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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

In the Matter of ) ) Philadelphia Electric Company ) Docket Nos. 50-352 ) 50-353 (Limerick Generating Station, ) Units 1 and 2) )

TESTIMONY OF LeROY A. CHRISTMAN, MONTELLO DISTRICT MANAGER, ARCO PIPE LINE COMPANY, RELATED TO CONTENTION V-3b ( Ql. State your name, title, employer and business. A1. I am LeRoy A. Christman, Montello District Manag- er, ARCO Pipe Line Company, Fritztown Road, P.O. Box 2086, Sinking Spring, Pennsylvania 19608.

. ' 02. Describe your responsibilities in this position. A2. I have been the Acting District Manager or Dis- trict Manager since July 1982. As such, I am responsible

for the management and direction of all construction, maintenance, operations and related activities of the Montello District Products Pips line System and the Ft. Mifflin Water Terminal facilities in Philadelphia. This

involves planning and coordinating these activities for approximately 1,000 miles of pipe line in the States of

Pennsylvania and New York.

Q3. Please describe previous work experience and , responsibilities related to your present position.

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A3. I ccamenced my employment with the predecessor to ARCO Pipe Line in 1946, at which time I was involved with operational activities at a pumping station and terminal

facility. In 1947, I worked as a pipe line dispatcher. In 1950, I worked in Product Quality Control as a Delivery

Supervisor. From 1960 through 1970, I worked in the Land and Right-of-Way office, which is responsible for acquiring land for pipelines, protecting easements from encroachment and development, working with developers and acting as a liaison with property owners. In 1970, I became District Department Supervisor of this office. In July 1982, I became Acting District Manager, and in April 1983 I became the District

. Manager.

Q4. Are you familiar with an ARCO pipe line that traverses Chester and Montgomery Counties, Pennsylvania?

A4. Yes. This is known as the 8" Northeast Boot to Fullerton Pipe line. It runs approximately 49 miles from the Boot Pumping Station to the Fullerton Terminal.

Q5. Are you aware of its physical relationship to the Limerick Generating Station and, if so, on what basis? AS. Yes. Numerous on-site inspections have been conducted by ARCO Pipe Line on this site since 1970. At that time, ARCO identified and staked out the pipe line

route as it passes Limerick. In conjunction with my respon-

sibilities as Department Supervisor for Land and Right-of-Way activities, I personally inspected this site

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and consulted ARCO maps and photos demarcating the pipe line

route. -

Q6. How is the pipe line right-of-way at road cross- ings identified? A6. Signs which meet industry and U.S. Department of Transportion standards are mounted on metal posts identify-

ing the center line of the pipe line.

Q7. Describe the design and configuration of this pipe

line. A7. The 8" diameter Northeast Boot to Fullerton line is 48.87 miles long, and utilizes X 42 grade steel'of .250

thickness. The pipe is, as noted, eight inches in diameter and coated with a coal tar enamel. The pipe line has a capacity of 31,700 barrels per day and operates at a maximum pumping pressure of 1,100 psig. ' Normal operating pressures for gasoline are 850 to 875 psig and for diesel and furnace oil, 950 to 1,000 psig. The pipe line was buried at least three feet below grade at the time it was constructed in 1955.

Q8. Describe the protection of this pipe line against corrosion. A8. The pipe line is coated with coal tar to protect against corrosion. Additional protection against corrosion is afforded by the impressed current cathodic protection

system. ; 09. Identify the products carried by the pipe line.

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A9. The pipe line carries automobile gasoline, kerosene, diesel oil, and home heating oil. ARCO Pipe Line

has stipulated in an amendment to its right-of-way agreement with Philadelphia Electric Company that it will not carry

propane through the line. The pipe line has never carried butane or liquified natural gas a,nd could not carry either product without major physical modification of the pipe

line. Although the pipe line could carry aviation fuel, which is simply a higher octane gasoline than used for automobiles, to my knowledge, the line has never been used for this purpose. The present tariffs on file with the

Pennsylvania Public Utilities Commission cover transportation of the following: gasoline, kerosene, jet engine fuel, tractor fuel, diesel fuel, and light and medium

fuel oil.

010, Describe the nearest pumping station above and

below the point at which the pipe line passes closest to e

Limerick. A10. There is no pumping station above Limerick since the pipe line terminates at Fullerton. The Boot Pumping

Station, located in the vicinity of West Chester, Pennsylvania, is approximately 1535 miles from the point at which the pipe line passes closest to Limerick.

Oll. Is the Boot Pumping Station manned or remotely

controlled?

All. A'ctivities at the Boot Pumping Station ae

remotely controlled from ARCO Pipe Line's Point Breeze - _ _ _ _ - _ _ _ - _ _ _ _ _

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Pumping Station, located in Philadelphia as well as from the Pipe Line Control Center in Independence, Kansas. Each of

these facilities provides continuous monitoring and are equipped to regulate pumpages, open and close the pipe line, and shut down the pumps.

Q12. Describe periodic inspection and maintenance of the pipe line that passes near the Limerick Generating Station which would provide additional information regarding

leaks. A12. ARCO Pipe Line conducts weekly aerial inspections of the pipe line. Dead vegetation along the pipe line route would indicate possible leakage of products. Where the pipe line passes near a stream or. body of water, a rainbow on the water could also indicate the possibility of a leak.

Finally, leakage could be detected during right-of-way maintenance activities, such as brush clearing.

Q13. Describe the devices and procedures utilized for detecting leaks in the pipe line. A13. As noted, pipe line flow is electronically moni- tored by remote control facilities at the Point Breeze Pumping Station in Philadelphia and the pipe line control center in Independence, Kansas. Specifically, pipe line flows are electronically monitored at terminals located at Sassamansville (Swann Oil) , 23.36 miles downstrear. of the

Boot Pumping Station, at Macungie (Buckeye Pipeline Compa- ny), 36.59 miles from the Boot Pumping Station, and at .Fullerton Distribution Terminals, 48.87 miles from the Boot

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Pumping Station. Both Point Breeze and Independence have

independent capability to detect from this continuous feedback of information in 1 psig difference in pressure

levels.

Q14. Upon detection of a leak by remote monitoring, what systems and procedures are available to stop pumpages? A14. An instantaneous, complete rupturing of the pipe line would result in immediate reduction in line pressure.

For tt$e products carried in the 8" Northeast Boot to Fullerpon linE., ARCO has set the low outlet pressure control at Boot at 365 psig. Thus, a loss of pressure at the Boot Pumping Station below this level, at any time, would be detected by a sensor there, which would result in an immedi- ate, automatic shutdown of pumpages. Assuming a rupture

severe r ..ough to result in a loss of pressure below the low

outlet pressure control level, the sensor would be activated within a matter of a few minutes. Additionally, the same flow information would be monitored by the Point Breeze Pumping Station and the Pipe line Control Center at Indepen- dence, and either facility could provide independent backup

shutdown capability. In addition to these automatic shutdown features, the

pipeline's monitoring system permits prompt detection and isolation of any leakages which are less substantial. It must be understcod that slight differences in pressure may be caused by ordinary operational functions of the pipe

line, such as ambient temperature changes and pressure

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differences for the products pumped. Any sudden indication

of a radical pressure change, e.g., 100 psig, however, would cause monitoring personnel to take a closer look at the flow informaticn to determine whether the Boot Pumping Station

should be shut down. Also, there is a continuous monitoring of product delivery information as flows are taken off line

at downstream stations. Thus, if information as to line pressure and product inventory at the - various terminals indicates a posrible leak, the pipe line would be shut down from either of the

remote facilities. In the meantime, the Pipe Line Control

Center at Independence would contact the ARCO Montello District Office with information as to the general location

of the pipe line section where the leak is suspected. While

further analysis is underway, a fully equipped " spill truck" is crew-readied and upon confirmation of the leak's location

would be dispatched from the District office. Although no rupture of this pipe line has ever oc- curred, it is estimated that work crews could shut off the pipe line valves in the area of the leak in about one hour if the leak occurred during working hours and about two

hours otherwise. The 8" Northeast Boot to Fullerton line

has a series of 10 valves. The nearest valve below Limerick is approximately 3,000 feet south of the Station, and the

nearest valve above Limerick is approximately 7.9 miles

north.

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In addition to monitoring and the dispatching of work

crews, weather permitting, an ARCO Pipe Line flyer, based in

Reading, could be sent to the area immediately upon notification of a problem. Upon arrival at the area, this airplane can fly the pipe line route from Boot to Fullerton

in one-half hour. A pilot and stand-by pilot are on 24-hour

alert and may be contacted at home or work.

Q15. What pressure, if any, is maintained in the pipe line when it is not in operation? A15. The pipe line is always closed in with at least 50 psig above hill pressure, which pressure is monitored by

the Pipe Line Control Center. 016. Describe the operating experience with this pipe

line. A16. As noted, this pipe line has not experienced any leak or rupture as a result of its 28 years of operation. Third party actions, however, have resulted in penetration of the pipe line on three occasions. In one instance, a

I centractor was installing fence posts in Chester County and

caused a 3 inch split in the pipe line with an auger drill. This incident occurred approximately two-thirds of a mile

north of the Boot Pumping Station. Approximately 80 barrels of furnace oil escaped, 52 of which were salvaged. The

incident was reported at 7:30 a.m. by a nearby ARCO terminal, which apparently had been notified by the contractor, and the pipe line was shut down at 7:38. The

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penetration apparently caused about a 50 psig change in pressure at the Boot Pumping Station. A second incident occurred in Whitehall Township on

August 4, 1972, when a front end loader grading the pipe line area struck the pipe line, creating a 3 to 3h inch hole in the top. The leak was reported but detected by the pressure drop at the Boot Pumping Station before the report was received. Significantly, the penetration occurred about one mile from the end of the pipe line. 365 barrels escaped

from the hole, and all but 35 barrels were contained and re- covered The line segment from Boot to Fullerton was not

operating at the time of this incident. , The third incident also occurred when the pipe line was

. not in operation. On October 10, 1972, a contractor's auger caused a small hole'in the top of the pipe, approximately 3/5 mile from the Fullerton Distribution Terminals. Eighteen barrels of gasoline were released, fifteen of which were recovered.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

In-the Matter of ) ) Philadelphia Electric Company ) Docket Nos. 50-352 ) 50-353 (Limerick Generating Station, ) Units 1 and 2) )

CERTIFICATE OF SERVICE,' , I hereby certify that copies of " Applicant's submission of Further Direct Testimony Relating to Cpntentions V-3a and V-3b" dated November 15, 1983, in the captioned matter have been served upon the following by deposit in the United States mail this 15th day of November, 1983:

Christine N. Kohl, Chairman * Judge Richard F. Cole Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission - Washington, D.C. 20555 Washington, D.C. -20555

Gary J. Edles * Judge Peter A. Morris Atomic Safety and Licensing Atomic Safety and Licensing ' Appeal Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20565

Dr. Reginald L. Gotchy Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Docketing and Service Section * Judge Lawrence Brenner (2) Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory ' Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555

* Hand Delivery * ** Hand Delivery of Testimony by facsimile

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* Ann P . Hodgdon , Esq . David Wersan, Esq. Consumer Counsel for NRC Staff Office At : Latant Advocate of'the Executive Otfice of Consumer Advocate Legal Director 1425 Strawberry Square U.S. Nuclear Regulatory Harrisburg, PA 17120 Commission Washington, D.C. 20555 Steven P. Hershey, Esq. Community Legal Atomic Safety and Licensing Services, Inc. Board Panel Law Center West North U.S. Nuclear Regulatory 5219 Chestnut Street Ccamission Philadelphia, PA 19139 Washington, D.C. 20555 Angus Love, Esq. 101 East Philadelphia Electric Company Main Street Norristown, PA ATTN: Edward G. Bauer, Jr. 19401 Vice President & General Counsel Mr. Joseph H. White, III ~2301 Market Street 15 Ardmore Avenue Philadelphia, PA 19101 Ardmore, PA 19003

Mr. Frank R. Romano Robert J. Sugarman, Esq. 61 Forest Avenue Sugarman & Denworth Suite Ambler, Pennsylvania 19002 510 North American Building 121 South Broad Street ** Nk . Robert L. Anthony Philadelphia, PA 19107 Friends of the Earth of the Delaware Valley Director, Pennsylvania 106 Vernon Lane, Box 186 Emergency Management Agency Moylan, Pennsylvania 19065 Basement, Transportation and Safety Building Mr. Marvin I. Lewis Harrisburg, PA 17120 6504 Brerford Terrace Philadelpnia, PA' 19149 Martha W. Bush, Esq. Kathryn S. Lewis, Esq. Judith A. Dorsey, Esq. City of Philadelphia 1315 Walnut Street Municipal Services Bldg. Suite 1632 15th and JFK Blvd. Philadelphia, PA 19107 Philadelphia, PA 19107 Charles W.-Elliott, Esq. Spence W. Perry, Esq. Brose and Postwistilo Associate General Counsel 1101 Building Federal Emergency lith & Northampton Streets Management Agency Easton, PA 18042 500 C Street, S.W., Rm. 840 Washington, DC 20472 Jacqueline I. Ruttenberg Keysteon Alliance 3700 Chestnut Street Philadelphia, PA 19104

-* Hand Delivery ** Hand Delivery of Testimony by facsimile

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. Thomas Y. Au, Esq. Assistant Counsel Commonwealth of Pennsylvania DER 505 Executive House P.O. Box 2357 Harrisburg, PA 17120 Thomas Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources 5th Floor, Fulton Bank Bldg. Third and Locust Streets Harrisburg, PA 17120

Jay M. Gutierrez, Esq. U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Zori G. Ferkin Commonwealth of Pennsylvania Governor's Energy Council P.O. Box 8010 1625 N. Front Street Harrisburg, PA 17105

. MarkMT.Tetterhahn

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