ML20211A328
| ML20211A328 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/15/1997 |
| From: | Johnson G, Joseph Kelly TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Gilley L TEXAS, STATE OF |
| References | |
| TXX-97171, NUDOCS 9709240218 | |
| Download: ML20211A328 (4) | |
Text
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_m y- File No.- 261 T-C-
_- TXX #97171 nlSERVICES September 15,1997 ,
Janws J. Kelle), Jr.
tice hvident
- Mr. Lonnie Gilley Texas Natural Resource Conservation Commission Petroleum Storage Tank Division 1101 East Arkansas Arlington, TX 76010 RE: - Comanche Peak Steam' Electric Station Underground Storage Tanks TNRCC Facility I.D. No. 28749 USNRC Docket Nos. 50-445 & 50-446
Dear Mr. Gilley:
On May 23,1997, Joe Simecek of Texas Utilities corporate environmental staff reported to you s a suspected release of lubricating oil at TU Electric's Comanche Peak Steam Electric Station (SES) kicated off highway 56. near Glen Rose, Texas. This is to report to you the findings of our investigation to date.1 Also on May 23, 1997, this issue was reported to the Nuclear Regulatory Commission in telephonic report #32385.
On May 22 - 1997. Bruce Turner and Scott Wilde from Comanche Peak SES and Joe Simecek investigated a very small' seep _of oil appearing on a concrete wall inside a staircase at approximately 40 feet below grade level in the turbine building at Comanche Peak SES. The
. amount of oil that could be seen was very small. If the oil were wiped off with a rag, the total volume of oil involved was about 1/5th of a teaspoon. The suspected source of the oil is related to a 1,500 gallon lubricating oil tank system krated near the outside wall of the turbine building.
Although the oil seep was seen at the forty foot depth level, the top of the tank is buried about three feet from the grade level.
The piping for the tank connects to the bottom of tha tank and is buried underground and then penetrates the same concrete wall at a higher level than where the seep appeared.
The potential suspected source for the oil seep is from either:
- 1. the lubricating oil tank k
- 2. the piping
- 3. past overspills of tank
/) h h j lllllllllllllglll lll 9709240218 970915 PDR ADOCK 05000445 S "' PDR Energy Ptaza 1601 Bryan Succi Dallas. Texas 15201 3411
4 Mr. Lonnie Gilley Septem,ber 15, 1997 Page 2 Since initiation of required release detection in 1992, tank and piping tests and inventory control
- have not indicated a release. Therefore, the most likely source of release is past overspills.
A We believe that the horizontal and ver.ical extent of the release is limited to that area of the soil that was disturbed during constructbn in the 1970's of a construction access slope to the turbine building. We have come to this conclusion based on the following information. From aerial photos taken during construction (see attached copy), the underground basement located at least 40 feet deep for the turbine b.tilding was blasted out of limestone. The excavation for the underground portion resulted in generally very steep sheer walls except at a graded slope used for access to the bottom of the excavation by construction vehicles. After the basement floor was poured, the concrete walls were poured against the native limestone. As work progressed, select fill material was used to back0ll the graded slope to grade outside the turbine building basement.
It appears that as the construction work progressed, the tank and piping in question were installed in the graded slope area to avoid additional excavation into limestone. This graded slope area was also used to install other pipes such as water r .d sanitary lines. The material used to backfill the graded slope area is more permeable than the native limestone; allowing some rainfall runoff penetration. This water becomes trapped against the outside concrete wall of the turbine building.
From consultation with Comanche l'eak personnel, at some time after the turbine building was constmeted in the 1970's, some minor water seepage penetrated the outside concrete wall building at approximately the forty foot depth level. At that time, a system of drain pipes was drilled through the 3 foot thick outside wall to collect the water trapped against the outside wall. Since that time, water trapped against the outside wall at the level of the pipes has gravity drained through the pipes and then been collected in a series of drain pipes and commingled with Hoor drains; and thence to a oil / water separator system. This series of co!!ection laterials originates in the immediate vicinity of the oil seepage.
As part of the oil seep investigation pipe plugs on the drain pipes located near the seep were removed to be able to determine if any oil was present in the pipes. An oil absorbent rag was inserted into the pipes to determine if any eil was in the pipe. The rags were examined and there was evidence of the yellow color lubricating oil on the rag. Based on the h> cation of the drainage pipe penetrations into the outside wall, we were able to determine that an nil sheen or oil is trapped against the outside .vall for approximately forty feet to fifty feet along the wall (horizontally east to west). However, we believe that the trapped water and some amount of oil is confined by the native limestone walls and the concrete wall of the turbine building and should not cause an impact to the environment.
TU Electric has removed lubricating oil from the tank and isolated it from the rest of the lubricating oil system.
TO Electric proposes to take the following steps to address the situation:
- 1. Hire an environmental consultant (PST Corrective Action Specialist) to prepare a Release Determination Report for submittal to TNRCC.
J
o l . -
( Mr. Lonnie Gilley
,Septerpber 15,1997 Page 3 ,
- 2. TU Electric is considering permanently eliminating the potential for any leakage from the existing piping or tank by abandoning the lubricating oil tank in-place in late 1997 or early 1998. Since it has aircady been determined that a release occurred, no soil samples will be taken from beneath the tank.
- 3. We believe that the horizontal and vertical extent of the release has been determined: and is hmited to that area which was blasted out of limestone to form the graded slope.
Therefore, we do not believe that a separate site assessment consisting of groundwater monitoring wells is required for this situation, in addition, TU Electric proposes that the existing drainage collection system will continue to attenuate the trapped oil and that this system can serve as a suitable sampling point for contaminant confirmation. TU Electric's environmental consultant will propose any remedial measures such as free pnxtuct removal or bio-remediation after the situation is studied further, if you have any questions, please call Joe Simecek of my staff at 214/812-8403.
Sincerely, dames J. Kelley, Jr.
By: Gerald . Johns ,
Generation Environmental Manager JJS:
Enchwure 28740 001 x
cc: U.S. Nuclear Regulatory Commission Attn: Docket Control Desk Washington. D.C. 20555 U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation One White Flint North: 11555 Rockville Pike Rockville, MD 20852 Attn: T.J. Polich
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