Part 21 Report - 1996-590

ACCESSION #: 9611130283 NOTE: This text document was processed from a scanned version or an electronic submittal and has been processed as received. Some tables, figures, strikeouts, redlines, and enclosures may not have been included with this submittal, or have been omitted due to ASCII text conversion limitations. In order to view this document in its entirety, you may wish to use the NUDOCS microfiche in addition to the electronic text. UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406-1415 October 23, 1996 MEMORANDUM TO: Walter Haass, Sr. Reactor Engineer Quality Assurance and Maintenance Branch Division of Reactor Controls and Human F Office of Nuclear Reactor Regulation THRU: Michael C. Modes, Branch Chief Civil, Mechanical and Materials Branch Region I, Division of Reactor Safety FROM: Michael McBrearty, Reactor Engineer Civil, Mechanical and Materials Engineering Branch Region I, Division of Reactor Safety SUBJECT: POTENTIAL PART 21 ON EMERGENCY DIESEL GENERATOR LUBE OIL HEAT EXCHANGER During an inspection at Limerick last month, I spoke with you about a potential Part 21 involving the design of the EDG lube oil heat exchanger at Limerick. At that time, Limerick was developing a letter to Coltec, the EDG manufacturer who procured the lube oil heat exchanger as part of the EDG system, requesting that Coltec perform a Part 21 evaluation. You asked me to get a copy of the letter and forward it to you, so that NRR could evaluate the Part 21 aspects, and take any action needed to notify other utilities that may be affected. Limerick just issued the letter and I have attached of copy. Attachment: As stated cc: J. Wiggins, DRS S. Black, NRR M. Modes, DRS A. Lohmeier, DRS N. Perry, SRI - Limerick W. Pasciak, DRP Nuclear Engineering Division PECO NUCLEAR PECO Energy Company A Unit of PECO Energy 965 Chesterbrook Blvd. Wayne, PA 19087-5691 Mr. T.M. Stevenson June 10, 1996 Coltec Industries/FMED 701 White Avenue Beloit, WI 53511 Subject: Limerick Generating Station, Units 1 &2 Emergency Diesel Generator Lubricating Oil Cooler Request for 10CFR21 Evaluation Dear Ted: During work associated with the development of our EDG heat exchanger performance monitoring program in response to USNRC Generic Letter 89-13, our consultants from Stone & Webster/Boston determined that the Limerick EDG lubricating oil coolers were undersized relative to the design conditions reported on the heat exchanger data sheet. The purpose of this letter is to alert you to this matter, explain how this conclusion has been reached, and request that you evaluate the situation for 10CFR21 reportability since we understand that "lo-fin" tubes similar to those at Limerick may have been used in the lubricating oil coolers for Coltec EDG's at other installations. Attachment 1 is a copy of Bechtel's lubricating oil heat exchanger data sheet 8031-M-71-DS-17. Our records indicate that the sheet was completed by Coltec during EDG design and manufacture and submitted to Bechtel as a part of the purchase contract. The data sheet provides the design conditions for the heat exchanger and specifies a tube-side fouling factor of 0.002. When our consultant input the heat exchanger geometry and the design conditions into Heat Transfer Research Inc.'s (HTRI) Shell & Tube heat exchanger modelling program ST-5, Mod 0.50-1.30, using the oil-side heat transfer rate of 83.2 BTU/(hr ft**2 degrees F) provided by the heat exchanger manufacturer for SAE 30 oil, and the specified tube- side fouling factor of 0.002, he found that a 22.8% undersurfaced heat exchanger was actually delivered. This is shown on pages 1 and 2, respectively, of Attachment 2. The tubes on this heat exchanger are Wolverine "lo-fin" tubes, 19 fins/inch, similar to Wolverine's Catalog No. 60-195049 except fabricated of 90-10 Cu-Ni alloy. The tube OD-to-ID area ratio is 3.62. In shelf-and-tube heat exchanger design, the individual factors which comprise the total resistance to heat transfer must be referenced to either the inside or outside surface of the tube. If it is referenced to the outside tube surface, the specified tubeside (inside) fouling factor of 0.002 becomes 0.002 x 3.62 = 0.00724. (Similarly, the 0.002 fouling factor would be used unmodified if the reference surface was the inside of the tube.) Our consultant suspects that the 0.002 fouling factor was applied unmodified to the outside Mr. T.M. Stevenson Page 2 May 31, 1996 surface. This would have been done during design by dividing the specified tube-side fouling factor by 3.62 (rather than multiplying) to yield 0.00055, and then applying it to the inside. This case was run on the HTRI program and corroboration of this suspicion obtained to within 0.461%. This is shown on Attachment 3. The use of a 0.00055 tube-side fouling factor is consistent with accepted power plant design practice; however, its substitution for the specified 0.002 fouling factor reduces the amount of fouling margin and mandates more frequent cleaning and testing of the heat exchangers in order to maintain EDG operability. For the Limerick design, sufficient margin is available in the calculated post-accident temperatures of the Emergency Service Water (ESW) system, in the post-accident loading (which is below the continuous rating), and in the seasonal variation of ambient temperatures such that precise scheduling of the cleanings will allow Limerick to maintain EDG operability. Please inform us of the results of your analysis and whether you concur with the findings of our consultant. Should your conclusions differ, please provide us with the detailed technical bases for how your conclusions were reached. Should you have any questions regarding this letter, please do not Hesitate to contact William McFarland of my staff at 610-640-6465. Very truly yours, John B. Cotton Director, Nuclear Engineering Division Attachments (3) WJM/wjm a:\052996 Copy to: N. Perry USNRC Limerick Senior Resident Inspector C.F. Andreone SWEC J.B. Cotton 63B-3 R.J. Croke SWEC L.J. Fusegni SWEC M.P. Gallagher LGS SSB 3-1 G.H. Gellrich 63B-3 J.P. Grimes LGS SSB 3-1 G.H. Hunger 62A-1 T.B. Madden SWEC W.J. McFarland 63B-3 J.B. McLaughlin LGS SSB 3-1 V.M. Nilekani 63B-3 W.J. Reilly LGS SSB 3-1 R.D. Weingard LGS SSB 3-1 File/DCC Doctype = 231 Attachment 1 Bechtel Heat Exchanger Data Sheet Table "Lube Oil HEAT EXCHANGER DATA SHEET" omitted. Attachment 2 Heat Exchanger Analysis with 0.002 Tube-side Fouling Factor Attachment 2 page 1 "ITT STANDARD" omitted. Attachment 2 page 2 "HTRI ST-5 Mod. 0.50-1.30" omitted. Attachment 3 Heat Exchanger Analysis with 0.000555 Tube-side Fouling Factor Attachment "HTRI ST-5 Mod. 0.50-1.30" omitted. *** END OF DOCUMENT ***

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