ML20100A495

Errata Sheet for City Statement 3.Svc List Encl.Related Correspondence

ML20100A495
Person / Time
Site:	Limerick
Issue date:	11/29/1984
From:	Bush M PHILADELPHIA, PA
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ML20100A481	List: ML20100A480 ML20100A495
References
OL, NUDOCS 8412030620
Download: ML20100A495 (4)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 00CHErr-a UShRC Helen F. Hoty, Chairman Richard F.

Cole, Administrative Dr. Jerry Harbour, AdministrativeLawLaw Judge *g4 Judge ggg ,3 N0:46 IA

, Tith fpyhg BRANCH

.In the Matter of  :

Philadelphia Electric Company  : Docket Nos. 50-352 (Limerick Generating Station, 50-353-Units 1 & 2)  :

ERRATA SHEET CITY STATEMENT NO. 3 i REVISED STATEMENT ORIGINAL REVISED <

p. 22, line 2 "unab ailable " unavailable

p. 19 , line 4 " Peak Useage" Peak Usage"

p. 29 , line 5 "leves" " leaves" i

p. 29, line 17 "suply" supply

p. 30, line 21 "with" " water"

p. 31, line 3 "oblivate" "obliviate"

p. 31, line 5 " interconnection currently " inter connection currently

, exist between purveyors" exist between the Water Department's distribution network and suburban purveyors" i

s 9412030620 841129 PDR ADOCK 05000352 9 PDR 1

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REVISED STATEMENT ORIGINAL REVISED

p. 31, line 16 "the accident.Under these "the accident. It is not conditions there are any certain at this time other utilities with whether there are any othe3 sufficient excess capacity utilities with sufficient to supply either or both of excess capacity to supply the high service districts. either or both of the This must be researched high service districts.

immediately. If excess If excess capacity is capacity is available , available",

p. 32, A.29, line 1 "estensions" " extensions"

p. 32, A.30, line 4, "PECo" "PECO"

p. 33, line 14, " plant" " plan" Respectfully submitted, dffhA MARTHA W. BUSH, Deputy City Solicitor

. November 29, 19 84 DATED 2 -

w SERVICE LIST NRC Philadelphia Electric Company (Limerick Generating Station (Units 1 and 3) Docket No. 50-352 50-353 Paul B. Cotter, Jr. Maureen Mulligan, Esquire Chief Administrative Law Judge Limerick Ecology Action Atomic Safety & Licensing Board Post Office Box 761 U.S. Nuclear Regulatory Commission Potts town, Penna. 19464 Washington, D.C. 20555 Zori G. Ferkin (FE)

Jerry Harbour, Dr. Assistant Counsel Adminis trative . Law Judge Governor's Energy Council Atomic Safety & Licensing Board 1625 N. Front Street U.S. Nuclear Regulatory Commission P.O. Box 8010 Washington, D.C. 20555 Harrisburg, Pennsylvania 17125 ,

Helen F. Hoyt, Chairman Mr. Frank R. Romano Administrative Law Judge 61 Forest Avenue Atomic Safety & Licensing Board Ambler, Pennsylvania 19002 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Gregory Minor Cf MHB Technical Associates Honorable Richard F. Cole 1723 Hamilton Avenue Administrative Law Judge San Jose, California 95125 Atomic Safety & Licensing Board j U.S. Nuclear Regulatory Commission Eugene J. Bradley i Washington, D.C. 20555 Philadelphia Electric Company j Associate General Counsel i Docketing & Service Section 2301 Market Street j Office of the Secretary Philadelphia, Penna. 19101 U.S. Nuclear Regulatory Commission I Washington, D.C. 20555 Edward G. Bauer, Jr.

1 Vice-President & General Counsel l Benjamin H. Vogler, Esquire (FE) Philadelphia Electric Company l O.E.L.D. 2301 Market Street i U.S. Nuclear Regulatory Commission Philadelphia, Penna. 19101

! Washington, D.C. 20555 i Mr. Vincent Boyer Mark Wetterhahn, Esquire (FE) Senior Vice President i

Troy B. Conner, Jr., Esquire Nuclear Operations Conner & Wetterhahn Philadelphia Electric Company 1747 Pennsylvania Avenue, N.W. 2301 Market Street

, Washington, D.C. 20006 Philadelphia, Pa. 19101

( Robert L. Anthony ,

103 vernon Lane Moyland, Pennsylvania 19065

,ww., v- -,+- -- v.-,-,-,-p, --., , -- nv- - - . ------,--y e.,--.-._ - - . -~~. . , , - - - ,~, 3. - . . - - - - _ + - r .- . . - - - - _e,. s.. --

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Mr. J. T. Robb, N2-1 Robert L. Sugarman, Esquire Philadelphia Electric Company Sugarman, Denworth & Hellegers 2301 Market Street 16th Floor, Center Plaza Philadelphia, Pa. 19101 101 North Broad Street Philadelphia, Penna. 19107 Honorable Lawrence Coughlin House of Representatives Charles W. Elliott, Esquire Congress of the United States 1101 Building Washington, D.C. 20515 Easton, Penna. 18042 Frank Hippart, Director Spence W. Perry, Esquire Pennsylvania Emergency Associate General Counsel Management Agency B-151 Federal Emergency Management Agency

> Transportation & Safety Building Room 840 Harrisburg, Pennsylvania 17120 500 C. Street, N.W.

Washington, D.C. 20472 Roge r B . Reynold, Jr., Esquire 324 Swede Street U.S.N.R.C. Region I Norristown, Pennsylvania 19401 631 Park Avenue King of Prussia, Penna. 19406 Phyllis Zitzer Limerick Ecology Action Thomas Gerusky, Director P.O. Box 761 Bureau of Radiation Protection Potts town , Pa. 19464 Department of Environmental For FE: 762 Queen St. Resources

(' Potts town, Pa. 19464 5th Floor, Fulton Bank Building Third & Locust Streets Timothy R. S. Campbell Harrisburg, Penna. 17120 Department of Emergency Services 14 East Biddle Street Atomic Safety & Licensing Wester Chester, Penna. 19380 Appeal Panel U.S. Nuclear Regulatory Commission Mr. Marvin I. Lewis Washington, D.C. 20555 6504 Bradford Terrace Philadelphia, Penna. 19149 Hen ry J . McGurren Office of the Executive Legal Directo Frederic M. Wentz U.S. Nuclear Regulatory Commission County Solicitor Washington, D.C. 20555 County of Montgomery Courthouse Norris town, Penna. 19404 l

l Angus Love, Esquire 101 East Main Street Norris town, Penna. 19401 Mr. Joseph H. White, III 15 Ardmore Avenue Ardmore, Pennsylvania 1900 3

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{ c' 3 ELATED CO.wc;agucg' l City Statm ent 3,,

Novenber 2,1984 UNITED STATES OF AMERICA fc NUCLEAR REGUIATORY CCM4ISSION

'M n~G -3 p:=

BFFORR THE ATCMIC 9AFETY AND LICENSING BOARD f

Helen F. Hoyt, Chairman Richard F. Cole, Administrative Law Judge Dr. Jerry Harbour, Administrative Law Judge In the Matter of  :

Philadelphia Electric Conpany  : Docket Nos. 50-352 (Limerick Generating Station, 50-353 Units 1 and 2)  :

TESTIMONY OP BRUCE APICWICZ CHARLES ZI'KMER AND RICHARD WEIS9 l DISCU9 SING 9EVERAL ADDITIONAL CONSIDERATIONS THAT NFED TO BE DEVEIDPED IN GREATER DETAIL A9 PART OF AN IMPLFMFNPATABLE WATER SUPPLY SMERGENCY PLAN FOR THE CITY OF PHILADELPHIA l

Q.l. Please state your names, addresses, cositions with the City of i

Philadelphia and the purpose of your tdstimony.

A.l. My name is Bruce Aotowicz, Manager of Operations, Water Department, City of Philadelphia. My business address is One Reading Center, Third Floor, Philadelphia, Pennsylvania, 19102.

My nam is Charles Zitaner, Chief of Load Control, Water Departent, City of Philadelphia. My business address is One Reading Center, Third Floor, Philadelphia, Pennsylvania, 19102.

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My name is Richard Weiss, Project Manager of Planning and Research, Water Department, City of Philadelphia. My business address is one Reading Center, Second Floor, Philadelphia, Pennsylvania, 19102 The purpose of this testimony is to discuss several additional con-7 siderations that need to be developed in greater detail as part of any inplementable water energency plan for the City of Philadelphia.

Q.2. In general, what additional information is needed before a water supply emergency plan can be developed for the City of Philadelphia?

1 A.2. More information is needed on the types of accidents for which planning must be done. Specifically, in order to develop an emergency plan, the level, kind and nature of contaminants, the time frames involved, meteorological impacts and the expected impact on potability must first be estimated. Knowledge of the associated probabilities of the various accident types also would be useful for planning. Further information must be developed on the feasibility and effectiveness of treating each type of contaminants at our treatment plants in order to be able use the treated water as a potable supply. As indicated by Mr. Rulesza, we have two raw water supply sources - the Delaware and the Schuylkill l Rivers. This information would therefore need to be developed for both sources.

i Q 3. Why is this level of detailed infomation necessary to develop an mergency plan for the water supply?

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s A.3. As we understand it, there are many potential types of accidents with varying quantities and qualities of released contaminants. These types of accidents have projected frequencies of occurrence. Also, the impact of weather conditions, wind direction, and precipitation will need to be taken into account in developing a plan.

All of these variables would affect the precise nature of the emergency plan that would need to be developed.

Q.4. Could you elaborate further on why this information is necessary?

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, A.4. The actions that would need to be undertaken by the Water Department a

for different time periods of contamination will vary. Similarly, the level of contamination will determine what types of mitigation tech-niques will need to be employed. The degree of water contamination will determine whether or not either supply source will be available r

and, if available, at what capacity. The availability and extent of 1

l supply is the primary factor in determining what conservation neasures and suoply strategias will be necessary to provide every Philadelphia Water Departent custmer with potable water. Similarly, if the Schuylkill River raw water treatment plants' capacities or the Delaware River treatment plant's capacity has to be fully or partially subjected to repeat precipitation, the plans would vary. The developrent of each cmponent of the plan vill depend on supply constraints imposed by pum-

, page capacities and the configuration of the water distribution system.

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s Q.5. Have you reviewed any information that addresses energency planning for the water supply of Philadelphia?

A.S. We have briefly reviewed the quantitative graphs presented by the NRC Staff and the Philadelphia Electric Ccmpany developed for the environ-mental inpact statement ("EIs") with regard to the levels, types and the time periods of contamination associated with various accident types. The Cmmonwealth of Pennsylvania also provided the City with a booklet. The City has had several meetings with the Ccrmonwealth and T

PECO with regard to these problems.

Q.6. Was that information sufficient to prepare a water supply emergency plan for the City of Philadelphia?

i l A.6. No. The EI9 material seemed to focus on the broader, long-term m asurements. For planning purposes one needs to know much more detailed information, e.g., short-term contaminants, the entire i spectrum of contaminants, the time periods of various contamination levels, probabilities, the imoacts on both rivers, etc. The material provided by the Cmmonwealth was also insufficient in addressing these issues.

Q.7. Please explain in nere detail the water system constraints that are relevant for these purposes.

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s A.7. In designing any water supply systen there are two major constraints that must be evaluated. The first is the demand for potable water supplies by all classes of customrs (residential, commercial, industrial, institutional, wholesale). These demands should be eva-luated both on a ceak and average day basis. Distribution systen denands for hydrant use and leakage must also be evaluated.

The second constraint that must be evaluated is the availability of potable water supplies. Factors that must be considered include raw water and finished water punping capacities at each plant and in the service districts, available treatment processes and their effec-tiveness in treating water supplies at various levels of contamination, available raw and finished water storage basin capacities, transmission

main capacities at average and peak daily demands and the ability of the system to supply all sections of the City fran more than one supply source. The last factor, i.e., the interconnection of supply sources, l is of particular concern to the City of Philadelphia since there are i

several sections of the City that can be supplied by only one of the two rivers.

Q.8. Why must peak day usage be considered in the development of an emergency plan?

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A.8. The design of any water or sewer facility must be based on peak day usage in order to assure that adequate service is provided to all uti-lity customrs.

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Q.9. In the case of a water supply emergency, what strategies must be employed to manage the situation?

A.9. To develop emergency planning strategy one must know the magnitude of

, the problem. Once this is known a number of measures, if properly developed, can be applied to minimize any potential health or safety impacts. It is assumed that the enormcus media coverage of such an -

event will help the Ccmnonwealth and the City of Philadelphia gain public cooperation. Although a number of measures should be imple-mented city-wide for all classes of custoners to minimize exposure and reduce denand, there may be a number of emergencies which are so severe that the water supply constraints of Philadelphia's system would pre-vent certain districts of the service area to be supplied with potable water. Under these conditions, special measures would have to be implemented for those customers that reside in these severely impacted districts.

Q.10. Previously a number of types of accidents have been mentioned. If one i possible water supply energency is an event such that the Schuylkill River cannot be used as a source of water supply, describe what would be entailed in utilizing only the Delaware River as the sole source of

! water supply for the City and its suburban custcmers.

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A.10. This would represent an energency condition of a mgnitude that has not been previously encountered by the City. In order to maintain water service for the City during such an event, three different operational 6

E modes must be addressed. Chronologically these phases would coincide with 1) a notification period, during which the details of the emergency are made known to the City and a raw water intake termination time has been established, 2) the period of four to eight days after shutdown of the Schuylkill River raw water intakes during which certain areas of the City are supplied solely fran storage reserves (of Schuylkill origin), while the majority of the City relies on the Delaware River as a supply source, and 3) that period after the deple-tion of storage reserves for the Roxborough/Manayunk sections, certain areas in Germantown, and the area known as the "Belmont High Service District," during which Delaware River water would be required to be

, utilized to the conveyance capacity limits of the system.

i Q.ll. Please elaborate on each of the three phases described above.

A.ll. PHASE I: The planning and implementation of the procedures necessary i

to cope with this type of energency are highly dependant on the availa-bility of accurate notification of the nature and extent of the event.

The possibility of the loss of a raw water source for periods of time longer than several hours necessitates implementation of a number of operational procedures that potentially could assure City-wide supply for at least several days. Inplementation of these operations would be

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needed to replenish storage facilities and isolate treatment and con-veyance routes to serve primarily areas that could not be ultimately supplied fran the Delaware River. Any facilities that are out-of-service for repair or maintenance would also need to be reactivated, if 7

I possible,' during this time. Because these actions require mobilization  ;

e t of crews and sufficient raw and filtered water punping time to refill storage structures, adequate advance notification is crucial. Adequate i

advance notification must allow approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to fill all '

storage facilities with potable water before the intakes are closed. A i water conservation program must be inplemented within 1.5 days of the l intakes being closed. 91nce certain areas of the City must rely solely upon accunulated storage, the lifespan of their remaining supplies is v 4 i directly proportional to their existing storage levels, consunption levels an3 the time of emergency readiness prior to the termination of Schuylkill River punping.

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] In sunmary, inherent in developnent of required emergency measures are '

i assunptions that define conditions prevalent at the outset of such an a

emergency as well as adequate advance warning. In addition, the following conditions aust exist: no loss of electrical power during the emergency and average day consunption demands even during peak i periods. (We present later an analysis of how emergency conservation

! i measures may reduce consunption.) '

i PHA98 II: Upon closure of the Schuylkill River raw water intakes, the Belmont High 9ervice District ("BHSD") and the Roxborough, Manayunk,

, and Germantown areas could be serviced by water from the storage reser-l Ves accumulated in Phase I, assuming average day consunption levels.

4 I Under the above stated assunctions, it is estimated that these reserves L l

will last approximately 8.0 days for these sections in Northwest 8 _

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Philadelphia and 4.0 days in the Belmont High Service District. Since storage in addition to that available in the Belmont High Service Clear Well exists at the Belmont Treatment Plant, portable punps could be used to supplement BHSD storage frm lower basins. This additional storage could meet the BHSD demands for roughly 3 more days.

Therefore, the longest possible self-sustained supply period for the Belmont High Service District would be 7.0 days. All other areas of the City could be adequately supplied frm the Delaware River source if

Delaware River Water can be utilized, all cricital components of the i water systs are operational, and a conservative plan can be imple-a mented.

1 PHASE III: Upon depletion of the storage reserves as mentioned above, additional operations can be taken to attempt to distribute more Delaware River water to the western reaches of the City. However, due to various system constraints, certain areas of the City cannot be delivered Delaware River water and will remain out of service. These 4

areas include the Belmont High Service District and Roxborough, as well as sections of Manayunk, Germantown, Mt. Airy and Chestnut Hill.

t i It should be noted that other sections of the last group would experience greatly reduced pressures and flow rates. Specific areas of cutage and reduced level of service could be located only after addi-tional detailed study; however, those areas which exist at high eleva-tion or are serviced by older, smaller distribution mains (Germantown),

will suffer the greatest loss. These effects will be felt inmediately 9

upon tha depletion of available storage reserves. In general, the only sections of Northwest Philadelphia that will continue to experience existing levels of water service will be the northernmost area bounded by Cheltenham Avenue.

If a conservative plan can be developed now and implemented as needed, and, if no critical outages affect a portion of the City's ability to be serviced, all other sections of the City could, frczn a distribution t

point of view, receive water supplies conveyed from the Delaware River source.

In sunmary, any type of emergency condition which would render the Schuylkill River useless as a source of potable water supply would impose a great hardship upon the City's water supply system.

Q.12. Have you evaluated a number of measures that might be effective in reducing consunption on a peak day in the event that the Schuylkill River could not M used as a source of water supply?

A.12. Yes.

Q.13. What measures did you review that might be implemented city-wide in the l

event that such an accident occurred?

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A.13. I reviewed the use of rationing, non-essential water use bans, the 10

distribution of flow restrictors and the imposition of water use surcharges for all Philadelphia Water Department custcmars.

f Q.14. Why is it important to evaluate the appropriateness of these various techniques?

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l A.14. A number of techniques must be implemented to reduce consunption 1

l quickly and for an a tended length of time if the Schuylkill River is l

I eliminated as source of supply for more than seven to eight days, a

Consunption must drop intnediately to ensure that the Baxter plant will be able to supply as much of the Water Department service area as possible. The objective of these techniques should be to enable the Water Department to stretch its reservoir supplies of potable water as long as possible and to supply as many people as possible with water l

, from the Baxter plant in the more likely situation that the Schuylkill l River would be contaminated to a relatively more severe degree than the Delaware River.

1 l Q.15. Which of the city-wide mitigation techiques that you evaluated were i

deem 2d appropriate?

i A.15. Rationig , the use of non-essential water use bans and the distribution of flow restrictors were all deemed appropriate.

Q.16. Which of the city-wide mitigation techniques that you evaluated were '

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l desned non-appropriate and why?

A.16. The use of water use surcharges is not workable for the short term.

The effectiveness of this measure depends on the use of quarterly billing to inpose high usage charges on custaners that do not emply with any mandated rationing provisions. Given the innediate nature of the energency, this option would not reduce consumption imediately.

In the case that the energency was prolonged for more than one year, this measure might be effective since most customers' meters would be read in this time frame. Any customrs not abiding by the other con-servation masures would be assessed high surplus usage charges. This would help to reduce consunption.

Q.17. Have you made so m preliminary estimates of the level of reduced con-sunption that might occur during a peak use day if the measures you desned appropriate were implemnted?

A.17. Yes.

Q.18. How were these estimations prepared?

I A.18. The peak day usage of 480 M m in Fiscal Year 1984 was used as a base- i line. Reductions in consunption fran this baseline were estimted for the non-essential water use ban, rationing and distribution of flow restrictor provisions. In order to make assunptions aboir tha level of conservation or reduced consunption that could in expected for each 12

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o measure, a number of sources of information were consulted. The two major sources of reduced water consunption that were assumed are the imposition of fire hydrant controls and the reduction in customer water usage. These are discussed in greater detail below.

1 Fire Hydrant Controls One type of non-essential water use provision that would have a major j impact on consunption during an emergency is a ban on the use of water l

l frczn a fire hydrant for any purpose except for firefighting or health protection purposes specifically approved by the City's health offi-l cials. An estimate of the anount of illegal recreational hydrant usage that could feasibly be reduced on a peak usage day was prepared using historical data. An assunption that seventy-five percent or 85 MGD of a possible 113 M3D of recreational hydrant usage would be reduced was made based on the success of the hydrant use control program during the i 1981 drought. It was assumed that hydrant use reduction would be even greater in this case as a result of the intense publicity this event would ccmnand. In addition, greater public resources such as police enforcement activities, around the clock shutoff of hydrants, and the installation of hydrant locks will of neccessity be concentrated on reducing hydrant abuse to ensure sufficient water for firefighting pur-poses.

In addition to illegal hydrant usage, a numMr of legal hydrant uses would be Mnned during this entgency such as the use of hydrants for water main flushing, construction and ccmmrcial use and for cleaning and disinfecting new water mains. The estimates for each use were 13

based on previous studies on hydrant use in the Philadelphia Water Department FY80 Unaccounted-For-Water Report (1981). A total savings of approximately 5.0 kid for these uses would be feasible.

Custcmer Water Use The inposition of non-essential water use bans and rationing will affect each class of custcmers in Philadelphia and Bucks County dif-ferently. Five classes of custcmers were analyzed for feasible water use reductions: residential, commercial, industrial, public properties and Bucks County. Since any set of water use restrictions will impact

. each class of customers differently, any energency plan inplemented as part of the city-wide consunction reduction strategy nust address each class of custcmer differently.

i The table below presents average day and estimated peak day consunp-tions for each custoner class. Average day consunption numbers were based on recent custcmer billing records. It is difficult to estimate the degree to which usage for each custcmer class will increase above this average on a peak day. The major reasons that each class increases usage during ceak periods are greater outdoor water use, greater use of air conditioning, use of swinming pools, and greater frequency of bathing. The peak day occurs on a very hot sunmer day.

! i During the sunmer in general industries may switch part of their supolies to groundwater sources for cooling water purposes. It is I exoected that Bucks County, since it has a suburban water population,  !

will have a higher per capita water use due to greater outdoor water use. A ballpark estimate is that all customer classes will increase l

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consunption by ten percent on the peak day except for Bucks County (an )

assumed twenty percent increase).

Average Day Peak Day (MGD) (ED)

Residential 104 114 Ccmnercial 41 45 Industrial 50 55 Public Properties 10 11 Bucks County 13 16 Residential - Per capita residential usage was assumed to be able to be reduced by approximately 25 percent frczn 68 gallons per capita day

("goed") to 50 gped. This would represent a 30.2 E D savings. It is assuned that these savings could occur through the distribution of flow restrictions (9.2 gped reduction), prohibition of outdoor water uses such as car washing, lawn watering, outdoor plant watering with fresh water and the use of swimning pools (5.0 gped reduction) and additional conservation efforts for dishwashing and laundry use, the elimination of many household leaks and the installation of toilet tank inserts by scrne households (3.8 goed reduction). An effective public relations programs as well as a network that can rapidly distribute the flow restrictors will be necessary for this goal to be realistic.

Ccmnercial - Ccmnercial usage includes water use by office buildings, institutions (school, hospitals, etc. ) and comnercial establishments I

(stores, engineering and other non-manufacturing businesses in the ser-vice sector). Conservation is more limited for commercial uses because many health and safety codes require the use of air conditioni.M during i

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the sumner in buildings which do not have windows that open. It is  !

also more difficult to reduce consunption since many connercial buildings have installed blowout fixtures (toilets and urinals) which use considerably more water per flush and cannot be easily modified. A five percent or 2.25 MGD reduction was assumed for outdoor water use (irrigation, ornamental water use and vehicle washing) during the maxi-mum day. Another five percent reduction was assumed for the installa-tion of flow restrictors, the reduction of timing of flush values, a water conservation enplayee education effort and the elimination of leaks.

Industrial - A goal of 25% reduction in industrial use would be established during such an energency. The impact on industry would vary according to the type of operation and the ability of the firm to reduce water usage without shutting down. cane firms may be more flexible in switching to alternative supply sources (e.g.,

groundwater). Others may be able to reduce production without shutting down completely. 9ince this level of industrial conservation has never been attained in the Philadelphia region, it is difficult to say for certain what the economic impact of this reduction would be. As part of the energency planning effort there should be a study in cooperation with the Chamber of Connerce and the Philadelphia Industrial Developnent Corporation ("PIDC") to assess this. Since certain industrial groups are better able to reduce consumption without affecting production or encloyment, a Comnercial and Industrial Water Use Cannittee could be established through the Chamber of Connerce to l 16 r

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determine' the best way for all industrial users to attain this goal.

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Perhaps certairJ industrial groups could save more than 25%, thus off-d

, setting those with less than 25% without shutting down any firm's sYs >

operation.s.

, A 25 percent reduction would reduce Philadelphia

! l industriallwaterusageby13.8MGD.

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s Ii Public Propertie's - Public properties are defined as buildings and

i parks owned by the City of Philadelphia. Public property accounts include public schools, public libraries and museums, city buildings, recreational centers, park facilities, etc. Prohibiting the use of i

b public swinning- pools, reducing the use of other public buildings

,t (schocoL , me(peums, libraries)and implementing various conservation i ' \ ,

, measures mentioned in the cmnvarcial use section should result in a ten

, , percent reduction (1.1 it;D) . It was assumed that public property a },a 's A i accounts and wcial accounts have similar usage patterns and there-i 4

'I fore similar potenti,al savings.

is incks County - Bucks Cou'.ty Water and Sewer Authority customers will be c

z. impacted since the Authority is a wholesale customer of the Water Department. 'It is unclear to what extent conservation will succeed here since the City .,of Philadelphia does not have direct regulatory control over the custcmers. During the 1981 drought, consumption i '

increased in Bucks County by 3.3 percent during February-May and then

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reduced 11.3 percent during June-August. Overall, the level of conser-

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vation was less than in the City of Philadelphia. For this reason a 15 l es <

percent reduction was assumed for a 2.4 ! tid savings, t

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D Q.19. What sources of information were consulted in the preparation of these estimates?

A.19. A number of analyses prepared following the 1981 drought in Philadelphia were reviewed to determine what levels of hydrant use reduction and custmer conservation are feasible. Several articles were also reviewed which analyzed the effectiveness of various masures

-taken in northern California in 1977 and in northern New Jersey in 1981 during the severe droughts in those states. Metered consunption history records were obtained frm the Revenue Department's Water Revenue Bureau. Water distribution records were obtained from the operations Division of the Water Department. The 1981 City of Philadelphia Drought Water anergency Plan was reviewed to determine which non-essential water uses might be banned during the sergency.

Many of the drought masures would need to be made mare stringent as part of an implemntable water emergency plan for Limerick. A number of estimates were prepared based on procedures referenced in the Water Departe nt's FY80 Unaccounted-For-Water Report. A pamphlet entitled Water Conservation and Wasteflow Reduction ,in_ the Hme (Special Circular 184) frm Pennsylvania State University provided this infor-mation in per capita use and residential conservation measures.

Q.20. What are the results of this preliminary analysis?

A.20. If successfully implemented, the various conservation measures pre-l

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viously bsih ' unld likely reduce the peak day consunption frm 480 E D to 338 E D. This represents a thirty percent reduction in consunption. A breakdown of this reduction is as follows:

Peak Usage of 480 E D (85.0) illegal hydrant use (5.0) other hydrant use (30.2) residential (4.5) cmmercial (13.8) industrial (1.1) public properties (2.4) Bucks Counties 338.0 ED This projected reduction could lower consunption fran the peak day usage to approximately the average day usage (342 E D). If one subtracts out the 12.1 E D average day demand of the Belmont High Service District (which currently cannot be supplied by Baxter without permanent punping and piping improvenents), the remaining 325.9 ED represents the demand the Baxter plant would have to satisfy to supply the~ rest of the service area. This is below the 350 E D peak day capa-city of the Baxter plant.

Q.21. Are there any caveats that should be entioned regarding the assunp-tions that were used in the preparation of these estimates?

A.21. First and foremost the applicability of each conservation measure will

! depend on the type and degree of accident assumed. The masures that were chosen and the conservation estimates that were made may change i

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radically for a different accident with different impacts. For example, an accident which is less severe may enable the Water Department to use at least part of the capacities of the Belmont and Queen Lane treatment plants assuming additional treatment remedial measures are underta'en.

Secondly, the assunptions that were "aM M the ectimatec that were prepared are not hard numbers - they rely on a good deal of guesswork since we do not have a previous accident history upon which to base our judgment. For example, any estimate of reduced residential consunption will be inexact in the case of a nuclear accident. It is difficult to approximate how the Philadelphia population will respond to such an anergency. S m e people may decide to board water once an energency is declared, especially in districts which are severely impacted. This would reduce the amount of conservation that is feasible. On the other hand, a number of people may decide to leave the area during any energency. This would tend to increase the amount of conservation that is feasible. A third possibility may be the evacuation of number of people from one section of the city to shelters in another section.

This may redistribute the consunption demands for potable water, thereby increasing or decreasing the feasiblity of various supply alternatives.

l It is also difficult to estimate peak usage by custaner class. There l

i have not been any studies to date in the Philadelphia service area on the daily variation in demand for each type of custmer throughout the 20' _

year. The ten and twenty percentage increases chosen were based on literature values reported for other cm munities, not on actual con-sunption data for Philadelphia. The peak usage estimates for industrial consunption are especially difficult to determine since industrial use tends to be less hmeneous in nature.

Q.22. During Mr. Kulesza's testimony it vua mentioned that lime-soda ash sof-tening might be used to remove R-90 during the sedimentation process at the Baxter Treatment Plant. If the water treated at the plant was softened twice, what u sible impacts would this have on the ability of Baxter to meet the City's average daily demand?

A.22. The use of lim-soda ash softening to remove SR-90 at the Baxter Treatment Plant may reduce the through-put by as must as one-half at the plant if the water is softened twice. If approximately 170 MGD is recycled then only 170 M30 would be available for distribution, which clearly is inadequate to satisfy demand.

Q. 23 . Beyond the imposition of city-wide rationing and non-essential use ban measures, are there any additional measures that might be necessary?

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A.23. Yes, additional measures must be undertaken for.a long-term accident in certain high pressure districts in the Philadelphia Service area to

, ensure that these custcmers do not run out of potable water. These I

people would be impacted most severely by such an accident.

Specifically, the Belmont High Service district and approximately i

i 21

thirty percent of the service area of the Roxborough High Service -West Oak Lane district would be impacted if the Schuylkill River was'una-vailable as a supply source for a long period of time. These measures

. would still be required even if the city-wide measures were success-fully implemented to the maximum extent possible.

Q.24. Please sumnarize any information you have on the number of people that could be affected and the amount of consunption in these two districts.

l A.24. The following table sumnarizes the consunption in the two districts that would affected by such an energency. Consumption values for the affected areas of the Roxborough High Service - West Oak Lane District can not be extrapolated fran known consunption values for the entire district due to the non-honogeneity of this service area. In order to fully evaluate various mitigation techniques for this district, con-

sunption and population nurrbers will have to be prepared as part of the energency planning process.

(EO) (E D) (ED)

, Average Day Max. Day Max. Rate Population

, Belmont High 9ervice 12.1 14.9 22.3 65,500 Roxborough High Service 16.9 24.6 46.4 111,138 W. Oak Lane (total service)

Roxborough High Service N/A N/A N/A N/A W. Oak Lane (affected portion only) 0.25. What measures did you review that might be necessary for these two districts?

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A.25. Four possible techniques were proposed to supply the two districts with potable water. The proposed techniques include 1) the use of tanker trucks or tmporary storage tanks, 2) the installation of emergency pipes and punps to provide additional capacity, 3) the permanent modi-fication and inprovement of the distribution system to enable residents in these two districts to be empletely supplied by the Baxter plant and 4) the creation of permanent interconnection (s) with neighboring water supply purveyors who have excess capacity. The first two tech-niques represent tmporary or stop-gap measures while the latter two techniques are more permanent in nature.

0.26. What criteria were chosen to evaluate the appropriateness of these various measures?

A.26. Each measure must be evaluated in terms of the accident event that was presupposed. In the particular case we mentioned, they must be con-t sistent with a situation in which the Schuylkill is unavailable as a supply source beyond the seven to eight days of available storage and the accident has occurred during a period of peak usage.

i To properly evaluate these four techniques one must first assess the impact of this emergency on the distribution system in the two high service district affected areas. As potable water supplies are depleted in these districts, three possible impacts could occur.

23

9 The first possibility is that a decision is made not to pump any water into those mains. This decision could be disastrous for the integrity of the system. As air gets entrained in the mains it bec mes more and more difficult to resupply the system without causing pipe collapses due to vacuum or water hamer. To prevent such damage, the resupply would take a number of days, retarding the reestablishrnent of service.

In addition, the lack of water in these mains is unacceptable frm a public safety standpoint due to the unavailability of water for fire-fighting purposes. This situation is especially acute in the case of the Belmont High Service District which would run out of water (assuming temporary remedial masures have already been taken) in approximately seven days if no Schuylkill River water or alternative water supplies were punped into the system. The situation for the affected areas in the Roxborough High Service - West Oak Lane District is less straight forward. Although sme water would probably remain in many of the mains in these areas (especially in lower elevation areas),

it would be inadequate to meet water consumption deands. It is unclear, without a very detailed analysis, to what extent these mains would have water and in what quantity. It is assumed, especially at the higher elevations, that the available supply will be inadequate frm a pressure standpoint for firefighting.

The second possibility is that contaminated Schuylkill River water is punped through these mains to prevent the loss of supply. The problem with this option is that there is a potential that a number of people j may ingest this contaminated water despite an intensive door to door i

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. education effort. In a recent Pittsburgh area contaminated water case, 1 a family ingested contaminated water in spite of such an education and media campaign. It is difficult to imagine a 100% effective campaign in reaching every person affected in the two districts. Given these drawbacks and the availability of alternatives, this option is not viable.

?

The third and only viable possibility available to the City of Philadelphia is the provision through the distribution system of alter-native sources of potable water to these Districts.

Q.27. On the basis of these criteria, which measures that you evaluated for

[ the two districts were deemed non-appropriate '

and why?

A.27. The first two possibilities presented in the previous response avoid

the use of alternative water supplies, through the distribution system, for potable water uses. Both possibilities rely on the use of tanker I

trucks, temporary storage tanks, or bottled water to supply potable water for drinking, cooking and possibly bathing purposes. Additional water would be needed for sanitary purposes (toilets and bathing) if the no punping first option was chosen. V.S. Boyer of PECO has indi-cated in his letter under date of August 1984 to Camissioner Marrazzo ,

i I

(City Exhibit "B") that the use of tanker trucks is a feasible option.

Given the discussion in the previous response, the use of tanker trucks

, is not a viable option since there are ways to obtain potable water i

through the distribution systs, which is the preferred alternative -

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O all water supply needs could be satisfied and health and safety hazards are minimized. This is especially true in the case of the Belmont High Service District which will run anpletely out of water in approxima-tely seven days. One underlying reason behind the determination that tanicer trucks are non-appropriate in this case is the opinion that mitigation techniques implenentable in the case of a severe drought are not necessarily appropriate in the case of a nuclear accident. A nuclear accident is much more likely to have health impact con-siderations as well as supply considerations. During a severe drought, for exarnple, water could still be punped frm the Schuylkill to these l 1

districts without the fear of people ingesting this water. This unfor- j tunately is not the case with a nuclear accident.

The letter by Mr. Boyer also refers to the use of temporary punps and

=

piping to supply the Belmont High 9ervice District frm existing covered reservoirs supplied by the Ihxter plant. Specifically, he refers to the supply of the Belmont High Service District Clear Well using a tenporary punping and piping scheme frm the covered M:mument Road Reservoir. The Monument Road Reservoir, which normally is used to supply the Belmont Gravity District, could be supplied frm a transmission main that connects to the East Park Reservoir. Thee ast Park Reservoir, in turn, could be supplied by the Delaware River. In order to supply the average daily consumption (12.1 K;D) to this a

district, sufficient temporary punping and piping capacity connecting the Monument Road Rnservoir and the Clear Well would be required to satisfy demand. Mr. Dick I;vnison of PFMA has indicated that pipes and 26 _ ___________ ____________

O punps are available frm that agency on an emergency basis. Mr.

Boyer's transmittal does attempt to define the total punping capacity and the discharge piping size that would be required.

The use of tmporary punps and piping is consistent with the alter-native potable water supply criteria presented earlier. Frm this standpoint the measure is a viable alternative. This alternative may not be viable, however, for some degrees of accident. The accident that was assumed here was a contamination of the Schuylkill River for more than seven to eight days such that available potable water storage supplies would no longer be available to supply the impacted high ser-vice districts. Mr. Boyer's letter fails to address the fact that insufficient hydraulic capacity currently exists in the 48 inch transmission main that connects the East Park Reservoir and the Mountain Road Reservior to supply both the Belmont High Service and Belmont Gravity District on a peak usace day even if the conservation measures previously discussed were fully inplemented. The temporary punping and piping scheme will succeed in the extending potable water i

service to the Belmont High Service District fran a four day supply to l

a seven day supply but this measure does not represent a long-term feasible response.

Q.28. The remaining measures that you nentioned earlier are 1) the installa-l tion of punping capacity and piping to permanently modify

Philadelphia's distribution systs and 2) the construction of intercon-nections with adjoining water supply curveyors who might have an excess 27 .-

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a capacity of non-contaminated water supplies. Have you studied either of these measures in more detail and, if so, were any possible supply options identified?

A.28. The first supply measure available to the Water Department would require several permanent modifications of Philadelphia's distribution systen in order to supply the two high service districts. In the case of an energency this measure represents the quickest and nost effective response by the Water Department. This measure would require the installation of sm e c mbination of additional punps and piping capa-l city. It should be mentioned that each design alternative identified for this measure would require additional studies to size the piping and determine the additional punping capacity that will be required.

Engineering cost estimates must be daeeleped as part of this process.

The modification of the systen in terms of this measure should be

evaulated frm two standpoints

1.) increased transmission capacity fran the Delaware River to the Baxter Treatment Plant and 2.) increased transmission capacity from the Baxter Treatnent Plan to the two impacted high service districts.

2 Increased transmission capacity from the Delaware River to h Baxter Treatment Plant would have at least three possible benefits for the Water Department. The first benefit would be an increase in peak capa-city at the Baxter Plant which currently is 350 K;D due to raw water punping constraints. If these constraints could be eliminated, actual 28

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peak capacity could increase to 423 K;D. This would improve the safety margin for the Water Department on a peak day assuming the Schuylkill River is unavailable as a supply source. Earlier it was projected that the peak demand could be reduced from 480 K;D to 338 K;D through various conservation measures. This only leaves a slight 12 *;D safety margin. If the raw water transmission capacity was increased and if the other intra-system transmission capacity modifications were imple-mented, the Water Department could safely supply its entire service area under the conditions assumed.

The second possible benefit this would present for the Water Department would be an increased flexibility in water supplies for the region.

For exanple, assuming interconnection (s) were available in Northeast i Philadelphia with the Philadelphia Suburban Water Canpany (PSWC), the Philadelphia Water Department could supply eastern sections of PSWC's capacity. PSWC's freed capacity could then be used at two other inter-connections near the Belmont High Service and Roxborough High Service-West Oak Lane Districts to supply these two areas. The increased capacity of the Baxter Plant would therefore enable the City to " tradeoff" its water supplies with neighboring water purveyors.

This supply option would eliminate the need for the previously men-tioned intrasysten nodifications. This raw water supply enhancement could also be scaled back to allow for PSWC or another water purveyor

to supply one High Service District which would mean that the Water l Department could lower its raw water transmission capacity increase requirenents. The Department would, however, have to provide addi-t tional transmission caoacity to the other High Service District.

l 29 .__ _ , _ _ _ . _ _ _ . .

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< 1 The third benefit would be to increase potable water suplies available at the Baxter Plant in an event of partial contamination of the Delaware River, requiring the use of lime-soda ash softening for decon-tamination. Since this treatment process may require the Delaware River water to be softened twice, thereby reducing the throughput of the plant by as much as one-half, any increase in peak capacity will be highly beneficial in helping the Water Department attain its objectives of supplying as many people as possible with potable water during an

, emergency.

Increasing the transmission capacity fr a the Baxter Treatment Plant to the two high service districts can potentially be accmplished in a number of ways. Several modifications may be necessary given the current distribution neterk arrangment to effectively supply the two districts without the use of interconnections. The purpose of these modifications would be to supply the BHSD and sections of Germantown, Roxborough, Manayunk and Chestnut Hill with sufficient additional capa-city to ensure adequate pressure for fIrefighting and potable water use in all areas, including the higher elevations.

The other supply measure available to the Water Department that should be further evaluated is the possibility of constructing interconnec-tions with adjoining water supply purveyors such as the Philadelphia

/

Suburban Water Conpany or the Chester Water " Authority. This option was discussed in the previous paragraph for the situation where the raw water peak capacity of the Baxter plant is increased and supply tra-deoffs through interconnections are inplement.ed. Another possibility 30

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! that may be feasible is for one or more suburban water supply purveyors to supply the two high service districts without any water supply trade-offs. This would obliviate the need for any permanent Water Department distribution systen modifications. Only one water supply interconnection currently exist between the Water Department's distri-bution network and suburban purveyors (with Bucks County Water and Sewer Authority.) It may be feasible to construct one or more addi-tional interconnections with suburban areas if the purveyors might have excess uncontaminated supplies under these sergency conditions. This would be the case for purveyors which rely on ground water sources, adjoining supply basins or stretches of the Delaware River not con-taminated. It is assumed in the case of a regional water supply surgency enforced by the Ccmnonwealth that neighboring Gater supply purveyors would be requested to implenent water conservation and rationing measures even if their supplies were not directly impacted by the accident. It is not certain at this time whether there are any other utilities with sufficient excess caoacity to supply either or both of the high service districts. If excess capacity is available,

, further design studies will be required to determine the size and con-nection points of the transmission mains and the capacities of the punps that will be needed as part of each interconnection. Simulation studies should be performed under a variety of omrgency conditions and systen danands prior to the selection of any design alternatives.

To evaluate the potential for regional interconnections, the anargency plan must include an analysis on a regional basis of various sources of 31

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alternative water supplies that water purveyors might have available in excess supply in the event that the Schuylkill River was eliminated as a source of potable water for various time frames. anergency planning should proceed with the objective of developing strategies in all affected water service areas so that the least number of people will not have an available non-contaminated water supply source. The energency plan for Philadelphia should therefore be part of a regional 4

energency plan that could be inplanented following an accident at

Lhnerick.

Q.29. Have you evaluated the feasibility of these water supply options at this time?

A.29. No. Each water supply option will require extensions or modifications to the existing distribution systen network. Sane of these options may require significant capital expenditures to accomplish. Mirther

research and detailed design work will be necessary to evaluate these alternative adequately.

Q.30. In sumnary, what needs to be done to have an implermntable water supply emrgency plan?

2 A.30. In order to have an implenentable water supply energency plan for the i City of Philadelphia a number of steps need to be undertaken jointly by l the City, suburban water ourveyors, the Ccmnonwealth and PFCO.

Firstly, PDCO must develop various accident prcbabilities, risks and impacts as an input into the planning process, secondly, each pirty

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r must review this information. Appropriate conservation and water supply measures for each level of accident must be developed.

Institutional or organizational barriers to the implenentation of these measures must be identified. For exmple, the City does not currently have a rationing plan for its custaners. The legal framework for instituting such a plan must be developed. Organizational procedures to institute the distribution of flow restrictors city-wide and the '

rapid reduction in illegal hydrant usage may also need to be addressed.

Thirdly, a detailed study of feasible potable water supply options for each severely inpacted district that would be affected by one or more levels of accidents must be prepared. Detailed design, construction and cost information for each feasible alternatives must be prepared.

This study should provide the basis for the developet of a regional water supply emergency plan to fully explore the possibility of creating interconnections. This study should be funded jointly by all parties involved (regional water purveyors, the City, the Canmonwealth and PIIO). Finally, the plan must be adopted by all parties involved.

Necessary water supply enhancenents reconnended in the third step must be funded and constructed. Institutional and organizational constraints to the inplenantation of various conservation measures must be overcone. The plan should be subject to a public hearing process prior to adoption.

Q.31. Does this conclude your testimony?

A.31. Yes it dms, i

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