ML20087M178
| ML20087M178 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/20/2020 |
| From: | Blanch P - No Known Affiliation |
| To: | NRC/EDO/AO, Office of Nuclear Material Safety and Safeguards |
| Clark T | |
| References | |
| NRC-0866, OIG 16-024 | |
| Download: ML20087M178 (51) | |
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: Friday, March 20, 2020 Work Order No.: NRC-0866 Pages 1-50 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + +
4 STAFF'S RESPONSE 5 ---------------------------x 6 In the Matter of: :
7 CONCERNS PERTAINING TO GAS :
8 TRANSMISSION LINES AT : OIG Case No.16-024 9 INDIAN POINT NUCLEAR POWER :
10 PLANT :
11 ---------------------------x 12 Friday, March 20, 2020 13 14 Teleconference 15 16 NRC STAFF PRESENT:
17 DAVID SKEEN, Team Lead; Deputy Director of 18 International Programs 19 THERESA CLARK, Program Manager 20 SUZANNE DENNIS, RES/DRA/PRAB 21 DR. YUEH-LI "RENE'E" LI, Office of Nuclear Reactor 22 Regulation 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 ALSO PRESENT:
2 PAUL BLANCH, Citizen Stakeholder 3 TINA BONGAR, Resist Spectra 4 MICHEL LEE, Council on Intelligent Energy and 5 Conservation Policy 6 STEVE NANNEY, Pipeline and Hazardous Materials 7 Safety Administration, DOT 8 AMY ROSMARIN, Stop the Algonquin Pipeline Expansion 9 SUSAN VAN DOLSEN, Stop the Algonquin Pipeline 10 Expansion 11 NANCY VANN, Safe Energy Rights Group 12 ELLEN WEININGER, Grassroots Environmental Education 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 1 P R O C E E D I N G S 2 1:02 p.m.
3 MR. SKEEN: Hello, this is Dave Skeen.
4 This is the 1:00 call to discuss the evaluation team's 5 review of the IG findings with Paul Blanch. Who else 6 do we have on the line?
7 MS. LI: Rene'e Li, from NRC.
8 MS. CLARK: Theresa Clark, from NRC.
9 MR. BLANCH: And Paul Blanch, a citizen 10 stakeholder.
11 MR. SKEEN: Thanks, Paul.
12 MR. NANNEY: And Steve Nanney, US DOT, 13 PHMSA.
14 MS. DENNIS: This is --
15 MR. SKEEN: Thanks, Steve.
16 MS. DENNIS: -- Suzanne Dennis, with the 17 NRC.
18 MR. SKEEN: Okay. I don't hear others. I 19 think with the court reporter, we should probably each 20 state our names and spell it for him, so that he, as 21 we're speaking, he'll know who to attribute comments 22 to.
23 So, I'll go first. My name is David 24 Skeen, it's S-K-E-E-N. And I'm the team leader for 25 the evaluation team that's looking into the Inspector NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 General's event inquiry.
2 MS. CLARK: This is Theresa Clark, T-H-E-R-3 E-S-A, last name Clark, C-L-A-R-K. And I'm Dave's 4 deputy on the NRC team.
5 MS. LI: This is Rene'e Li, my official 6 name is Yueh-Li Li, spells Y-U-E-H, dash, L-I, last 7 name Li, L-I. And I'm from NRC.
8 MR. BLANCH: You're from where?
9 MS. LI: NRC, Nuclear Regulatory 10 Commission.
11 MR. BLANCH: Okay. And my name is Paul 12 Blanch, B-L-A-N-C-H, and I am the concerned 13 stakeholder that was discussed in the OIG report.
14 MS. DENNIS: Hi, this is Suzanne Dennis, S-15 U-Z-A-N-N-E, last name Dennis, D-E-N-N-I-S.
16 MR. BLANCH: And where are you from, 17 Suzanne?
18 MS. DENNIS: Oh, I'm from the Nuclear 19 Regulatory Commission. Sorry about that.
20 MR. BLANCH: Okay.
21 MR. SKEEN: So, who else do we have? I 22 know there's other folks.
23 MS. ROSMARIN: This is Amy Rosmarin, and 24 I'm just listening. I'm with Stop the Algonquin 25 Pipeline Expansion.
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5 1 MR. SKEEN: Okay, thank you.
2 MS. VAN DOLSEN: This is Susan Van Dolsen, 3 I'm also with Stop the Algonquin Pipeline Expansion 4 and listening. I'm going to go on mute.
5 MR. SKEEN: Thank you.
6 MS. VANN: I'm Nancy Vann, I'm with Safe 7 Energy Rights Group, and also just listening.
8 MR. SKEEN: Okay, thank you.
9 MS. BONGAR: And hi, I'm Tina Bongar, and 10 I'm with United for Clean Energy/Resist Spectra. And 11 I'm just listening.
12 MR. SKEEN: Okay. Is there anyone else on 13 the line?
14 MS. LEE: Yes, this is Michel Lee, with the 15 Council on Intelligent Energy and Conservation Policy, 16 also just listening on mute.
17 MR. SKEEN: All right, thank you.
18 MS. WEININGER: Ellen Weininger, and I'm 19 with Grassroots Environmental Education, and I'm just 20 listening. Thank you.
21 MR. SKEEN: Okay. Is that everyone? I 22 don't hear anyone else.
23 MR. BLANCH: I thought we were going to 24 have someone from New York State. Amy, you said you 25 were going to be in contact, are they participating?
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6 1 MS. ROSMARIN: I just, I sent them an 2 invitation and haven't heard back. I gave them the 3 call-in information. But the timing was pretty short.
4 MR. BLANCH: Yes, I know. Okay. Who wants 5 to start?
6 MR. SKEEN: Okay. Well, thanks, Paul. So, 7 let me just get the thing started here.
8 So, as I said, I'm part of a special team 9 that the Nuclear Regulatory Commission put together to 10 evaluate the Inspector General findings from the event 11 inquiry related to the 42-inch gas pipeline that runs 12 near Indian Point Energy Center.
13 I was tasked to put together a team of NRC 14 and external experts to evaluate the findings and to 15 provide a report back to the Commission within 45 days 16 on the findings, on our evaluation of the Inspector 17 General's findings.
18 And so, we have both internal experts, as 19 well as external experts, on our team that are looking 20 into the findings from the Inspector General.
21 So, with that, the purpose of this call 22 was to talk with Paul Blanch today. I know Paul was 23 the concerned individual that was involved in some of 24 the activities related to the gas pipeline and the 25 2.206 Petition that was provided to the NRC.
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7 1 And so, we want to hear his thoughts, make 2 sure that we have all of his concerns as part of our 3 efforts, as we go forward. And so, with that, I 4 wanted to talk with Paul about, to make sure we 5 understood his concerns that he has raised thus far.
6 And I know, Paul, you had sent something 7 in to us with a draft letter that you had, and maybe 8 we should go and start with that, maybe the best thing 9 to walk through that with you.
10 MR. BLANCH: Yes. That's what --
11 MR. SKEEN: And then, we have --
12 MR. BLANCH: That's what I --
13 MR. SKEEN: -- some particular questions --
14 MR. BLANCH: -- would like, too.
15 MR. SKEEN: -- we wanted to ask as well.
16 So, if that's okay with you, and the team, I have the 17 team on the line with me, so if there are specific 18 questions or clarifications we need as you go through 19 some of your concerns, we'll try to make sure we 20 capture those as we go forward.
21 MR. BLANCH: Okay. What I -- it was a 22 draft letter, and I know anything sent to the NRC, 23 draft or not, is going to go into ADAMS. That's fine.
24 I was just trying to give you a heads-up, 25 because there were probably editorial mistakes in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 there and so on and so forth. But the concept of the 2 letter remains the same. I do not know whether you 3 distributed it to the rest of your team.
4 MR. SKEEN: Yes, the team has seen it. I 5 forwarded that to them when you sent it, because I 6 thought it would help the discussion this afternoon.
7 So, we have at least seen it.
8 But if you wanted to walk us through, to 9 make sure we've got your concerns. I think a lot of 10 what is in your letter was already part of our 11 efforts, but I just want to be sure, as we talk with 12 you, that we've captured everything. So --
13 MR. BLANCH: Okay.
14 MR. SKEEN: -- if you want to go ahead, 15 please do.
16 MR. BLANCH: Yes, do you have anyone from 17 Sandia online? On the line?
18 MR. SKEEN: I don't believe Sandia is on.
19 I know they were doing the computer runs, but I don't 20 believe that we have them on. Suzanne, did you notice 21 if Sandia was going to be available?
22 MS. DENNIS: Hi, yes, I talked with our 23 experts from Sandia yesterday and they decided, since 24 today was being transcribed, they would look over the 25 notes and focus on getting the simulations done, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 hopefully before this weekend.
2 MR. SKEEN: All right, thank you. So, 3 Paul, no, we don't have Sandia with us this afternoon.
4 MR. BLANCH: Okay. Well, I sent that 5 letter just so your team could digest where I'm coming 6 from, and for those others listening to it, they have 7 not seen my draft letter, but it's my comments on a 8 official NRC document that was put out on March 18, 9 which is basically the scope of the team.
10 And I think it would be best if I just 11 read the letter and we could stop after each 12 paragraph, if there are questions. So, if that's 13 okay, to get it into the record, I know it will be 14 part of the record anyway.
15 I say in my letter, it's addressed to 16 David Skeen, it appears the team's direction is to 17 have Sandia National Labs perform a risk analysis.
18 I have no problem with this approach, 19 however, I question, quote, analyzing natural gas 20 pipeline rupture phenomena and consequences, which was 21 in Dave's outline, as the sole guidance, when there is 22 clear federal law and regulations as to how to 23 evaluate the pipeline's impact on public safety.
24 I want a structured approach for risk 25 assessment, is basically what I'm saying. And the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 only one that we can fall back on is what is in the 2 federal law.
3 And then, I go on and state the PHMSA's 4 mission is to protect, is pipeline safety, no doubt 5 about that. NRC's mission is nuclear safety and 6 providing adequate protections to the public health 7 and safety. PHMSA does not regulate the NRC or 8 oversee the NRC, and the same way, the NRC doesn't 9 oversee PHMSA.
10 So, I go on to say, from the enclosed 11 direction, it appears the NRC is about to charter 12 Sandia to conduct yet one more risk assessment. We've 13 had risk assessments conducted by Entergy, Algonquin, 14 NRC, PHMSA, State of New York, myself, and then, 15 there's another one that got lost by the NRC that's on 16 a CD somewhere.
17 We've had enough attempts on risk 18 assessment and have everyone thinking, this is what we 19 think we need. I go on to say, there is a regulatory 20 and industry consensus of conducting a risk 21 assessment, and that is specified in 49 CFR 192.917 22 and 935.
23 This is the only generally accepted 24 guidance for conducting a risk assessment of gas 25 lines. This went through rulemaking, comments, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 industry comments, this is the consensus of how one 2 does a risk assessment.
3 And I go on to say, quoting in my letter, 4 it is my position that the risk assessment be 5 conducted following the Pipeline Safety Act of 2016 6 and 49 CFR 192. The result must then be reviewed by 7 PHMSA for compliance with its regulations.
8 And then, the NRC, based on that risk 9 assessment, makes the determination of, quote, 10 reasonable assurance of adequate protection of public 11 health and safety.
12 I have just gone through the final 13 Environmental Impact Statement and, Steve, this is 14 probably directed at you. Steve is from PHMSA.
15 Throughout the Environmental Impact Statement, dozens 16 and dozens of times, are statement, total compliance 17 with 49 CFR 192.
18 No exceptions that I have identified.
19 Meaning that, FERC, PHMSA, EPA, in signing off of that 20 document are saying, the regulations of 192, amongst 21 others, have been met.
22 I have tried, communicated, and the reason 23 Amy and Ellen are on here, they have communicated with 24 me and with Karen Gentile of PHMSA, to attempt to get 25 a copy of the risk assessment they said was done. All NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 I got from PHMSA, and this was all in writing and 2 PHMSA has it and I think, Dave, you may have some of 3 it, all --
4 MR. SKEEN: Excuse me, Paul.
5 MR. BLANCH: -- I've gotten are --
6 MR. SKEEN: Excuse me, Paul. Did someone 7 else just come on the line.
8 MS. CLARK: That was Theresa. Somehow my 9 call dropped and now I'm back, sorry.
10 MR. SKEEN: Okay, thank you. I just heard 11 another beep, so I just wanted to make sure we knew 12 who was on the line. Thank you. Go ahead, Paul, I'm 13 sorry.
14 MR. BLANCH: Okay. So, what we have is a 15 document called the Environmental Impact Statement 16 certifying compliance with 49 CFR 192, which is, at 17 best, an inaccurate statement. And something that the 18 NRC's risk assessment may have been based upon.
19 I guess my next question is directed at 20 Steve. And by the way, Rick Kuprewicz, our common 21 associate says very good things about you. Has there 22 been a risk assessment done for the pipelines at 23 Indian Point that are in compliance with PHMSA 24 regulations? And if so, how do we get a copy?
25 MR. SKEEN: So, Steve, are you on the line?
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13 1 MR. NANNEY: Yes, I'm listening. Dave, do 2 you want me to answer?
3 MR. BLANCH: Yes, I'd like to.
4 MR. SKEEN: Yes, if you could answer that, 5 that's fine. Like I say, that's more of a PHMSA than 6 an NRC question, I guess --
7 MR. BLANCH: Well, they're all --
8 MR. SKEEN: -- so, if you can --
9 MR. BLANCH: -- tied together.
10 MR. SKEEN: -- answer, that would be fine.
11 MR. NANNEY: Well, first of all, you're 12 asking has one been done? But I can answer you this 13 way, if you go look at Part 192, Subpart O, it has the 14 regulations of when you have to do assessments of the 15 pipeline.
16 In other words, when you've found it to be 17 a high consequence area, as defined in Part 192. And 18 --
19 MR. BLANCH: Right.
20 MR. NANNEY: -- the parent company that 21 owns the same pipeline is Enbridge. And Enbridge does 22 have a compliant integrity management program.
23 This particular line, this particular 24 location, has Steve Nanney seen the documents? The 25 answer is, no.
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14 1 And because -- I'm listening in today, 2 I've listened in when Richard talked yesterday, 3 because my goal of listening in was to see what the 4 concerns were and to see what my takeaway would be of 5 going back and looking, since I wasn't involved in 6 this back several years ago when it was built and 7 everything.
8 So, that being said, yes, they would have 9 to have a risk assessment on that. A risk assessment, 10 by the code on the new pipeline, the first thing that 11 I would look for would be, did they do a hydrostatic 12 pressure test that met the code?
13 On a new pipeline, that would be the first 14 item to look at, to make sure. And I would be, and I 15 will be going back and asking that question.
16 The other thing, as the pipeline is put 17 in-service and time goes by, would be inline 18 inspection tools run on this pipeline, plus their 19 yearly maintenance activities and patrolling 20 activities.
21 So, to answer your question, yes, I will 22 go back and look at that. What we can actually put 23 out for the public review, I can't say right at the 24 moment what I could actually give you, until I look at 25 the records and everything.
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15 1 MR. SKEEN: So, I appreciate that, Steve.
2 I appreciate that. And maybe, Paul, when we talk 3 about a risk assessment, are we talking about two 4 different things?
5 From an NRC probabilistic risk assessment, 6 a risk-informed process that we have, versus the risk 7 assessment for a gas pipeline may be looking at 8 different things.
9 And I know we've talked about this, what's 10 in the ASME appendix and all of that, but maybe it 11 would be good to make sure we understand, when we say 12 risk assessment, what we're talking about.
13 MR. BLANCH: Okay. This is Paul Blanch, 14 again. I'll try to explain it and, Steve, sorry to 15 put you on the spot here, because you're relatively 16 new to this.
17 But the clear requirements, Steve, in 18 Subpart O of 192 are numerous, as you know. And 19 192.917 and 934 require a very detailed risk 20 assessment. This should be outside of NRC space.
21 I would have expected, if you're 22 installing or if PHMSA is approving the installation 23 of a 42-inch line in the vicinity of two nuclear power 24 plants, that they would do an adequate risk assessment 25 and those results would be presented to the NRC. They NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 could take the results, here are the probabilities, 2 these are numbers.
3 It shouldn't be the NRC doing this, these 4 are the numbers that PHMSA should be coming up with 5 and following the regulations of ASME B31.8, and there 6 are other references, or documents, incorporated by 7 reference.
8 And this is not inconsistent -- has 9 everyone seen the letter from the Attorney General of 10 the State of New York this morning?
11 MR. SKEEN: I have seen that, yes, Paul.
12 MR. BLANCH: Yes. My request is not 13 inconsistent with what the Attorney General of the 14 State of New York is saying.
15 These are -- this is my immediate concern, 16 I've been working on this, as everyone knows, for five 17 or six, maybe more years, and all I get is, oh, I'm 18 going to do my risk assessment my way, and I'm going 19 to do it my way, and we don't even get to see what 20 these risk assessments, and they get lost.
21 And my very strong position is, I want to 22 see a risk assessment, which is PHMSA's 23 responsibility. And I'm not -- it's just like the 24 NRC, PHMSA needs to impose that requirement on its 25 licensees or its regulated pipeline manufacturer.
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17 1 That's the way the NRC does it, they don't 2 do -- it's not their responsibility to do the risk 3 analysis. And it's not PHMSA's, but PHMSA should 4 assure that we are being protected by ensuring 5 compliance with the regulation. Which is the absolute 6 minimum to assure safety.
7 And then, NRC takes that and the NRC 8 decides, does this present a hazard to the nuclear 9 power plant?
10 MR. SKEEN: Okay. So, appreciate that, 11 Paul. And so, I think what we can do, we recognize 12 the concern. Certainly, we can work with Steve and 13 his folks to verify, or confirm if there was this risk 14 assessment done under the Part 49 regulations. So, we 15 can take that. So, appreciate that statement and I 16 think we can move on from there, then.
17 MR. BLANCH: Yes. That is my number one 18 immediate concern. There's a lot of other issues, but 19 that's my priority right now. And from my 20 communications with PHMSA, PHMSA has dropped the ball 21 and has not done a risk assessment.
22 MR. SKEEN: Okay. I think we understand 23 your concern and we'll look at that to see if we can 24 verify that a risk assessment was done under Part 49.
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18 1 like to go from here?
2 MR. SKEEN: So, I think, in the rest of 3 your letter, it does talk about some other things, 4 some of which I think are covered in the IG findings, 5 but if you wanted to kind of step through those, that 6 was the bulletized issues that you had on another page 7 of your draft letter you had shared with me this 8 morning.
9 MR. BLANCH: Yes. Yes, the -- I made a 10 complaint with the Inspector General's Office. And 11 you know the Inspector General does not have adequate 12 budget, personnel, they get a lot of stuff and they're 13 very selective in what they do and the scope.
14 I asked the Inspector General to look at 15 a lot of different things. They didn't look at 16 everything.
17 Now, one of the things I asked them to do, 18 and I've asked the NRC staff, is Entergy made 19 inaccurate, incomplete, I believe, okay, allege, 20 inaccurate, incomplete, in violation of 10 CFR 50.9, 21 and possibly 50.5. That has never been addressed.
22 Let me see.
23 MR. SKEEN: Okay. So, could you clarify 24 just a little bit on the 50.9, where you think it 25 violated 50.9? Just to help us understand --
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19 1 MR. BLANCH: Sure.
2 MR. SKEEN: -- it, please.
3 MR. BLANCH: Well, in their 50.59 4 evaluation, they clearly stated three-minute closure 5 time. That is an inaccurate statement, inaccurate, 6 incomplete statement. I got better words for it, but 7 I'm going to be nice. It's never been looked at by 8 anyone within the NRC.
9 MR. SKEEN: Okay. I -- just stop right 10 there just a sec, Paul. So, I can tell you, as part 11 of our team, we are looking at that, trying to find 12 out where that one to three minutes came from, as 13 well. So, that will be part of what our report covers 14 when we do that. So, we can certainly look at that 15 one.
16 MR. BLANCH: You and I have talked about 17 that, and we think we might know where it is. But 18 getting back to the root cause of the problem.
19 The NRC is allowing, and accepts and 20 defends, A, inaccurate information provided by a 21 licensee, which has just cost us so much time, 22 trouble, cost the State of New York over a quarter of 23 a million dollars to have their own analysis done.
24 And the NRC won't do anything.
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20 1 information, deliberate misconduct, and inaccurate and 2 incomplete information. But you seem not to be 3 willing to ever enforce those laws. And then, let me 4 see what else.
5 MR. SKEEN: Okay. Just so I understand, so 6 you're saying that the fact that they reported this 7 one to three minutes, that is a violation of the 50.9, 8 that's your concern?
9 MR. BLANCH: Yes, it is.
10 MR. SKEEN: Okay.
11 MR. BLANCH: Unless you --
12 MR. SKEEN: That makes --
13 (Simultaneous speaking.)
14 MR. BLANCH: -- a message, with a 15 violation, intentional, criminal, I don't care what, 16 but anyway.
17 One of my things was fuel in the diesel 18 slurries tank. Dave, you and I, I think, I'm 19 satisfied, if Brian told you that those tanks are 20 empty, that's just fine.
21 MR. SKEEN: And for those that aren't 22 aware, we're talking about the storage, the diesel 23 storage tanks that was for Unit 1, that has been shut 24 down for many years.
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21 1 abandoned those tanks, they drained them, they cleaned 2 them out, and they valved them off, so that there's 3 nothing in those tanks any more. We did verify that 4 with the Senior Resident Inspector at the site. So, 5 thanks, Paul, I appreciate that.
6 MR. BLANCH: Yes. But my, as we've talked, 7 Dave, my biggest concern is the existing pipelines.
8 Okay. We have two pipelines, one of them's idle right 9 now and the 30-inch is active.
10 They run very close to the switchgear room 11 and the control room. A leak in one of those pipes 12 could cause unignited methane to migrate into the 13 control room, just a few hundred feet away.
14 If that occurs, and I'm talking a gas 15 leak, like we've all seen in our neighborhoods, but a 16 sizeable one, two-inch or greater, and that gas 17 migrates into, especially the control room and the 18 electrical switchgear room, if that gets in there, we 19 are in big trouble.
20 If you take out the switchgear room, then 21 the danger of core damage, spent fuel pool damage, and 22 all your post-Fukushima fixes would not be available.
23 And that's something that absolutely, that is my 24 number one concern, and that has been conveyed many 25 times to the NRC and ignored.
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22 1 So, the risk assessment not only applies 2 to the AIM pipeline, it also applies to existing 3 pipelines, and that's effective in the year 2004. So, 4 I don't think PHMSA has assured that that has been 5 done. And I don't mean to pick on PHMSA, but I've 6 never been able to get a straight answer from them.
7 MR. SKEEN: Okay. Well, thanks for that, 8 Paul, appreciate that. Now, let me understand just a 9 little bit more. So, when you're talking about the 10 existing lines, would the leak be from the underground 11 part? Because there's not -- it's mostly underground 12 it runs on the site, right? It only comes aboveground 13 --
14 MR. BLANCH: Correct.
15 MR. SKEEN: -- just before it gets to the 16 river, is that correct?
17 MR. BLANCH: Yes. It's underground, it 18 comes up out of the ground by the river and that's 19 where the pig station is. And then, from the pig 20 station, it goes across the site, within the owner 21 controlled area, comes within 300 or 400 feet of the 22 control room, switchgear room, and then goes out. And 23 then, it ties into the AIM pipeline.
24 MR. SKEEN: Okay. So, but your concern 25 would be where the aboveground portion of the piping NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 is? Is that what you're concerned about, a gas leak 2 --
3 MR. BLANCH: Well, it's --
4 MR. SKEEN: -- from a --
5 MR. BLANCH: -- primarily the one, 6 aboveground, whatever could cause gas to leak into 7 those areas. Aboveground, below ground, doesn't 8 matter where the source is. But certainly, this is 9 not something that would be acceptable in today's 10 environment, for being built today.
11 MR. SKEEN: Okay. All right. I --
12 MR. BLANCH: And that --
13 MR. SKEEN: -- think I understand your 14 concern. I'm not sure that was one of the findings of 15 the IG report, but like I say, I want to hear all of 16 your concerns one way or the other, to make sure we're 17 addressing what we need to address and if there's 18 things outside of our scope, I want to make sure that 19 those get addressed as well. So, I don't mind at all 20 pursuing this a little bit --
21 MR. BLANCH: Yes.
22 MR. SKEEN: -- with you.
23 MR. BLANCH: Again, when I wrote to the IG, 24 and I think I gave you this letter, all those concerns 25 were outlined in my letter to the IG dated, it was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 2016, I believe, February somewhere. Those are my 2 concerns, they weren't all addressed by the IG, so 3 that means they're back with the staff.
4 MR. SKEEN: Okay. Okay. I understand, I 5 appreciate that.
6 MR. BLANCH: Okay. Dave, you do have that 7 letter, or I could send it again to you.
8 MR. SKEEN: Well, I think we have that.
9 That was your 2016 letter, right, that you sent in?
10 MR. BLANCH: 2016?
11 MR. SKEEN: Is that -- which one were you 12 referring to?
13 MR. BLANCH: My initial -- yes, 2016, yes.
14 MR. SKEEN: Yes.
15 MR. BLANCH: I think --
16 MR. SKEEN: Yes, we --
17 MR. BLANCH: -- February --
18 MR. SKEEN: -- have that.
19 MR. BLANCH: -- of 2016.
20 MR. SKEEN: Yes, we have that one.
21 MR. BLANCH: Okay. Those are the issues.
22 If the IG didn't address them, then I think the NRC 23 staff needs to close it out. And my final comment 24 here is I have -- this is in my -- you haven't even 25 seen this, Steve, is why I didn't make that a draft.
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25 1 I have extensive experience at Millstone, 2 as you know, Maine Yankee, Indian Point, and other 3 places, and worked with the NRC on safety culture.
4 And I have a limited knowledge of root cause analysis.
5 And if the NRC identified these type of 6 problems at a licensee, they would give them the 7 normal chilling effect letter and they may impose 8 Inspection Procedure 95003 for a total assessment.
9 That's going to be in my final letter to you.
10 And I believe that the NRC has a cultural 11 problem and I think that this definitely needs a root 12 cause assessment, and I know NRC has done these, 13 they've been trained on them. This is a deep rooted 14 cultural problem within the NRC, such as the backward 15 engineering.
16 And I've done it, I will admit, if my boss 17 tells me this is the result that I want, I can go find 18 information supporting that result. That is a 19 cultural problem, I've been a victim of that myself, 20 I've done it.
21 We used to have a document the NRC 22 approved, which is a justification for operations, its 23 name has been changed to something else now. It's 24 basically saying, go find me a solution that I want.
25 Unacceptable.
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26 1 And I believe that the NRC has a severe 2 cultural problem and that needs to be looked at. And 3 you need to look at that Inspection Procedure 95003, 4 see if the NRC fits into that.
5 I know this was not a part of the OIG 6 findings, but from my assessments, somewhat as an 7 expert, even written, Dave, I shared it with you, my 8 paper on safety culture, NRC has a problem.
9 And finally, I support just about 10 everything that was in the letter from the Attorney 11 General from the State of New York dated yesterday, 12 March 19.
13 MR. SKEEN: Okay. I appreciate that. I 14 know we had talked about that, you had mentioned 15 before that you had supported what the Attorney 16 General was sending in, so I appreciate that. And 17 certainly, we can take a look at that and make sure we 18 understand that. Anything else?
19 MR. BLANCH: That's all I have. I will 20 follow up, I'll give you a final copy of that letter, 21 whether you want to keep your draft or not doesn't 22 matter to me.
23 But I will -- before, well, by Monday or 24 Monday night, I will have my final letter out to you.
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27 1 needs to do.
2 And obviously, what Steve said and, not 3 picking on Steve, but I think Steve is going to go 4 back and see if a risk assessment was done in 5 compliance with the regulations. Do I understand that 6 correctly, Steve?
7 MR. SKEEN: Well, we can certainly do that 8 as part of our efforts. I mean --
9 MR. BLANCH: Okay.
10 MR. SKEEN: -- Steve's on the team with us, 11 so we'll make sure that we address that, Paul, because 12 we had been looking at that ourselves, surely there 13 must have been a Part 49 risk assessment done.
14 And we're just trying to uncover that 15 ourselves, to make sure that that was done anyway.
16 So, appreciate your concerns on that, we were kind of 17 heading that direction anyway. So, we'll see what we 18 can find out on that one.
19 MR. BLANCH: Okay. Your job becomes much 20 easier if you can find one that meets the requirement.
21 MR. SKEEN: Yes, I understand, certainly.
22 MR. BLANCH: And -- yes.
23 MR. SKEEN: Go ahead.
24 MR. BLANCH: And I just want to say this, 25 Sandia is involved. I have no problem whatsoever with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 1 Sandia. If Sandia is directed to go out and do a risk 2 assessment in accordance with the requirements, I have 3 no problem with that, as long as they're in compliance 4 with the requirements.
5 MR. SKEEN: Okay. Thank you for that, I 6 appreciate that too. We did want to talk about some 7 of the NRC process issues.
8 MR. BLANCH: Sure.
9 MR. SKEEN: That's one I think that we can 10 -- we need to have a good understanding of that as we 11 go forward, if the agency is going to try to do 12 something about some of our processes. So, I do want 13 to touch on that with you as well.
14 MR. BLANCH: Yes. Well -- yes. There's 15 one other technical thing I need to address, do you 16 mind, Dave?
17 MR. SKEEN: No, please, go ahead.
18 MR. BLANCH: Okay. The -- I had sent you 19 our calculations done by Dave Lochbaum and a few other 20 people. And they're the calculations that were done 21 based on the equation provided in Regulatory Guide 22 1.91.
23 And I asked four different people and we 24 all came up with similar results, that go out greater, 25 the blast pressure greater than one pound going out NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 1 beyond 4,000 feet, or whatever the number, you got the 2 information.
3 But the ASME document that is incorporated 4 by reference also has an equation for calculating the 5 impact radius. Okay. It's a different equation, 6 comes up with a completely different result.
7 The purpose of the PIR equation in ASME 8 B31.8S is to determine the high consequence area. You 9 come up with a number, it could be 660 feet, it could 10 be a thousand feet.
11 Its only purpose is to calculate the area 12 that is covered by high consequence area requirements.
13 It's not meant to say that if you're at more than 14 that, you're not going to be in danger, which is what 15 the NRC equation is.
16 The intent of both equations, I thought 17 was the same thing, but it's not. So, just be aware 18 of that. I have no problem with the NRC's equation.
19 MR. SKEEN: Well, I appreciate that, Paul.
20 That's one thing we were looking at, was the Reg Guide 21 1.91, to see if it was clear or if there's things that 22 maybe it needs to be clarified in some way in how to 23 apply that. So, appreciate that information that you 24 provided to us.
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30 1 there.
2 MR. SKEEN: Oh, no, that's fine. That's 3 okay. So, those are the kinds of things we want to 4 hear, right? Because to me, that is process, if 5 you're telling me that some of our procedures may not 6 be clear or appropriate. So, that's what we're 7 looking at as well, as part of our effort.
8 MR. BLANCH: Yes, I'm saying Reg Guide 1.91 9 equation is very clear. You just have to plug in the 10 numbers and go. I haven't had a problem with it.
11 MR. SKEEN: Okay. So, you think 1.91 is 12 okay the way it is?
13 MR. BLANCH: I think so, unless you guys 14 see something wrong with it.
15 MR. SKEEN: Well, we'll look into that and 16 see. That was one that we wanted to make sure we 17 understood. So, I appreciate your input on that, 18 that's good.
19 What if we turn to the 2.206 process now?
20 I know that you've had some concerns with that over 21 the years, so if you could kind of enlighten us a 22 little bit more on some of the concerns with that 23 process?
24 MR. BLANCH: Yes. That process, and I've 25 probably filed five, over my lifetime. And the first NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 thing we get is a, we've rejected because, or we don't 2 see any immediate problem. I've got one in the works 3 out at Southern Cal Edison right now.
4 So, we get an immediate response from the 5 NRC, we don't see any problem. And this gets back to 6 the culture, okay? They've already made a 7 determination, there's no problem, and then, the NRC 8 sends its Petition Review Board out, okay, come and 9 support my conclusion I've already done here.
10 It's, again, getting back to the IG's 11 statement about backward engineering. It's a real 12 problem and we've faced it time and time again. I had 13 a very well thought out petition, well, not only this 14 one on the pipeline, but we had one that I filed with 15 Arnie Gunderson on Vermont Yankee and tritium leaks.
16 And it's just that if we look historically 17 at 2.206 petitions, the number of them in the last 20-18 30 years has been 400, either -- many of them may be 19 not valid, but many of them are valid, but they've all 20 been rejected. There might have been two that have 21 been partially accepted.
22 So, one's chances of getting a 2.206 23 petition granted, even though it comes from people 24 with credibility, and I say credibility, Dave Lochbaum 25 has credibility, I have credibility, Arnie Gunderson NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 has some credibility, everything's always rejected.
2 Something's wrong with it.
3 If a licensee comes in and makes a request 4 to change something, to reduce safety margin, it's 5 always, it's never rejected. We just get the feeling 6 that the NRC is not protecting the public by not 7 listening to our 2.206 petitions.
8 I mean, how many years did we spend on 9 this one that I put in? And no one has pointed out 10 why it was wrong. Something is wrong within the 11 agency that essentially they automatically find a way 12 to reject petitions from the public on safety issues.
13 And sometimes, these members of the 14 public, like myself, have as much, if not more, 15 expertise than the NRC staff has. So, anyway, that's 16 the general complaint I have. I'm not sure how we 17 address that.
18 MR. SKEEN: Okay. No, I appreciate that, 19 Paul, it's good feedback. And that's something we're 20 looking at too, is how does the NRC handle the 2.206 21 petitions that we get in and are we being true to our 22 processes? And so, I do appreciate your input on 23 that.
24 MR. BLANCH: Yes, and that goes back a long 25 way, to 1993, when I was working with Senator NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 Lieberman and Dan Berkovitz, who was his chief of 2 staff on the committee, and we were working on the 3 2.206 process and should that have the ability to 4 appeal the NRR director's decision?
5 And because of the politics at the time, 6 there's no legal appeal to a director's decision on 7 that. So, when a director says, no, this is not a 8 problem, we have no way to appeal.
9 I know that's a Congressional issue, it's 10 part of the Atomic Energy Act, but it's obviously 11 something that irks me. But on a positive side, 12 you're one of the few agencies that does have a 13 petition process. Okay.
14 I think those are big issues. I don't 15 think we need to get into specific, but the culture is 16 bad, and I understand that, we've seen cultural 17 problems in a lot of regulated industries. We've seen 18 the Boeing recently. We've seen airline industry.
19 You look at NTSB studies and stuff, you see cultural 20 problems identified.
21 So, those are my concerns, you know where 22 my priorities are and you know what I think has to be 23 addressed.
24 MR. SKEEN: Yes, no, I appreciate that.
25 But another thing I wanted to raise with you as well, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 1 Paul, is what about the interactions among the 2 different agencies, the government, and dealing with 3 the different agencies? As far as communication or 4 understanding the roles and responsibilities of the 5 various agencies, did you see any issues with that in 6 your --
7 MR. BLANCH: No, I don't. I don't know 8 what it is between PHMSA and FERC and EPA, but I can 9 say I think the interactions on a subject like this, 10 of putting a 42-inch gas line next to a nuclear power 11 plant, from an outsider's observation, there was no 12 communication with PHMSA, with the licensee.
13 Now, there's a big problem. It's probably 14 very rare that two agencies are facing such an 15 overlapping problem. But on something like this, my 16 God, there has to be some good communication and open 17 communication. What is the risk of this line? What 18 harm's it going to do?
19 And NRC, I'm not saying it's all NRC, but 20 NRC should have been communicating with PHMSA all 21 along on this thing, to assure that the public is 22 adequately protected, not only from gas lines, but 23 from its impact on nuclear plants, or potential impact 24 on nuclear plants. You could have gotten ahead of the 25 curve with proper communication back in 2014, I think.
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35 1 And the fact that you just blindly 2 accepted Entergy's 50.59 analysis, without question, 3 is inexcusable. And that question could have gone 4 from the NRC to PHMSA, hey, is this three minutes 5 really possible?
6 You, Dave, as an engineer, and me, as an 7 engineer, and every other engineer, including Rick 8 Kuprewicz, and I'm not sure that Steve will even 9 disagree, that the time to identify a leak at a 10 minimum is 30 minutes, from 920 documents I've looked 11 at from PHMSA.
12 And someone not being able to recognize 13 that false statement by Entergy is unforgivable. And 14 they --
15 MR. SKEEN: Okay.
16 MR. BLANCH: -- ought to pay a price.
17 MR. SKEEN: No, I understand, I understand 18 your concern there. But, I guess, as far as the 19 communications, was it -- apparently, from the 20 outside, it looks like there were no communications 21 among the agencies at all.
22 And so, that's what I'm wondering, is it 23 a public communication issue, that we're not doing 24 enough to communicate with the public? Or is it an 25 internal interagency issue of communications between NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 agencies?
2 MR. BLANCH: Well, I don't know the 3 interactions between agencies, I have -- that 4 information is never made public or I never see it.
5 I've never seen any formal communication between the 6 NRC and PHMSA or FERC or anything like that. So, yes, 7 our perception, there is none. And believe me, we've 8 tried to get it.
9 MR. SKEEN: Okay. That's helpful 10 information too, so I appreciate that piece as well.
11 MR. BLANCH: Okay. Anyone else?
12 MR. SKEEN: Well, I want to make sure that 13 the team, because I'm doing all the talking here, but 14 a lot of the team has a lot of the technical 15 capabilities, so I want to make sure I leave a chance 16 for other folks to, if they have clarifying questions 17 or maybe something that they've been working on that 18 they want to make sure they understand from you.
19 So, if you're okay, I'll open it up and 20 let Theresa go first. And then, ask if other team 21 members might have questions or explanations for you.
22 Let's do that. Theresa?
23 MS. CLARK: Hi, Paul, this is Theresa 24 Clark. Thanks again for taking the time to talk to 25 us, I think this has been really helpful to hear in-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 person, or virtually in-person at least --
2 MR. BLANCH: Right.
3 MS. CLARK: -- what some of your concerns 4 are. I have a couple of questions, a couple of 5 process ones, I think, and then, technical ones.
6 We're quite interested in both angles of this, it's 7 what the Chairman asked us to look at.
8 One thing that you just mentioned about 9 proper communications that we could have had back in 10 2014, one of the things I've been struggling with in 11 putting together the documents that we might include 12 in our report is that some of the analyses that were 13 done had security related information in them, when we 14 were talking about specific distances from here to 15 there, for example.
16 And it seems like that may have 17 complicated some of our communications on these 18 issues. Do you have a perspective on that?
19 MR. BLANCH: Yes, I do, because I have 20 received from FERC, over Algonquin's objections, I 21 have received CEII clearance from FERC. I've conveyed 22 that to the NRC. So, that should not have been a 23 problem with those people. I know Rick Kuprewicz also 24 has CEII clearance.
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38 1 security issues, terrorism issues, and so on, that may 2 contain CEII, but not most of it. And as I say, I 3 have that clearance.
4 MS. CLARK: Thanks, Paul, that's helpful.
5 What about how we communicate these issues to the 6 broader public, who don't have those clearances? Are 7 there ways that we could communicate better on these 8 topics without getting into details that we shouldn't?
9 MR. BLANCH: Sure, I think that you could 10 hold public meetings and say, hey, we've addressed 11 terrorism, we've addressed EMP, whatever else might be 12 considered CEII information.
13 And if you got before the public and said, 14 hey, we've looked at these, it's security related or 15 CEII related, but I provide you my assurance that we 16 have looked at it and we're satisfied with it, that's 17 never been done.
18 MS. CLARK: Okay. That's fair, thank you.
19 So, you mentioned a couple minutes ago about documents 20 that you had looked at from PHMSA, I think you said a 21 number of 920, I didn't know if that was a number of 22 documents or a specific document, on valve closure 23 times. Are there specific references that you want to 24 offer to us?
25 MR. BLANCH: Sure, I've sent Dave a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 1 spreadsheet. Correct, Dave?
2 MR. SKEEN: Yes, we have the spreadsheet 3 that you sent on the pipe rupture data.
4 MR. BLANCH: Yes. That is, I'm not sure 5 how far it goes back, but I think there were 921 6 events identified by PHMSA and it provides location, 7 latitude, longitude, size of the leak, did it 8 explode?, did it not explode?, time identified, time 9 event occurred. You've got it all. And that is not 10 Paul Blanch's data, that is on PHMSA's website.
11 MS. CLARK: Okay, Paul, I was confused 12 about that. Yes, we definitely have that spreadsheet.
13 I couldn't remember whether that spreadsheet included 14 data that would let us calculate how long it took to 15 detect and isolate these issues.
16 MR. BLANCH: Yes, it does.
17 MS. CLARK: Okay, thanks. We'll take 18 another look at that. And then, I guess --
19 MR. BLANCH: There's so --
20 MS. CLARK: -- my last --
21 MR. BLANCH: -- many columns --
22 MS. CLARK: Go ahead, please.
23 MR. BLANCH: -- of data, so many columns of 24 data, you're going to have to parse it and sort it and 25 everything, which I've done, and that's how I found NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 out there's --
2 MS. CLARK: Okay.
3 MR. BLANCH: -- anywhere from 30 minutes to 4 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> --
5 MS. CLARK: Okay.
6 MR. BLANCH: -- for a response time.
7 MS. CLARK: Understand. Thank you. And I 8 guess, I want to give other folks some air time here, 9 but you mentioned a few minutes ago about the Reg 10 Guide 1.91 equations and the calculations that you and 11 some of the others had done using those.
12 And I think the number that you mentioned, 13 knowing that it wasn't necessarily the exact number, 14 was something like a 4,000-foot radius.
15 I wanted to clarify, is that -- your point 16 was that this was the number that you got using our 17 equation, so it raised some questions in your mind, or 18 were you concerned that that was, perhaps I'm not 19 saying this the right way, but the radius of concern 20 for the plant?
21 MR. BLANCH: I didn't --
22 MS. CLARK: Am I making sense?
23 MR. BLANCH: -- look into the derivation of 24 the equation in Reg Guide 1.91. I'm ex-Navy reactor 25 operator and degreed electrical engineer, understand NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 all that stuff.
2 But when I did the calculations, given the 3 gas flow through that line, assuming that comes out, 4 I did a plot, as Dave Lochbaum did and Joe Carson, 5 Larry Criscione, we all came up with the same numbers 6 and they all go out thousands of thousands of feet.
7 And that's just for the pressure pulse.
8 We did not use ALOHA, we used your 9 numbers, and we all came up with a similar thing. Is 10 that right? I don't know, but that's the only thing 11 we could go by, we're not gas experts.
12 MS. CLARK: Okay. I think I understand, I 13 just wanted to clarify that. So, do you have a feel 14 for whether you think there would be impacts at that 15 distance? Or is the point that you're making more 16 specific to how the equation works?
17 MR. BLANCH: Well, the equation works such 18 that it predicts the impact going out, based on the 19 gas flow and time.
20 And that's what the results of the 21 equation say, that the impact, depending on the amount 22 of time it takes to isolate the leak, goes out this 23 far. And I would assume it includes pressure pulses, 24 heat flux, vapor clouds, and so on and so forth. I 25 don't know the derivation of your equation in 1.91.
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42 1 MS. CLARK: Okay. Thanks, Paul. And 2 that's why I have smart people helping us out, because 3 I don't think I do either, at this point. But I'm 4 learning a lot.
5 MR. BLANCH: I'm not the only dumb one 6 here, huh?
7 MS. CLARK: Hey, I didn't say I was dumb.
8 (Laughter.)
9 MR. BLANCH: I'm saying I am.
10 MS. CLARK: Just kidding. Okay. I think 11 that's everything I have this second. Dave, you want 12 to call the next person?
13 MR. SKEEN: Yes. Suzanne, did you have 14 anything that you wanted to raise?
15 MS. DENNIS: Yes. Hi, Paul, this is 16 Suzanne Dennis. I was looking over the calculations 17 that you had sent to Dave about what other people had 18 seen using those Reg Guide 1.91 calculations.
19 MR. BLANCH: Yes.
20 MS. DENNIS: The minutes that were used 21 differed. And so, I was just wondering how the 22 timings were chosen for those expert evaluations, or 23 if you just had asked, hey, take an independent look 24 at this and let me know, and each expert kind of 25 picked?
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43 1 MR. BLANCH: Well, what I did, I told Dave 2 and Larry and Joe to, hey, here's the equation, here's 3 the flow rate, what's the impact radius, based on the 4 1.91 equation? And we all came up with numbers that 5 are plus or minus 20-30 percent. So, they're ballpark 6 numbers.
7 MS. DENNIS: Okay. All right. Yes, that's 8 very helpful, thank you. And then, as our resident 9 risk analysis expert, I just wanted to, one, ask for 10 some clarification and maybe provide some 11 clarification too.
12 So, at the NRC, when we talk about risk 13 assessment, we're usually talking about probabilistic 14 risk assessment, so not only the consequence, but also 15 the frequency of the event occurring.
16 And I think, and Steve can correct me if 17 I'm wrong here, but the PHMSA risk assessment that is 18 in the regulations isn't quite that. It's more making 19 sure that the pipeline operators have taken steps to 20 ensure that there is limited risk.
21 So, essentially, trying to lower that 22 probability portion of the equation. And I think at 23 NRC, we're kind of looking at risk a little 24 differently. So, I didn't know if you had any 25 thoughts on that or Steve had any thoughts on that.
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44 1 MR. BLANCH: I briefly looked at the 2 regulation 917, 935, and I briefly looked at the ASME 3 B31.8 document.
4 And what I got out of the ASME document 5 is, here are 22 scenarios that you must evaluate, from 6 tornado to flooding to ice age to global warming to 7 vandalism, didn't use the word terrorism. And those 8 are probabilistic, more than consequences, I think.
9 I don't know how -- I mean, that damn 10 document is 800-page long, but that's the document 11 that was approved by the industry.
12 MS. DENNIS: Got it, understood.
13 MR. SKEEN: Any other questions, Suzanne?
14 MS. DENNIS: No, that's all I have.
15 Thanks, Dave.
16 MR. SKEEN: Rene'e, did you have any 17 questions?
18 MS. LI: Yes. Paul, I would like to get 19 some clarification on the calculation that we got, or 20 I got, today, if they are thorough calculation.
21 And I noted that, in one of the table, 22 that you calculate, it's a table that lists for the 23 Indian Point blast radius calculation. And then, the 24 first column is time in minutes. And then, there's a 25 column that describe the mass of vapor. So --
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45 1 MR. BLANCH: Correct.
2 MS. LI: -- like the first minute is 3 376,000 kilogram. And then, for the two minutes, 4 because the increase by 200,000 kilogram, so it become 5 576,000. And then, the next minute, it increase by 6 100,000, resulting in 676,000. And there, after that, 7 every minute, you would increase by 100,000.
8 So, that's this table and it's consistent 9 with the number that in the calculation by Dave that 10 use this and then, used the Reg Guide 1.91 equation to 11 calculate the radius.
12 But I noticed that in Joe Carson's 13 calculation, I think that use a different approach, 14 assuming average flow rate of 1,877 kilograms per 15 second and last for six minutes. So, that's 360 16 seconds. And times this two number, it come up with 17 approximately same as the three minutes in the other 18 two calculation, it's about 676,000.
19 And therefore, all the calculation using 20 the Reg Guide 1.91 equation result in a pretty 21 consistent radius, blast radius.
22 And I'm just wondering, the two different 23 assumption, one is the average flow rate times the six 24 minutes and the other one just has for one minute, 25 what's the release of mass, and the three minutes, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 1 after three minutes, it come up with a pretty same 2 mass of vapor. Do you have some thought about what's 3 behind these two consideration?
4 MR. BLANCH: Yes, I do. It was from a 5 document, an email from Dave Bellio, who's NRC staff, 6 and it should have been redacted. It was redacted one 7 FOIA request, but unredacted in another.
8 And Dave Bellio actually gave the flow 9 rate in dekatherms for minute for various times. So, 10 I used those numbers from Dave Bellio. If you don't 11 have them, I could probably find them with a little 12 bit of effort.
13 But those are the numbers that I used when 14 I calculated it. I can't say for sure that Dave 15 Lochbaum and Larry and Joe used the same numbers, but 16 I would suspect they did. So, those numbers were 17 given to me by the staff.
18 MS. LI: I see. Thank you. Yes, I just 19 wondering, because one is accounting for three 20 minutes, the other is six minutes, but somehow it come 21 out with the same mass of vapor.
22 MR. BLANCH: Yes, I didn't go over the 23 details of the other engineers' calculations. So, 24 sorry, but I can't give you a definitive answer, other 25 than we used David Bellio's numbers.
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47 1 MS. LI: Okay, thank you.
2 MR. BLANCH: You're welcome.
3 MR. SKEEN: Yes, thanks for that, Paul. I 4 know it was fairly technical for other folks to hear, 5 but I know Rene'e was looking at the calculations that 6 you had provided. So, we thought this was a good 7 opportunity to ask a question of that, too. So, I 8 appreciate you being able to answer that for us.
9 Anyone else? Steve, did you have any 10 questions you wanted to raise?
11 MR. NANNEY: I just have one clarification 12 I'd like to know. I kept hearing Regulation 1.92 and 13 1.91, and I just wanted to make sure, when I was 14 hearing the 1.92, you weren't by mistake meaning the 15 DOT Part 192?
16 MR. BLANCH: Oh, no, let me clarify. I'm 17 looking at PHMSA Regulation 49.192. Now, under there 18 are subregulations --
19 MR. NANNEY: There isn't a DOT Regulation 20 0.192, there is --
21 MR. BLANCH: No.
22 MR. NANNEY: -- DOT Regulation 192, that's 23 what my clarification was.
24 MR. BLANCH: No, the --
25 MR. NANNEY: Were you --
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48 1 MR. BLANCH: The regulation is 49 CFR 2 192.917 and 192.935.
3 MR. NANNEY: Okay. And you also mentioned 4 a calculation you were doing for blast radius of some 5 equation. What equation was that that you were using?
6 MR. BLANCH: I was using the NRC's equation 7 for external threats, including gas lines. NRC will 8 be able to give you them, they're in Regulatory Guide 9 1.91. But you need input to that too.
10 MR. NANNEY: Okay. Thank you.
11 MR. SKEEN: Yes, and we can discuss that, 12 Steve. That's in our own Reg Guide, so we can 13 certainly discuss that with you.
14 MR. NANNEY: Okay. Thank you.
15 MR. SKEEN: So, no other questions?
16 MR. BLANCH: For an old man, I can remember 17 all those numbers. Been around them long enough.
18 MR. SKEEN: You did very well.
19 MR. BLANCH: Thank you.
20 MR. SKEEN: So, again, Paul, we appreciate 21 you taking the time to talk to us. As you know, we're 22 on this time line to try to get this report to the 23 Commission.
24 I thought it was very important to talk 25 with you today, and with Rick Kuprewicz as well, to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 1 make sure we understand the concerns coming in from 2 you.
3 And we'll certainly take this forward in 4 our considerations as we get ready to write our report 5 and get something to the Commission.
6 MR. BLANCH: I don't envy you guys.
7 MR. SKEEN: I appreciate that, but we've 8 got a good team here. So, between our internal and 9 external folks, we've got some really good experts 10 that we're working on this.
11 MR. BLANCH: Especially the letter from the 12 State of New York, it went to the world.
13 MR. SKEEN: Yes.
14 MR. BLANCH: So, you are --
15 MR. SKEEN: I think, we're aware of that, 16 I think.
17 MR. BLANCH: Thank you, Dave, for your 18 consideration, obviously.
19 MR. SKEEN: Yes, I understand.
20 MR. BLANCH: Okay. I have --
21 MR. SKEEN: Okay. We --
22 MR. BLANCH: -- spoken my piece.
23 MR. SKEEN: Well, we certainly appreciate 24 your time and this gives us some more information to 25 consider as we go forward.
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50 1 And if you have any other issues, I know 2 you're not shy about letting me know if you have other 3 issues coming along or concerns. So, certainly feel 4 free to pass anything along that you do have.
5 We do have a few weeks before we have to 6 get the report to the Commission, so if there's 7 anything we can factor in, we'll certainly try to do 8 that.
9 MR. BLANCH: I've never been shy, never 10 been accused of it.
11 MR. SKEEN: Well, thank you --
12 MR. BLANCH: I will do it. I appreciate 13 everyone's time.
14 MR. SKEEN: All right. We appreciate you 15 talking with us. So, you have a good afternoon and 16 I'm sure we'll be talking with you.
17 MR. BLANCH: You too, ladies and gentlemen, 18 thank you.
19 (Whereupon, the above-entitled matter went 20 off the record at 2:12 p.m.)
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