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