Community Prepared for Pipeline Incident?

Much has been made of the San Juan Hills High School site and the ability of CUSD to to respond to a nearby incident on the 16-inch liquid fuel pipeline. Of course, if such an incident were to occur, the school would be assisted by agencies and resources from the surrounding community. But what of the readiness of the community itself?

This question is of more than passing interest in our area since the three three major rivers (San Juan Creek, Trabuco Creek and Verdugo Creek) cross the pipeline just upstream from the cities San Juan Capistrano, Capistrano Beach and Dana Point. Portions of Laguna Niguel, and Mission Viejo are also affected.


A pipeline rupture and fuel spill into any of these creeks or their tributaries has the potential to spread disaster over a wide area. In the 1988 Bellingham incident, gasoline flowed more than a mile downstream from the point of pipeline rupture and then ignited.


At locations where the fuel pipeline crosses a river, the normal practice is to bury the pipeline deep below the riverbed. For example, at the San Juan Creek crossing, the pipeline was buried 8 to 15 feet below the riverbed that existed at the time of installation in 1988 (this according to authoritative Kinder-Morgan alignment drawings that I have examined). Of course, seasonal erosion of these natural riverbeds is a consideration. The erosive action of river water and threat to the pipeline are exceedingly small, corresponding to unusual storm flows that are both rare and obvious to the pipeline operator when they occur. Thus, the prospect that a pipeline would rupture through action of a river itself is small.

A larger risk is the potential for a pipeline rupture in areas that drain directly into one of these rivers along the path provided for storm water. Damage from digging, an earthquake, or even a railroad accident can result in release of fuel. A flaw in the pipeline itself, corrosion, and improper operation of the pipeline are other potentials. Fuel that escapes will flow downhill along natural water courses and storm drains into the creeks.

Are our community agencies prepared to respond to a report of fuel flowing in one of these creeks? The Orange County Fire Authority has past experience with one such an event, in 1988 when gasoline spilled from a pipeline and flowed down San Diego Creek in Tustin and Irvine. Fortunately, there was no ignition and the Fire Authority performed well in containing the spill in a sparsely-populated industrial area before it reached the Upper Newport Bay. I am told that two of firefighters were permanently disabled as a result of exposure to gasoline fumes as a result of this incident.

It is noteworthy that this incident occurred in an area that was largely undeveloped at the time. The same incident, if it would occur today, would require that large tracts of homes, movie theaters, medical facilities, multi-floor condominiums and office buildings be evacuated. In 1988, the incident was barely mentioned in the newspaper. Today, it would be a disaster of major proportions, with a significantly greater potential for ignition and loss of life.

If the Fire Authority is prepared, our cities appear to be less so. In fact, they appear to be downright uninformed! For example, my inquires at the City of San Juan Capistrano planning and engineering offices produced blank stares. While SJC has an emergency response plan for a whole variety of events from nuclear accidents to tsunamis, there is no mention of the fuel pipeline. The City of Mission Viejo appears to be no better off. I can find no mention of the pipeline in their disaster response plans.

No city appears to possess the maps that have been created by the pipeline operator, Kinder-Morgan, that describe where fuel would flow in the event of a rupture. The Pipeline and Hazardous Material Safety Administration has designated most of Orange County to be a "High Consequence Area" with regard to this pipeline, yet the cities and the county do not acknowledge this risk.

We can can gain from the experience of others. In this regard, a "lessons learned" presentation by the Bellingham, WA Fire Chief is enlightening. The presentation makes it clear that response to a pipeline incident must be carefully coordinated. It is also outlines the potential that a much greater loss of life might have occurred among those who responded, but for luck and quick reactions of a few who realized that they were dealing with a deadly unknown and pulled-back from the immediate area just before the ignition.

Land Use Planning

CUSD was required to consider the risk to SJHHS because it is subject to provisions of Title 5 in the California Code that regulate school construction adjacent to liquid fuel and natural gas pipelines. But other facilities such as private schools, hospitals, convalescent facilities, pre-schools, etc., can (and are) inappropriately located in areas near dangerous pipelines. The location of these activities are regulated by cities and county through land-use plans. So far as can be determined, no city in our area has incorporated the presence of pipelines into their land-use planning. The county also has nothing.

Responsible land-use planning must incorporate the principal that no facility that houses large numbers of people, or that would require assistance in evacuation should be located in an area or along a path that could be directly threatened by a pipeline rupture. In response to a rupture of a liquid fuel or natural gas pipeline, no assistance in evacuation can be provided in areas that are threatened by gas or vapor clouds, or that are located inside the wider radius of exposure to blast or thermal radiation in the event there is a detonation or fire. People in these areas must be able to move to safety without outside assistance.

All the way back in 1990, following the train wreck and subsequent pipeline disaster in San Bernardino, the National Transportation Safety Board wrote a Safety Recommendation to the Mayor of that city. The letter stated:

Although the City of San Bernardino had developed a general plan for land use, which was the framework for decisions by the City on the use of its land for the protection of residents from natural and man-caused hazards, the use of land in proximity to mainline railroads or high pressure pipelines was not addressed in the general plan or in subsequent revisions to the plan. The Safety Board believes that city and county officials should take into account the location of railroads and high pressure pipelines when developing a general plan for land use.

The letter goes on to issue a specific "priority recommendation" that the city make such amendments to its general plan. Almost two decades later, one wonders how this recommendation has been ignored by so many (including the City of San Bernardino). Perhaps the siren song of real estate developers is simply too strong for our local elected leaders?

Back in San Juan Capistrano, we also have to consider a high-pressure natural gas transmission line that runs right through the center of town:


This Southern California Gas facility enters San Juan Capistrano from the north across the street from J Serra Catholic High School, passes nearby the Saddleback Valley Christian School and the adjacent Silverado Senior Living (Alzheimer's) facility, through the densely populated Villas complex and then into the heart of the historic area. As it continues southbound under Alipaz, it passes 900 feet from Kinoshita Elementary School and Marco Forster Middle School before joining the path of the creek and continuing into Dana Point.

Historically, this facility has been located on "the wrong side of the tracks", so to speak. The areas threatened by it were mostly open space and farmland, with a few exceptions. However, over the past two decades, this area has developed dramatically and all of the aforementioned facilities have been permitted to be built in close proximity to this risk because the land-use plan for the City of San Juan Capistrano is silent.

In 2004, the National Academy of Sciences issued a report that provides considerable guidance to communities: Transmission Pipelines and Land-Use: A Risk-Informed Approach. It is recommended reading for our local leaders.
Read more!

How a Democracy Allocates Risk

Last evening, a few of us got a stark lesson in how our democratic institutions deal with risk to the public. In this instance, the subject was the risk posed by the fuel pipeline adjacent to SJHHS.

A workshop was scheduled for 5 PM, a very inconvenient time for most people. Predictably, the turnout was light -- about a dozen members of the public were on hand, along with two dozen district staff, and the district Trustees.

From the outset, this workshop was rigged by Superintendent and staff to produce the desired outcome: approval of their new Pipeline Safety Hazard Assessment. The technique used to obtain this approval was venerable and time-honored, "Keep asking until you get the desired answer."

No new information has become available since the evening two weeks ago when these same Trustees refused to approve the Assessment. Everyone is aware that a technical disagreement exists between CUSD's expert, Dr. Fitzgerald, and another expert, Richard Kuprewicz, yet no effort was made to involve Kuprewicz or any other expert in the workshop.

The resulting discussion was meaningless. There was one expert in the room, a technical dispute, and no way to resolve it since there was nobody qualified to question the one expert.

For my part, I urged the Trustees to consider why they were being asked for their approval. Mr. Carter earlier extorted the Trustees when he stated that CDE would "sooner or later" demand that CUSD return the state money expended to construct SJHHS unless approval was forthcoming. I suggested that if the Trustees were satisfied with Dr. Fitzgerald's Assessment despite the existing technical dispute, they should vote to approve it. On the other hand, if they felt the need to be better informed, they were obligated to demand additional information. I suggested peer review of the report would be one way of obtaining more information.

In his own way, Mr. Carter urged the Trustees to approve the Assessment because he wanted it resolved "before school opened" on September 2. In the same breath, he admitted that issues related to EMF and land ownership would prevent re-opening of the affected athletic field at the school.

A number of parents urged the Trustees to "move on", stating that they were "satisfied" with the report.

Finally, CUSD's attorney Mr. Bergman, provided the Trustees with an incomplete and misleading description of their personal legal obligation and potential liability under the Government Code. He omitted the obligation to make reasonably informed decisions, something that might be questioned under these circumstances.

Without resolving the technical dispute, without discussion of the recent revisions in the Assessment, and without consideration of a single mitigation strategy, this workshop set the stage for the eventual approval of the Assessment later in the evening.

Does the fuel pipeline pose a risk to SJHHS?

In my opinion, we will never know the answer to this question. Trustees were persuaded to certify the safety of the school on the basis of one Assessment. That Assessment concludes that there was "no risk", but of course, this conclusion is based on certain assumptions. Did anyone seriously challenge these assumptions? Yes, they were seriously challenged but Trustees chose to pay no attention.

After formally approving the Assessment, a couple of Trustees did express the desire to obtain a peer review of Dr. Fitzgerald's work. But one Trustee, Ms. Bryson, commented that such a review would be "very costly", though she had no basis for making the statement.

So in the end, we conclude that democracy allocates risk to the public on the basis of expedience and cost. Those of us who thought otherwise were wasting our time. Read more!

Orchestrated Chaos and Broken Commitment

There is considerable speculation that CUSD staff may have submitted the new pipeline safety analysis to the California Department of Education (CDE) before it was approved by the CUSD Board. A document has come my way that appears to confirm this.

This e-mail thread also provides insight into thinking of CUSD staff regarding safety. In fact, I see no mention of it.

The document further supports that fact that Dr. Fitzgerald's appearance at the August 11 Board meeting was unexpected.

"She will be out of town tomorrow through the weekend to attend [redacted] services and wasn't planning on returning Monday unless we specifically need her to attend the meeting. While she has graciously offered to attend, I think it would be unreasonable to ask her to cut short a family trip of this nature. We would have to let her know today if we need her there."

How easily something so innocent becomes so political in the absence of an explanation from those involved!

Notice, if you will, that Dr. Fitzgerald's response to Trustees, dated July 31, was not actually sent to Trustees until August 6. Why would staff delay delivering this information to Trustees?

Lastly, a critical piece of information has not surfaced:

"Also, Greg is preparing a memo for you regarding liability questions which were raised previously."

Where is this memo?

If it was provided to Trustees in closed session, it may be a Brown Act violation. If not, I would call on CUSD to publish this memo on their website alongside the analysis.

I recall that Mr. Carter and Mr. Bergman promised that this entire subject would be handled "transparently", and in "public session". What happened to this commitment? Read more!

Transparency? Information Vacuum Leads to Misunderstandings

As one who raised the pipeline as an issue and has subsequently come across other questions concerning SJHHS, I attended the Board meeting on August 11, to hear what the Board would decide to do with information in their possession, including information that I provided.

It was indeed unfortunate that Dr. Fitzgerald was personally inconvenienced to appear at the meeting. Her presence was entirely unexpected. Board members were told by senior District staff before the meeting that she would not be present.

Once Mr. Carter took the resolution to approve the pipeline analysis "off the table", introduced Dr. Fitzgerald, and suggested discussion only, "to give the Trustees time to consider new information", it was clear that Dr. Fitzgerald's presence was entirely unnecessary and unfortunate waste of her time.

It is not surprising that the Trustees had almost no questions for her. Three Trustees, Christenson, Maddox and Palazzo, had already submitted written questions to Dr. Fitzgerald that were answered in her July 31 memo (on the CUSD website). What all the Trustees knew was that another qualified expert had submitted statements to Trustees that directly contradicted Ms. Fitzgerald's answers.

This contradictory "new" information was compelling enough to get the attention of everyone involved, motivating Mr. Carter to withdraw the resolution of approval. His statement that "the Trustees" need more time was a bit off the mark. It seems more likely that he was motivated by the desire not to see the resolution and study rejected for a second time. This was a prudent move.

Everyone needs more time to consider this whole subject, and we need all available information to do so.

Too bad, but most of the audience was completely clueless about what transpired. The atmosphere was so tense that neither the Superintendent or the Trustees bothered to explain what they were doing.

CUSD took public comment on their website concerning the pipeline study during the past month. None of this material has been published. Senior district staff and Trustees received advance information from me, and from an independent expert, that raised questions regarding the direction of CUSD's pipeline study. None of this information has published. Is this the transparent process that was promised to parents when this discussion started?

Does the school district not have a duty to inform people of the questions related to the SJHHS site?

Many of SJHHS parents who were in the audience at the Board meeting probably thought that the Board’s failure to approve the pipeline analysis would result in pressure to close the school. Why?. These issues were raised long before school adjourned in June (the issues have existed since 2003), yet the 2007-8 school term was allowed to end normally.

When CUSD considers all the SJHHS site issues, a great opportunity exists to forge a corrective plan that everyone would regard as safe, protect the public's $155 million investment, and create a great school site. However, the continuing negative reaction of uninformed SJHHS “supporters” who view this question through a political prism is delaying the day that the issues will addressed and resolved.

In other words, who wants to support San Juan Hills High School?

Shall we continue to wait for CUSD to address pipelines, power lines, property lines, and site size? Shall we continue to standby as they engage in inept negotiations with the owner of the surrounding property?

These issues have existed since 2003, and they remain unresolved yet today. We should all be telling the CUSD Board that five years is long enough to get it right. Read more!

Update4: Pipeline Rupture in Illinois on 8/10/2008

A 20-inch pipeline carrying crude oil from Illinois to Kentucky ruptured sometime Sunday morning. There was no fire. Latest estimates put the amount of oil that has escaped at 5000 bbl (210,000 gallons). The pipeline is owned by Marathon Oil Co.

Robert Calmus, a spokesman for Marathon stated that the pipeline was shut down as quickly as monitors indicated there had been a sudden drop in pressure. "Of course there was some residual pressure in the line," Calmus said. "Our emergency response team is on the scene, and we're still assessing the situation."

Residual pressure? Somebody should inform Mr. Calmus that our expert says that such pressure doesn't exist.

The Evansville Courier & Press carries a brief article on the incident.

The same newspaper offered an update today.

In a later update, the newspaper reports that the EPA has dispatched investigators to the site of the rupture. Additional details are contained in a new article.

In a follow-up, the newspaper reports on the broader implication of the incident. Find the article here.

On October 4, 2008, a newspaper reports that the original estimate of the amount of oil lost during the pipeline breach have been significantly revised upward. See the latest here. Read more!

Outside Review Questions Validity of CUSD Study

In preparation for the Board meeting on Monday night, CUSD Trustees have been provided a memo containing responses to their questions concerning the pipeline adjacent to San Juan Hills High School. This memo was prepared in response to questions posed by CUSD Trustees after receiving Pipeline Safety Hazard Assessment prepared by Dr. Fitzgerald, of The Planning Center.

The following review of Dr. Fitzgerald's memo was prepared by Richard Kuprewicz, President of Accufacts, Inc. Mr. Kuprewicz is an internationally recognized expert in the field of pipeline safety. He was not paid for his review.

Mr. Kuprewicz wrote on Sat, 9 Aug 2008 11:43:33 -0400:

I have had an opportunity to review the memorandum to Superintendent Carter, Greg Bergman, Ron Lebs, dated July 31, 2008 and have the following general observations related to pipelines and the San Juan Hills High School. In a previous email I indicated that too many engineers and pipeline operators do not understand the unique dynamics that can be associated with transmission pipeline releases. Again, my purpose is not to alarm but to insure that informed and prudent decisions related to pipeline risk management are made concerning this very difficult situation. One sure sign of problems associated with very poor risk management approaches is the violation of the physical laws of science governing sound pipeline management and engineering practices, such as those identified below, rebutting some of the observations from the above 7/31/08 memorandum:

Explosive Vapor in the Atmosphere

The statement “Explosion of vapors in the open atmosphere cannot occur under the conditions present at the site.” is in all probability in serious error. While the specific conditions of the site that would prevent explosion are not identified in the memorandum, all forms of hydrocarbons, especially hydrocarbon mixtures, can explode or detonate, even in open fields, under the conditions related to many transmission pipeline releases, especially ruptures. It is a myth reflecting much inexperience, that hydrocarbon releases cannot explosively detonate in the “open,” and cannot generate serious overpressure in such situations. Many models fail to properly capture the critical factors that can result in detonation of pipeline hydrocarbon releases in such unconfined environments. The good news is that blast overpressure forces generated in the open that can be lethal, dissipate with distance quickly. As a result, high heat flux radiation associated with combustion following detonation usually controls the maximum size of the potential impact zone and mortality.

Please note that liquid hydrocarbon pipeline rupture releases are inappropriately modeled by pool or flash fires given the very high turbulence, aerosoling of the liquid, and extreme mixing associated with these very high mass rate releases. The assumption to model a gasoline release as if it where hexane, does not properly capture the release and detonation characteristics of a pipeline release which is moving a highly complex mixture of hydrocarbon compounds such as that in gasoline.

Risk of Asphyxiation

The memorandum statement “There is no risk of asphyxiation with a release from the pipeline in the open atmosphere” is in error. Hydrocarbon release, especially high rate releases from this product pipeline can generate large volumes of heavier than air hydrocarbon vapors which will flow like water settling into low spots displacing air. For individuals in such low spots, death by asphyxiation is a bona fide risk as has been well demonstrated by other pipeline releases with asphyxiation fatalities for individuals located in the “open.”

Danger to Evacuation Routes

The memorandum comment that “there is no conceivable way that fuel could flow onto the school site,” appears to not sync with the terrain and location of the school and surrounding infrastructure as well as previous documents that have been provided regarding this matter. Vapor release of heavier than air-fuel mixtures will quickly flow wherever gravity will take them. It appears that the analysis is ignoring or missing the large vapor generation. Ruptures are highly turbulent aerosoled events. Given the rapid dynamics of such releases, while emergency response plans are needed, no credit should be taken in risk management for emergency responder or other human field responder interaction, as usually such actions come too late to mitigate consequences given the rapid release dynamics. All too often I have observed that crediting emergency response in risk management approaches is a sure sign that the risk approach is fatality flawed!

Sustained Fire

A pipeline rupture explosion followed by fire (or if one is lucky, just a fire event) will not be a fire from a burning pool of liquid generating vapor from “evaporation.” Ruptures are highly turbulent releases of many hundreds of tons of fuel boosting vapor generation from aerosoling in a relatively short period of time. Detonation and or ignition generate tremendously high heat radiation flux and thermal dosages associated with very high mortality. This mortality is especially sensitive for unsheltered individuals such as those who may be in school open fields who will be least likely to survive upon receiving such extreme thermal dosages.

It should be also noted that pipeline hydrocarbon releases do not need an outside ignition source such as a flame to initiate combustion as such releases can generate their own source of ignition (e.g., from static electricity or rock sparking).

Increased Fuel Flow Due to Fluid Compression & Line Packing

All hydrocarbon liquids are compressible in the pressure ranges operated by transmission pipelines and yes the bulk modulus (which is the inverse of compressibility) is indeed approximately 200,000 psi for gasoline. Compressibility must be taken into consideration in all pipeline operations especially as it relates to rupture impact as release rates are substantially increased over pumping capacity because of this factor. While I do not know what position or experience is reflected in Mr. Morones of KM not knowing the term line pack in liquid pipelines, this term is readily used in hydrocarbon liquid pipeline pressure transient analysis/application, pipeline safety design, as well as failure/release dynamics.

Transient effects associated with hydrocarbon compressibility can easily render liquid pipeline leak detection “moot and ineffective” during the critical time or early stages of pipeline failure. Failure to properly account for compressibility/line unpacking seriously extends the time for remote determination and response at a time when system release rates are at their highest, well beyond pump capacity. Failure of KM to understand compressibility and line pack effects raises serious questions and concerns about the stated or implied capability of the KM leak detection system to determine a leak, especially a rupture, within 5 minutes of an event. On liquid pipeline systems 5 minutes is a very short time to pickup signals, determine, and then react to such possible release indicators, even rupture.

Circumstances Under Which Fuel Might Reach the School Site

A closer evaluation of the pipeline, the terrain, and the school are called for, in which realistic release volumes and surface flow characteristics and patterns (especially for vapor) as a function of time are properly stated and evaluated to confirm whether the memorandum statement “there is no physical way for product to reach and flow onto the school.” is valid.

I find very confusing the comment in the memorandum, in reply apparently to Mr. Christensen’s comments, “Nevertheless, the period of time assumed for shutdown of the pumps is not considered in the “worst case” scenario, which is based on liquid in the pipeline flowing for an indefinite period of time reaching the storm drain, and flowing beneath the school site.” We find no evidence in previous documents that support this claim. In fact given the limitations and technical errors imposed by critical assumptions in these previous studies and this memorandum, the validity and conclusions of these previous risk analysis reports should be called into serious question.

These comments raise serious questions regarding the value of materials being supplied to CUSD Trustees. Read more!

Picture Book Pipeline Failure

For those of you that complain that my comments on pipelines are too technical, here is the picture book version of a serious accident. This occurred in Bellingham, WA during 1999, on a 16-inch fuel pipeline that is nearly identical to the one passing near SJHHS. When it was over, three young bystanders were dead.



Details of this incident are available at numerous places online, and here.


This photo depicts the section of the pipeline that ruptured at Bellingham. External damage to the pipe as a result of excavation that occurred years before the accident contributed to this failure. Some of the damage is clearly visible on either side of the point of rupture. Read more!

Mitigation vs. Disaster Response

It appears to be a rather common mistake made around CUSD these days. During the last Board meeting, Mr. Bergman and Mr. Carter made a great deal of the fact that CUSD would respond promptly in the event that fuel were to escape from the Kinder Morgan pipeline adjacent to SJHHS. I've previously commented on this error in Pipeline Common Sense (at para. 8), stating that actions taken after an incident are not risk mitigation. Instead, they are incident response, or disaster response.

Actual risk mitigation consists of steps taken before an incident that are designed to reduce the potential affects of known risk. So far, no mitigation whatsoever has been proposed.

Non-experts such as Mr. Bergman and Mr. Carter may be excused for this common error. However, it is disappointing to see Ms. Fitzgerald commit the same blunder. In her memo responding to Trustees, she wrote the following response to a question from Mrs. Palazzo:

As discussed during the presentation, one mitigation measure would be to have the local CUPA agency or Orange County Fire Authority contact SJHHS and the District in the event that a rupture or leak occurred from the pipeline. Since the only scenario by which product could impact the school site is if vapors and/or product got into the storm drain and traveled beneath the school site, another potential mitigation measure would be that upon notification of a break in the pipeline, one of the engineers at the high school would go to the storm drain and install straw waddles or some similar type of barrier to prevent product from entering the storm drain. A permanent berm or dike could not be located around the storm drain because it would prevent stormwater runoff from rainfall events from entering the drain and thereby cause flooding.

Obviously, a telephone call notifying the school that fuel has escaped would come some time after the occurrence. As such, this constitutes a response to an emergency situation. It is not a step taken to mitigate risk.

It is even more incredible that Ms. Fitzgerald would propose that one of the "engineers" at the high school would be sent into the area of leaking fuel to install straw waddles, presumably to absorb the fuel. Would Ms. Fitzgerald herself be willing to perform this task? Does she know a category of CUSD staff that is trained for suicide missions?

The last sentence of Ms. Fitzgerald's response appears to deal with actual risk mitigation, presumably something suggested by Mrs. Palazzo. However, in dismissing the matter, Ms. Fitzgerald is stating that the only place where fuel flow might be diverted is at the storm drains. This is a very narrow minded view of the options available. Read more!

Consultant Response to Maddox is Faulty and Misleading - Gasoline is Compressible

Ms. Fitzgerald wrote in her July 31, memo to CUSD Trustees at paragraph 5:

Liquids are considered to be incompressible fluids. Therefore, increased fuel flow by fluid compression is not possible. The bulk modulus of gasoline is approximately 200,000 psig; therefore, to get just a 1% increase in volume, the pressure would need to be increased by an additional 2,000 psi above what the current operating pressure of the pipeline is.

Please understand that I’m not a hydraulic engineer. However, only a few minutes of research is needed to dispense with this argument.

First, while liquids are relatively incompressible compared to gases, they are not “incompressible”. In fact, there is quite a difference between the compressibility of gasoline compared to, say, water. The term “bulk modulus” is used to describe the “stiffness” of a fluid. Gasoline has a bulk modulus of 190,000 psig. The bulk modulus of water is between 310,000 psig and 340,000 psig, depending on salinity.

Thus, gasoline is not as “stiff” as water and a certain amount of pressure applied to gasoline will reduce its volume more than the same pressure will reduce an equal volume of water. Conclusion: liquids are compressible. This contradicts Ms. Fitzgerald’s main statement.

Next, the compressibility of a fluid is not a linear function. An uncompressed fluid (at 0 psig, atmospheric pressure) is easily compressed a small amount. However, it takes an increasing larger amount of effort to achieve more compression. The effort to go from 0 psig to 1 psig is far less than is required to go from 10 psig to 11 psig, and so on. In fact, the function is hyperbolic.

The Kinder-Morgan pipeline operates at 1400 psig. The volume of gasoline under consideration in the pipeline is a fluid cylinder that is at least 24 miles in length and 16-inches in diameter (considering only the section up to the high school).

The “increase in volume” discussed by Ms. Fitzgerald misses the point entirely. Her disingenuous argument obscures the actual danger.

In a pipeline rupture, the enormous energy that has been expended to compress Ms. Fitzgerald’s “incompressible” fluid is released instantaneously. The entire 24+ mile cylinder of fuel (plus more beyond the point of rupture) will “relax” back to atmospheric pressure, increasing in volume as it does so. During this process, any obstruction (e.g., earth) at the site of the rupture will literally be “blown away” and a geyser of aerosol gasoline will rise into the air.

As the fluid in the pipeline returns to atmospheric pressure, it must escape from the pipe because with relaxed compression, it occupies a larger space (or volume) than the container (the pipeline) that previously held it. At the point of rupture, the rate of fuel escape will be dramatically higher than the nominal flow rate of the closed pipeline past the same location. Given the length of the pipeline, this accelerated release will continue for some time until all of the fuel has returned to atmospheric pressure.

Ms. Fitzgerald then makes this statement:

...therefore, to get just a 1% increase in volume, the pressure would need to be increased by an additional 2,000 psi above what the current operating pressure of the pipeline is.

This is way off subject; so far off, in fact, that it is difficult to accept as a mistake. The volume differential that is of interest is the difference between that of the pipeline payload compressed to 1400 psig (normal pipeline operations) compared to that same payload at atmospheric pressure (during a rupture). This would be far more than 1% and the volume under consideration (24 miles x 16 inches) is immense.

Given this error, Ms. Fitzgerald should also reconsider her response to Mr. Maddox in paragraph 6. Maybe she spoke to the wrong person at Kinder-Morgan? Read more!

Flawed Response to Trustee Inquiries re Pipeline

Everyone should be aware that consideration of the SJHHS pipeline issue appears on the Board agenda next week.

The CUSD website now contains a memo from district's consultant, Ms. Fitzgerald in which she responds to inquires from some of our Trustees regarding her pipeline report. Of course, this report was prepared after a conference call with CUSD's attorney, Mr. Bergman. You should read her memo and then consider the following...

The second paragraph of Ms. Fitzgerald’s report states:

There is no risk of asphyxiation with a release from the pipeline in the open atmosphere. Death from asphyxiation can occur when workers enter chemical tanks, pipelines, manholes, and other confined spaces without taking proper precautions.

On page 11, “Injuries”, the National Transportation Safety Board (NTSB) report provides this description of the injuries resulting from the pipeline release in Bellingham, WA in 1999:

A police officer patrolling the accident area was alerted by residents that two boys needed medical assistance. The police officer immediately called for the assistance of a Bellingham Fire Department medic unit. The two 10-year-old boys were taken by ambulance from the 1900 block of Iowa Street to St. Joseph Hospital in Bellingham. Hospital staff stabilized them before each patient was flown by helicopter to the burn unit of Harborview Medical Center in Seattle. Each boy had received extensive second and third degree thermal burn injuries of the head, trunk, and extremities (80 to 90 percent total body surface area). Both boys died on June 11, 1999.

The body of an 18-year-old man was found in Whatcom Creek by members of the Bellingham Mountain Search and Rescue team. Bellingham Police Department investigators arrived at the creek and documented the body as having been found partially submerged near the north bank of Whatcom Creek. According to the Whatcom County medical examiner, cause of death was chemical asphyxia from hydrocarbon inhalation poisoning. The death certificate does mention inhalation of hydrocarbons (gasoline) but states the cause of death as “asphyxia due to fresh water drowning.” The autopsy report notes that the victim was most likely “overcome by volatile hydrocarbon fumes, lost consciousness, and died from hypoxia by freshwater drowning.”

Eight other individuals transported themselves to the hospital with minor inhalation injuries.

I cannot imagine how Ms. Fitzgerald could make such a serious mistake. The NTSB is the Federal agency responsible for investigation of transmission pipeline incidents. Every word of their report is carefully considered and reviewed.

The fuel released in the Bellingham accident was unleaded gasoline.

I will have more complete comments regarding Ms. Fitzgerald’s memo before the meeting. Please check back. Read more!

Where School Spending is the Priority -- Not Schools!

Each year, the California Department of Education is heavily lobbied by an organization known as the Coalition for Adequate School Housing (affectionately known as C.A.S.H., or simply "cash" by its membership).

The members of this private lobbying group are school districts and the school employees that deal with facility matters throughout California. The group also invites contractors, architects, environmental firms, geologists, lawyers, and others involved in construction of public schools to join. The average membership fee is just over $500 per year per individual or organization.

The State of California barely keeps an eye on such lobbying groups. However, State records show that C.A.S.H. reports lobbying two departments of state government, the Office of Public School Construction (OPSC) being one of them. They spend about $0.5 million per year on such activities. A lot of this money originates from public agencies and public agency employees.

The obvious question one might ask is why a public agency such as a school district would spend money to lobby a department of state government such as CDE/OPSC? Assuming that departments merely implement policy established by the Legislature, this seems improper. But apparently, it is not illegal even if it should be.

What does C.A.S.H. have to do with CUSD and San Juan Hills High School?

Among other things, Dave Doomey, former Deputy Superintendent in charge Facilities, was the President of C.A.S.H. during the period when SJHHS was developed. The membership of the C.A.S.H. included all of CUSD's lawyers, engineers, architects, construction companies, and environmental firms. While C.A.S.H. does not publish its membership list (it is available to members only), one can infer these memberships from the various presentations made at C.A.S.H. conferences involving the employees of these companies.

Even today, CUSD's law firm, Bergman & Dacey, is a member of C.A.S.H. The Planning Center, responsible for preparation of the new Pipeline Safety Hazard Analysis is also a member (as was Wilson Geotechnical, authors of the original defective analysis).

If you don't think that the C.A.S.H. affiliation has some influence over the work and decisions of the members, just consider the following presentation made at a recent C.A.S.H. conference. The author of this presentation was responsible for the original review of the SJHHS site application!

Read more!

Dept of Education Declared SJHHS Site is Deficient

If you make the time to wander around San Juan Hills High School as I have, you will come away with the feeling that the site is crowded and small. And once all the "land not owned", setback issues, and portable classrooms are resolved, usable space will be even less. You would think that $150 million would buy a large facility, especially in a remote and unimproved area such as this. How did this happen?

The California Department of Education (CDE) has a standard for the size of public high schools. This standard is used by CDE to evaluate applications for school approval and matching funds for school construction. We are repeatedly told by CUSD officials that SJHHS is "approved by CDE". But how can it be that this school is only 75% of the required minimum size?

The CDE standard requires 67 acres of land for the 2691 student enrollment planned by CUSD and yet the school itself consists of only 50.3 acres -- and not all of this area is usable.

Credit: SJHHS ASB.

CUSD accomplished this trick by doing the site development process backwards. They bought the land, designed the school, and even started construction before obtaining approval from the state. CUSD was committed to the site -- in fact, they owned it and construction was underway -- before it was approved. In the application for approval CUSD set the projected enrollment of the school at a very low figure that made it appear that the school would comply with the state standard. The state was tricked!

CUSD kept all this a secret, in case anyone locally might question why they needed to build the school at all.

Within hours of obtaining CDE approval, CUSD announced the true plan for enrollment in revised documents. The state was quick to react, issuing an "Supersede Site Approval" letter only two weeks after issuing the original approval. This second approval letter stated that the site is deficient.

The property approved for acquisition and/or use is 50.33 gross acres of which 50.33 are usable for school purposes. This represents 75.12% of the California Department of Education's recommended master plan site size of 67 acres as contained in the California Department of Education's Guide to School Site Analysis and Development (2000).

Unfortunately, by the time this was written nobody was paying attention.

CDE then went on to recommend financial support and the State Allocation Board approved $65 million in matching funds. Why was the subterfuge tolerated? Whose interest was protected? Answers to these questions will require an investigation. However, documents already obtained by Public Records Act request paint a picture of strong dissent among CDE staff regarding SJHHS, including serious concerns about the size of the site, the pipeline, the power lines, and the excessive costs associated with landscaping and street improvements. Without actually addressing any of these questions, senior CDE staff intervened and issued the approval.

It is interesting to note that one dissenting CDE staff member, a person with more knowledge of the actual site conditions than anyone and whose name is printed on the signature block of the Site Approval letter, never signed either version of the document. Instead, her "signature" was provided by others.

This now explains the installation of portable classrooms at a brand-new school. CDE could not approve construction of permanent classrooms in excess of those required to serve the original false enrollment plan. The portables were added afterward to make up the difference between the fake plan and the actual need.

Why did CUSD do it? The answer is found at the school itself. It is obvious that an additional 17 acres of land is not available at this location. This site would have been abandoned because it is too small, had site approval been sought before becoming committed to the project.

SJHHS remains too small for projected enrollment yet today, and conditions surrounding the site threaten to make it smaller still. Read more!

Additional Violation of State Law at SJHHS

CUSD appears to be violating state law that requires separation of the school from adjacent high voltage electrical transmission lines. A 230,000 volt SCE line brings electricity from San Onofre Nuclear Generating Station into Orange County along the eastern side of the new $150 million high school. At the northeast corner of the campus, CUSD has extended an athletic field into the area that is too close to these overhead wires.



A 150 foot separation from power lines of this type is required - CCR Title 5, Section 14010(c). The separation is measured from the "edge of the school site, joint use facility, or area regularly accessible to students" to the edge of the power line right-of-way (not the wires or towers). CUSD staff are certainly aware of this requirement since they did not purchase the land in the area of the required setback.

Nevertheless, this photo clearly illustrates that the athletic field has been extended on to the private property adjacent to the power lines and the school perimeter fence and landscaping are well beyond the property line. I have personally confirmed the status of this private property in a conversation with the owner.

There is a procedure under which the CUSD Trustees could have requested that the State Superintendent of Instruction issue an exemption from the required setback. CUSD is certainly aware of this procedure since they used it to gain an exemption from setback requirements for a smaller 138,000 volt power line on the southern edge of the campus. However, no request was ever made for this larger line and no exemption was ever issued.

Incidentally, these exemptions are not normally granted by the state Superintendent for a new school site. This may explain how the current circumstances came to exist.

During the past school year, students and staff conducted PE activities in this area. The field is routinely used for soccer and football practice. This appears to be a willful and flagrant violation of the law.

Will CUSD continue to use of this area in the coming school year? How many areas of this school campus will have to be closed and made off-limits before it is brought into compliance with the law? How much of the school will remain usable afterward? Read more!