ML20236U253

Expresses Appreciation for Extending Time Frame to Comment on Draft Info Notice Re Leaks in EDG Lube Oil Piping at Several Nuclear Power Plants Fairbanks Morse OG Comments. Final Comments Submitted

ML20236U253
Person / Time
Site:	Millstone, Vermont Yankee, Crystal River  File:NorthStar Vermont Yankee icon.png
Issue date:	07/25/1998
From:	Epstein H AFFILIATION NOT ASSIGNED
To:	Petrone C NRC
References
IEN-NRC-9807-02, IEN-NRC-9807-2, NUDOCS 9807290411
Download: ML20236U253 (4)

Text

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Engineering i July 25,'1998 IEN/NRC 9807-02--

U.S. Nuclear Regulatory Commission

. ATrN: Charles D. Petrone Mail Stop: 0-12D3

_ Washington, D.Ci20555-0001

SUBJECT:

Draft Information Notice Regarding Leaks in the Emergency Diesel Generator Lube Oil Piping at Several Nuclear Power Plants Fairbanks Morse Owners' Group Comments '

s

Dear Mr. Petrone,

Thank.you for extending the time frame to comment on the subject draft information notice. until July 27, 1998. Below, please find final comments'on the subject draft

, information notice by the Fairbanks Morse Owners' Group. j Comment 1 ~

The draft information notice seems to apply to all plants employing the same type.

engines as Crystal River, Unit 3. Millstone, Unit 2, and Vermont Yankee. The draft information notice identifies diesel engines at 14 plant sites may be affected.

As noted previously, there are 15 plant sites employing the same type of engines as the three operating units noted in the draft information notice. Some of these engines, as well- as. a number of Pielstick engines ' provided by th_c same manufacturer, were fabricated to the requirements of ASME Section III, Class 3 with regard to the skid mounted piping. The Coltec ' Industries Part 21 Notification series of correspondence on this matter seemingly excludes the plants -

in which ASME Section'Ill, Class 3 requirements were employed. The Coltec Part 21 Notification listed 12 plant sites that may be affected. The information

( . notice in its current form may cause several licensees to unnecessarily expend resources to mtemally disposition the information notice.

e

In the view of the Fairbanks Morse Owners' Group, it should be noted in the ,

information notice that the weld-quality issue does not apply to plants that applied g4 ASME Section 111. Class 3 requirements to the skid mounted piping on their engines. This added information will assist licensees in determining the need to perform an evaluation of the skid mounted piping on their engines.

9907290411 980725  ? x PDR ADOCK 05000271s O P PDR j Q 19 Garden Road, Marblehead, MA 01945 L 9 Ag g\

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(781)631-9219 Fcx:(781)6319032 E-Mail:ieneng@aol.com

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EN/NRC 9807-02, dated July 25,1998 E Engineering Comment 2 As noted in my previous correspondence, there is very little mention of the efforts by the vendor, Coltec Industries, to assure that the existing welds are acceptable.

To date, the vendor of these engines has issued four supplemental information letters dated, December 18,1997, March 3,1998, April 29,1998, and June 24, 1998. The information contained in these supplemental letters is pertinent to the information notice and should be summarized within any generic correspondence on the weld-quality issue for these engines. The Fairbanks Morse Owners' Group recommends that Coltec Industries be contacted and the information provided by the manufacturer of these engmes pertinent to the subject matter of the

- information notice be included within it.

Comment 3 It is suggested actions taken by Millstone, Unit 2 concerning replacement of skid mounted piping be clarified in the information notice. The licensee replaced one section of skid mounted pipe (one piece of pipe was replaced). The balance of partial penetration welds were cut out and replaced with full penetration welds using the existing skid mounted piping.

CoIIttnenL4 The following modifications are recommended to the first two sentences of the first paragraph of the " Discussion" section of the information notice (clarifications are noted in bold / italic):

"The main piping systems on the EDG skid consist of lube oil, jacket water cooling and intercooling water. The tube oil discharge piping between the engine driven lube oil pump discharge and the oil filter is of special concern since this portion of the piping experiences the most vibration."

Comment 5 The first paragraph of the " Discussion" section of the information notice identifies that oil leaks experienced at Millstone, Unit 2 and Vermont Yankee were in a piping section that consists of a 4.5-inch diameter, 0.25-inch wall thickness carbon steel (ASTM A513) material. While most licensees employing this type engine have a similar skid mounted lube oil piping configuration, all the engmes of this type installed at nuclear operating power plants may not employ this exact configuration. It is recommended, the information notice be clarified to identify that the configuration discussed is specific to Millstone, Unit 2 and Vermont Yankee.

l The above comments on the subject draft information notice are respectively submitted on behalf of the Fairbanks Morse Owners' Group. IEN Engineering would like to add the following.

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IEN/NRC 9807-02. dated July 25,1998 I Engineering

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When the weld-quality issue on skid mounted piping was first identified, the Fairbanks Morse Owners' Group took immediate action to ensure that its members were fully aware of the issue and all members of the Fairbanks Morse Owners' Group took appropriate actions to assure that the emergency diesel generators employed at their operating units would fulfill their design and licensing basis requirements. These member actions included various inspections, tests, and analyses, as well as monitoring of the suspect welds during surveillance testing of the emergency diesel generators. Several licensees replaced entire sections of skid mounted lube oil pipe on their ent;ines with new pipe with full penetration welds, while several others cut out and replaced the welds on the skid mounted tube oil pipe sections with full penetration welds. IEN Engineering is confident each member of the Fairbanks Morse Owners' Group has taken appropriate actions to ensure the safety function of the emergency diesel generators at their plant sites is assured.

IEN Engineering will be pleased to discuss the contents of the subject draft information notice as well as provide clarifications on any of the above comments at your request.

On behalf of the Fairbanks Morse Owners' Group, I appreciate the opportunity to review this Information Notice and submit comments on it.

If you have any questions regarding the above, please contact me at (781) 631-9219.

Sincerely, bME. h Harold E. Epstein IEN Engineering i

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$ Engineering 19 Garden Road Marblehead, MA 01945 TELEPIIONE: (781) 631-9219 FACSIMILE: (781) 631-9032 E-Mail ieneng@aol.com SENT BY: IIarry Epstein DATE: July 25,1998 SENT TO: U. S. Regulatory Commission Attn: Mr. Charles D. Petrone MAIL STOP: 0-12D3 Washington. D.C. 20555-0001 Fax # (301)415-1032 Phone # (301)415-1027 MESSAGE:

Dear Mr. Petrone,

attached please find final comments on the draft information notice you sent to me by the Fairbanks Morse Owners' Group. I will mail you the original copy.

On behalf of the Fairbanks Morse Owners' Group, I sincerely appreciate the opportunity to submit comments on the draft information notice. I hope you find them to be of assistance.

If you have any questions concerning the above, please contact me at (781) 631-9219.

NUMBER OF PAGES ONCLUDING COVER SHEET) 4 l

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