ML19325E244

LER 89-018-00:on 890922,determined That Const Installation Procedure for Reg Guide 1.97 Category 2 Instrumentation Did Not Include Installation Details.Caused by Improper Design Coordination.Procedure No Longer in use.W/891026 Ltr

ML19325E244
Person / Time
Site:	South Texas
Issue date:	10/26/1989
From:	Ayala C, Chewning R HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-89-018-01, LER-89-18-1, ST-HL-AE-3264, NUDOCS 8911030061
Download: ML19325E244 (5)

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c The Light P.O. Box 1700 llouston, 'lhas 77001 (713) 228 9211

, Houston Lighting Ac Power October 26, 1989 ST-HL-AE- 3264 File No.: G26 10CFR50.73 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project' Elsrctric Generating St + w Unit 1 Docket No. STN 50-498 .,

Voluntary Licer.see Event Report 89-018 Regarding Improper Installation of Reg Guide 1.97 Category 2 Instrumentation Due to An Error 7n The Installation Details Pursuant to 10CFR50.73, Houston Lighting & Pcwer (HL&P) submits the attached' voluntary Licensee Event Report 89-018 regarding the impeoper installation of Regulatory Guide 1.97 Category 2 instrumentation pursuant to 10CFR50.49. This event did not have any adverso impact on the health and safety of the public.

'If you should have any questions on this matter, please contact ,

Mr. C. A. Ayala at (512) 972-8628.

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R. W. Chewning j Vice President Nuclear Operations

'i RWC/SDP/n1 -

Attachment:

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LER 89-018, Soutn Texas,  !

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Cct Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive, Suite 1000 Houston Lighting & Power Company Arlington, TX 76011 P. O. Box 1700 Houston, TX 77001 Osorge Dick, Project Manager  !

'U . S. Nuclear Regulatory Commission INPO

((. Maahir.gton, DC 20555 Records Center 1100 circle 75 Parkway y

• Atlanta, GA 30339-3064 \

g.J. I. Talia ,

Senior Resident. Inspector  ;

c/o U. S. Nuclear Regulatory Commission Dr. Joseph M. Hendrie s P. O. Box 910 50 Be11 port Lane i

'( Bay City, TX 77414 Be11 port, NY 11713 1 ;

J. R. Newman, Esquire. D. K. Lacker I Newman & Holtzinger, P.C. Bureau of Radiation Control 1615 L Street, N.W. Texas Department of Health Washington, DC 20036 1100 West 49th Street ,

Austin, TX 78756-3189 R. L. Range /R. P. Verret Central Power & Light Company P. O. Box 2121 Corpus Christi, TX 78403 R. John Miner (2 copies)  ;

Chief Operatins Officer  !

City of Austin Electric Utility 721 Barton Springs Road i Austin, TX 78704 R. J. Costello/M. T. Hardt E

,. City Public Cervice Board

.P. O. Box 1771 San Antonio, TX 78296  ;

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• ' " R'R' S ' '8 LICENSEE EVENT REPORT (LER) -

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• Voluntary Licensee Event Report 89-018 Regarding Improper Installation of Reg.

Cui rf n 1.97 Pntnenry 2 T n n e vi r an n e n r i n n Dun n An Frrnr Tn rhn T n n e n 11 n t-i nn nne n 41 n .

tytNT DATE m tan NuMain m alPoni oats m ointa e ACiuvias iNvoLvto ion se0 NTH DAY YEAR YlAR **0M L"' Fj, WNTH DAY M AR Awv ums ptfunu e South Texas. Unit 2 016 l 0 ] o l o l4 l 9; 9

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l Aes, n acT m-,, M ren ,m.t . . . e,P,. .w, o.n aw. u,.c. un,m . .e n s, l- On September 22, 1989 Unit I was in Mode 6 in a refueling outage and Unit 2 l was in Mode 3, it wea determined that the construction installation procedure l for Regulatory Guide 1.97 Category 2 instrumentation did not include installation details that would assure the devices are qualified to the I requirements of 10CFR50.49 ar.d IEEE 323-1974 This was discovered as a result l of the followup investigation into concerns raised during the NRC l Environmental Qualification audit conducted on site from September 18, 1989 to l- September 22, 1989. Potentially deficient equipment was identified, inspected and restored to a qualified installation prior to the affected Unit returning to power. No equipment f ailed as a result of a loss- of function due to incorrectly installed splices and subsequent investigation determined that l there were no safety concerns. Although some of these Post-Accident

! Monitoring . Inst ruments required rework of cable splices, plant safety systems would have "unctioned properly under all required conditions and would not have jeopardized recovery from an accident. There were no adverse safety or radiological consequences as a result of this event. The event did not result in additional risk to the public. This cor:dition is not reportable pursuant to 10CF. 0.73. As such, this is a voluntary LER.

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South Texas, Unit 1

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On September 22, 1989 Unit I was in Mode 6 in a refueling outage and Unit 2 was in Mode 3. It was discovered that the construction installation j requirements for the Regulatory Guide 1.97 Cstegory 2 instrumentation did not include the installation of qualified splices for wiring terminations located in a harsh post-accident environment. This resulted in some installations not '

being qualified to the requirements of 10CFR50.49 and IEEE 323-1974. In addition, the installation requirements did not specify that tae devices ,

requirer to operate efter a Safe Shutdown Seismic event, or their et'sociated tubing, be mounted in a manner to ensure proper operability follow.ng a Safe ,

Shutdown Seismic event as required by the Regulatory Guide and IEEE 344-1975.

A review was performed to identify the potentially non-qualified devices. The installation of these devices and their associated cabling and tubing was inspected to determine if they were properly installed. The deficient  ;

equipnent was identified and restored to a qualified installation prior to the i affected Unit returning to power.

CAUSE OF OCCURRENCE:

The cause of this event was improper design coordination by the Architect ,

Engineer in that the electrical installation procedure did not assure that i Regulatory Guide 1.97 Category 2 instrumentation devices were installed to meet the qualification requirements of 10CFR50.49 and IEEE 323-1974.

ANALYSIS OF EVENT:

i Regulatcry Guide 1.97 Category 2 instrumentation is unique in that the devices ,

are required to be qualified to IEEE 323-1974 and/or 344-1975 if their design l requires functionality in a narsh environment or after a seismic event, I respectively. However, the devices are not required to be powered from a Class 1E source. In addition, the devices are not subject to 10CFR50 Appendix i B, but there are requirements that are implemented which provide control over l activities affecting quality to an extent consistent with the importance to safety of the instrumentation. l Th9 installation requirements at the South Texas Project (STP) are determined by the quality classification of the devices. Regulatory Guide 1.97 l Category 2 instrumentation is classified as " Instrumentation Clast, IC-II*".

This classification requires that these devices be procured to requirements similar to Class 1E instrumentation, including environmental qualification to TEEE 323-1974. The subject devicen were assigned to electrical separation group "N". This means that they are powered by a non-Class IE power source which is highly reliable, as required by the Regulatory Guide; however, the construction electrical installation procedure for separation group "N" equipment did not require that the installation be qualified to tne requirements of IEEE 323-1974 or IEEE 344-1975. The result of this error was that some deviceu did not have splices 2nstalled in a manner consistent with

,the requirements to assure environmental qualification.

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aa " 00. "'J *.W South Texas. Unit I vext u . = um w aac w muw nn l ANALYSIS OF EVENT Cont'd.:

l This event occurred as a result of a construction installation procedure which did not require that Regulatory Guide 1.97 Category 2 instrumentation, classified as " Instrumentation Class IC-II*", be installed to the requirements j of IEEE 323-1974 ano IEEE 344-1975. No equipment failed as a result of a loss of function due to incorrectly installed splices and subsequent investigation

' determined that there were no safety concerns. Plant safety systems would ,

have functioned properly under required conditions and would not have  !

jeopardized recovery from an accident. There were no adverse safety or  !

radiological consequences as a result of this event. The event did not result i in additional risk to the public. As such, this condition is not reportable l pursuant to 10CFRSO.73. j J

C2 1ECTIVE ACTION:

1[) The deficient construction installation procedure is no longer'in use.

2.) A review was performed to identify the potentially non-qualified devices.

The installation of there devices and their associated cabling and tubing )

was inspected to determine if they were properly installed. Non-conforming conditions were documented and discrepancies were resolved prior to the Units' return to power.

3.) The mounting details were examined for the devices, and they were determined to be installed in a manner which would ensure seismic operability, i

f 4.) The installation program followed sv.bsequent to the construction phase of STP was reviewed to assure that splicos installed to the present program requireme:nts are acceptable. The present installation progrcm for Regulatory Guide 1.97 Category 2 instrumentation requires the installation of qualified splices for wiring terminations located in a harsh post-accident environment. Therefore, no additional corrective actions are necessary to prevent recurrence of this event. l 1

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