The Case of the Swamped Sump Pump
Synopsis:
Having the right tools for the job, and knowing how to use them, can prevent many a false start. Hiring the wrong technical investigator can be costly and embarrassing, as in this case.
Background:
A primary sump pump and battery back-up pump in a large home failed, flooding the first floor of the home and causing major damage. TI’s client insured the manufacturer of the primary pump but the back-up pump was made by others.
Assignment:
The incident was in litigation and TI was requested to attend a joint laboratory destructive exam of the pumps at the east coast office of a major national “forensic engineering” firm, and to determine the cause of damage to the Claimant’s home.
Analysis:
It was clear from the beginning that the P.E. Electrical and P.E. Mechanical Engineers tasked with conducting the exam had no idea how to proceed with it and thus visitors took the lead in conducting the exam, at least to the extent that it could proceed with the lack of equipment at the office. The intake screen of the primary pump was almost entirely plugged with pebbles, sand, grass clippings, bits of plastic sheeting, and a range of other debris. The pumps had been installed in series rather than in parallel, and without check valves at the discharge of each pump. The primary pump had been broken from the stub pipe leading to the back-up pump pre-loss. With series installation most of the water pumped by either pump short-circuited back into the sump through the other pump.
It was requested that the primary pump motor insulation system be tested with a MegOhmMeter and the electrical P.E. flatly refused, claiming that the test would open the motor windings, ignorant of the fact that the test is the ANSI specified test for maintenance testing of electrical motors. They likely had no MegOhmMeter. An arbor press was requested for pressing the motor shaft out of the motor end bell but the office didn’t have one. All it had of use in its sparsely filled tool drawer was a rubber mallet with a cracked handle. The mallet was tagged “Broken – Do Not Use”. The two P.E.s were questioned in depth regarding the site and conditions under which they personally recovered the pumps but had no knowledge of site conditions that should have been recorded and considered prior to putting any party on notice.
TI’s report ran 29 pages describing the numerous technical deficiencies of the Plaintiff’s case and the actual conditions of the insured’s pump. Even though the loss site was only 15 miles from the exam site, no provision was made to inspect the loss site. After repeated requests for permission to at least inspect the site on which the home was built, permission was granted but it was then late in the day. A quick inspection was made and it showed that the Claimant’s yard consisted of the end of a downhill funnel that drained a substantial part of the neighborhood to a large catch basin and storm sewer located across the street. Worse, the back of the home, that faced the downhill flow, had an 8’ wide, 9’ deep stairwell leading to French doors entering the lower level of the home. A slot drain at the bottom of the stairs was piped to the sump. Thus, neighborhood rainfall was routed to the sump pump. Weather records were reviewed and it was learned that on the date of loss 6” of rain fell in two hours . . . The litigation went nowhere.
