesel was 14 a couple of days, not seven days. You might have said 15 seven.
16 MR. SKEEN: I'm sorry if I said seven.
17 Yes, it's a few days.
18 MR. KUPREWICZ: It will bring the plant 19 down, yes.
20 MR. SKEEN: That's also a full plant load 21 if you have an accident. And so, for normal plant 22 loads, if you shut down normally, those fuels should 23 last more than several days.
24 MR. KUPREWICZ: Steve, did you have 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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62 another question?
1 MR. NANNEY: Yes, sorry. Rick, another 2
question. I know you talked about the PHMSA or the 3
Part 192 potential impact radius.
4 And the question I have there is, in your 5
understanding, the potential impact radius in the Part 6
192 code is a radius to give people basically X number 7
of seconds to get out of that potential impact radius 8
before basically it kills them.
9 And if you go read in the code and go on 10 how it was developed. It wasn't developed to protect 11 structures, it was protected to just give people X 12 seconds to get out of that PIR.
13 MR. KUPREWICZ: Yes, if memory serves me 14 right, it was the same thing we used for flare design, 15 5,000 btu per hour, per square foot.
16 MR. NANNEY: Yes.
17 MR. KUPREWICZ: And 5,000 --
18 MR. NANNEY: And it is 5,000.
19 MR. KUPREWICZ: -- btu per hour, per 20 square foot, you're not going to be in real 21 comfortable zone.
22 MR. NANNEY: Right. And in fact, you'll 23 see people getting burned --
24 MR. KUPREWICZ: Yes.
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63 MR. NANNEY: -- getting out of that a lot 1
of times when there is an explosion.
2 So, your understanding is, that's what it 3
is.
4 MR. KUPREWICZ: Right.
5 MR. NANNEY: Which is what I have told the 6
folks there at the NRC.
7 MR. KUPREWICZ: Yes. And I just try to be 8
real careful because in my mind, in my experience, 9
some were around 20 or 24-inch diameter pipe, you 10 know, the PIR is very accurate and reasonable.
11 But after that you start getting into this 12 turbulence factor and that's hard to predict. And so 13 I just, you got to do what you got to do.
14 We were trying to get a transmission 15 integrity management rule moving forward. And it 16 turned out it was 7.3 miles per, not the total mileage 17 of gas transmission lines.
18 But anyway, we're on the same wavelength.
19 MR. NANNEY: The other, and probably the 20 last little couple of questions is, if you put a 21 pipeline like this in and you put additional 22 mitigation measures in, like heavier wall pipe, you 23 put the pipe deeper in the ground and you put, as you 24 all were talking earlier, things in the ditch such as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 warning tape and maybe the concrete barriers as 1
mitigation measures against someone getting into the 2
pipeline, do you have any thoughts on like heavier 3
wall pipe and it being a High Consequence Area and 4
doing all the risk assessments and remediation efforts 5
there?
6 MR. KUPREWICZ: Well, I do. It's moving 7
in the right direction going, from your early 8
conversation, maybe you were off, I just counsel 9
people to be careful. While these are good and 10 they're moving in the right direction.
11 Like thicker pipe, that's a good thing.
12 Even the concrete barriers. I gave them a case where 13 14 MR. NANNEY: I heard that. Okay, we're 15 good.
16 MR. KUPREWICZ: -- I can't tell you what 17 state that was in, but it was a state of confusion.
18 (Laughter.)
19 MR. NANNEY: Okay.
20 MR. KUPREWICZ: And it wasn't the 21 operator's fault, or Christ almighty, they were 22 blowing right through there with a big old backhoe.
23 But anyway. So those are all moving in 24 the right direction. You just have to be real 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 careful, in especially in sensitive locations where 1
the consequences can be catastrophic, that you're not 2
overcompensating in your risk analysis and saying, 3
well --
4 And I think one of the criticisms is, one 5
of the specialists came up with, well, we'll use a 65 6
percent factor here, well, wait a minute, how the hell 7
you get, you know, that puts you in a bad spot. Try 8
to avoid that.
9 So, you can list those things as positive 10 things, you just got to be careful when you try to be 11 careful when you quantify their effect because there 12 is no such. It's amazing how people can figure out a 13 way to rupture steel pipeline.
14 And I've been in places where these guys 15 are under oath and they may believe it but it's not 16 necessarily true. Even though it's thicker and deeper 17 and all that, you got to be careful that certain 18 factors don't come together.
19 The law of Murphy works to conspire to 20 cause a failure.
21 MR. NANNEY: Okay.
22 MR. KUPREWICZ: And those are good things.
23 I don't want to downplay them, that's good that they 24 did them. But I also don't want to overcompensate for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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66 what they did.
1 MR. NANNEY: I understand. Thank you.
2 MR. SKEEN: All right. Well, thanks, 3
Steve. Does anyone else have any other questions for 4
Rick?
5 All right, hearing none, Rick, we really 6
appreciate you talking with us. As I say, we're under 7
a tight deadline to try to get a report to our 8
Commission.
9 And we do have a good team working on this 10 but we thought it was very important that we spoke 11 with you since you were one of the technical experts 12 that were involved in this and had raised some 13 concerns about what the NRC might have done. So we 14 appreciate that.
15 And we've learned a lot from talking to 16 you today. Very helpful. I wonder, if we have any 17 subsequent questions would we be able to reach back 18 out to you and contact you again if we have any other 19 questions for you?
20 MR. KUPREWICZ: Any time. Just give me an 21 email and I may have a couple of, it comes in waves.
22 I just finished one.
23 So, send me an email and like I say, I can 24 come back and talk to you guys at this time or 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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67 whatever. But yes --
1 MS. DENNIS: Hey, Dave?
2 MR. KUPREWICZ: -- anything I can do to 3
help you guys try to meet your deadlines.
4 MS. DENNIS: Hey, Dave, this is Suzy. I 5
forgot one question. I'm sorry I'm not very on top of 6
the ball today.
7 So, when we were looking at the PHMSA 8
data, it has a separate category for leaks and 9
ruptures. So, I was just wondering if this was 10 something that you, like, would you assume that a leak 11 in relation to the PHMSA data would cause this kind of 12 catastrophic event?
13 MR. KUPREWICZ: There is no correlation 14 between leaks and rupture.
15 MS. DENNIS: Got it.
16 MR. KUPREWICZ: It's not illegal to leak.
17 If you rupture, you're probably in big trouble.
18 (Laughter.)
19 MS. DENNIS: Got it. Thank you.
20 MR. SKEEN: All right, thanks for that, 21 Suzanne. And thanks, Rick.
22 MR. KUPREWICZ: Hey, you guys take care 23 and have a good -- what day is today, Thursday?
24 MR. SKEEN: Today is Thursday.
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68 MR. KUPREWICZ: Okay. Boy, I'm losing it.
1 MR. SKEEN: And if you think of anything 2
else we didn't cover or something that you think you 3
need to share with us, please feel free in the next 4
few weeks as we continue our efforts to get through 5
this evaluation.
6 MR. KUPREWICZ: No, I had a list of things 7
and you guys pretty well covered them. That's good.
8 That's a good thing you brought your team.
9 MR. SKEEN: Well, thank you, I appreciate 10 that. And again, thanks for talking with us. And if 11 we have any other questions we may reach out to you 12 again, but if you think of something else that we 13 didn't cover, please let us know.
14 MR. KUPREWICZ: I sure will. You take 15 care now.
16 MR. SKEEN: All right, thank you very 17 much.
18 MR. KUPREWICZ: Bye-bye.
19 MR. SKEEN: All right, bye.
20 (Whereupon, the above-entitled matter went 21 off the record at 2:21 p.m.)
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