ML20086E498
| ML20086E498 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/22/1991 |
| From: | Doering J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Bauer R PENNSYLVANIA, COMMONWEALTH OF |
| References | |
| NUDOCS 9112020140 | |
| Download: ML20086E498 (4) | |
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PHILADELPHIA ELECTRIC COMPANY LIMEHICK GENCH ATING ST ATION P, 0. HUX A S AN A1 GG A, PENNSY LV ANI A 19464 (21&l 3271200 s em n oo
), UU t 90 I04 9, 4 04.
!1ovember 22, 1991 Mr. Itobert Dauer, Jr.
Department of Environmental Resources 13ureau of Water Quality Management Suite 6010, Lee Park
% 5 IJorih Lane Conshohocken, PA.1942H SUUJECT:
!Joncompilance with !JPDES Permit himerick Generating Station
!JPDCS Permit IJo. PA-0051926
Dear Mr. Dauer:
DESCRIPTIO!J Ol' !JOl1COMPLI Al1CE On October 16, 1991, at approximately 1145 hours0.0133 days <br />0.318 hours <br />0.00189 weeks <br />4.356725e-4 months <br />, a ta x inch underground fire water pipelli.e was inadvertently punctured by a contractor backhoe ram operator during the excavation of a trench for a new sewer pipeline from the Limerick Training Center.
The backhoe ram operator was breaking fill concrete with the backhoe ram when he inadvettently punctured an approximately three inch diameter hole th vugh the pipeline wall, causing-an immediate discharge of water from the fire water pipeline.
The resultant plume of fire water partially filled the trench and also fell onto a-mound of loose ditt and gravel located just beyond the trench.
The runorf from this dirt and gravel mound flowed downhill into a storm water catch basin.
The stormwater catch basin then directed the surface water into the drainage line for L
stormwater outfall number 014, which discharges into the Possum i
llollow Creek.
The !JPDES permi t allows _only stormwater-runoff to
-be discharged t.hrough outfall number 014.
Do harge of fire water,-which originated from the Cooling Towers,-is in violation of the permit.1 '1he permi t.' requi res tha t th10 noncompliance be reported with the next monthly Discharge Monitoring Report.
On October 16, 1991, at approximately 1220 hours0.0141 days <br />0.339 hours <br />0.00202 weeks <br />4.6421e-4 months <br />, a water sample was collected at the discharge of stormwater outfall number 014.
The sample was then analyzed for pH and total suspended solids.
The pH was found to be 8.50 and the total suspended solids was
^ 9112020140 911122 PDR ADOCK-05000332 I
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)4r. Rober t Dauer, J r.
Page 2 of 3 IJovember 22, 1991 determined to be 179.6 mg/L, which primarily consisted of dirt.
Observation of the diocharge flow and the Possum llollow Creek indicated that no visible foam was present.
Therefore, we conclude that minimal environmental impact occurred within the Possum liollow Creek.
CAUSC OF Tile IJO!JCOMPL1 A!JCU l
The contractor backhoe ram operator was directed by the Limerick Generating Station (LGS) Installation Group to excavate the trench for the newer pipeline to a specified depth and direct'on in a_particular area.
Installation Procedure, IP-5.34,
" Procedure for Performing Excavation and Preservation of Site Flood Protection at bimerick Generating Station," was being utilized to perform the excavation activity.
Procedure IP-5.34 requires that certain site engineering prints be reviewed prior to Lt2 clart of-an excavation activity to determine if other utility service pipelines exist W thin the area to be excavated.
Also, procedure IP-5.34 requires that all proposed excavation activities be reviewed and approved by Installation Group supervision.
This review and approval is to be documented on an Excavation Clearance Form.
Pollowing the event, a Root Cause Analysis (RCA) wan performed, and installation Group personnel identified that an inadequate review of the required prints referenced in proctdure IP-S.34 was performed by both the contractor and the Installation Group.
The contractor initially reviewed the printo and developed a composite layout drawing for the excavation site.
The composite layout drawing was then reviewed by appropriate Installation Group Supervision.
Apptoval and concurrence of this layout by Installation Group Supervision wau indicated on the Excavation Clearance Form.
As a result of inadequate reviews performed by both groups, the six inch fire water pipeline was not indicated on'the layout drawing, since their reviews concluded that the pipeline was 20 to 26 feet west of the excavation site.
Therefore, the backhoe ram operator was unaware that.the excavation trench was being dug directly across the path of the fire water pipeline.
The RCA also identified that Bechtel Yardwork composite prints, C-2200 series, which clearly show details of the location of the six inch fire water pipeline and other various pipelines within the_ excavation site, were not listed with the required prints to be reviewed in procedure'IP-5.34.
Therefore, the need to
-generate a composite layout drawing of the excavation site was
+
unnecessary if these additional prints were used.
DURATIOt1 OP Tile IJO!JCOMPbl A!JCE The fire water pipeline was punctured at approximately 1145 i
hours, on October 16, 1991.
At approximately 1205 hours0.0139 days <br />0.335 hours <br />0.00199 weeks <br />4.585025e-4 months <br />, on I
October 16, 1991, LGS operationn personnel had isolated the l.
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4
.M r. Robert Hauer, Jr.
Page J of 3
!Jovember 22, 1991 9
punctuted section ut the iit e watet pipeline, and terminated the telease of t.he fire watet.
The estimated total quantity of fire watet teleased during the twenty minute period was 20,000 gallons.
A significant portion of this release was absorbed through the trench walls and bottom, and also through the mound of loose ditt and gravel located just beyond the trench.
Therefore, the amount of runoff drainage that actually discharged 3
from stormwatet outIal1 numtut 014 was ertimated to be 10,000 i
gal 1onu.
CORHl:CTIVE ACT 'Of1 The backhoe ram operator inunediat e.y t erminated all activities in the trench and relocated the backbce ram extension arm away from the plume of water spewing out of the fire water pipeline.
LGS Operations personnel inaned i a t e l y responded to the incident, and within twenty luinutes had inulated the punctured section of the pipeline by closing the appropriate valves in the system.
The punctured section of the fire water pipeline remained isolated until it was repaired on November 8,
1991.
PREVENTION OP FUTURE UCCURRF.!JCES 1.
Personnel involved in thir, event were counseled on the requirements of procedure 1P-5.34, and regarding attention to detail and the need to perform a self check of their work.
2.
Procedure IP-5.34 is expect.ed to be revised by December 13, 1991, to incorporate the Bechtel Yardwork composite prints, C-2200 series, into the list of required prints to be reviewed prior to performing an excavation activity.
3.
Formal training un procedure IP-5.34 and its requirements will be given to Installation Group personnel and also to specially cont.ractors who per f orth excavation activities at LCS.
This training will include a discussion of this event, and vill also emphasize the need for attention to detail and the need for self check verifications.
Training t o t.h e Installation Group is expected to be completed by December 31, 1991.
Training to the specialty contractors is expected to be completed liy June 1992.
Sincerely,
. ff Av Osroy
/
DMS:cah
r
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S. IJuclear Hegulatory. Commission Document Conti01 Desk 1
Docket llos. 50-352/50-353 Washington, D.C.
20555 T. T. Martin
{
Administrator, Hegion 1, US!JRC l
Docket 140s. 50-352/50-353 t
T.- J. Kenny i
UI';RC. Senior Hesident Inspector, LGS Docket lios. 50-352/50-353 Program Management Section (2WM52) i Permits Endorsement Dranch Water Management Division Environmental Protection Agency Water permits Section Region 111 841-Chestnut Building Philadelphia, PA 19107 bcci J. Doeting, Jr. - ADMS-1 R. W. Dubiel - ADMS-1 T. J. Jackson - SSD3-3 i
G. J. Madsen - SSB3-4 G. M. Morley, Jr. - S9-2 J. A. Muntz - SMB3-2 11RB Chairman - 51A-1 G. J.
Beck, Jr. - 52A-5 H. W. Vollmer - 638-1 R. J. Scholz-- 51A-3 Commitment Coordinator - 52A-5 PA DER BRP. Inspector - SMB3-4 Correspondence Release Point - SMB1-2 11RMS - SMD,1-2 I
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