ML19332D774

LER 89-018-01:on 890922,discovered That Const Installation Procedure for Reg Guide 1.97,Rev 2 Instrumentation Did Not Include Details to Ensure Qualification Per 10CFR50.49 or IEEE 323-1974.Caused by Installation error.W/891124 Ltr

ML19332D774
Person / Time
Site:	South Texas
Issue date:	11/24/1989
From:	Ayala C, Rosen S HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-REGGD-01.097, RTR-REGGD-1.097 LER-89-018, LER-89-18, ST-HL-AE-3299, NUDOCS 8912050216
Download: ML19332D774 (5)

Text

~ ~

, jj e , .:

1

7. ,o - ;,, =4 i ,

+

f;*

7 .

.The Light companyS uth Texas Project Electric GeneratingPStation O. Box 289 Wadsworth, Texas 77483

- Houston Lighting & Power 1

November 24, 1989 ST-HL-AE-3299 File No. : G26 10CFR50.73 10CFR50.49 j U.S. Nuclear Regulatory Commission l Attention: Document Control Desk l Washington,-DC 20555 ..

South Texas Project Electric Generating Station ~

l Unit l l Docket No. STN 50-498  !

l -Voluntary Licensee Evsnt Report 89-018 Supplement.1 Regarding Imoroner Installation of Rec. Guide 1.97 Catecorv 2-Instrumentation:

Due to an Error in the Installation Details

Reference:

Letter ST-HL-AE-3264 from R. W. Chewning, to.U.S. NRC Document-Control Desk, dated October 26, 1989 Pursuant to 10CFR50.73, Houston Lighting & Power (HL&P)

L . submits the attached voluntary Licensee Event Report '89-018 .

L Supplement; 1 regarding the improper installation of Regulatory Guide 1.97 Category 2 instrumentation pursuant to 10CFR50.49. This *

event did not have any adverse impact on the health and safety of the public.

A statement in the Corrective- Action of the referenced letter has been revised to reflect the 'present recurrence control measures. The revision is identified by a change bar in the margin

.of the attachment. If you should have any questions on this

,. matter, please contact Mr. C. A. Ayala at (512) 972-8628, or myself L at (512) 972-7138.  ;

S. L. Rosen Vice President, Nuclear Engineering and Construction SLR/SDP

Attachment:

LER 89-018 Supplement 1, South Texas, Unit 1 8912050216 891124 PDR ADOCK0500g8 s

L l A Subsidiary of Houston Industrics incorporated 2n.  !

l

~ . . .- - - . ..-.- - - - ...- ~ _ . - _ . . . - . - . . . . . . . . - . _ . - . - . . . . -

7. ,

N y$th  ; , i<!; ', -

~^

W; F O

j 1

- < t

. S. U Y s

-s-1 Houston Lighting & Power Company _ST HL- AE- 3299 ' .,

1. 2 South Texas Project Electric Generating Station _

File No.: G26  ;

Page 2: 1 u

cc <

Regional Administrator, Region IV.

Rufus S.; Scott .

-Nuclear,RegulatoryJCommission-

~

Associate General' Counsel 'l

, l611 Ryan Plaza _ Drive;-Suite 1000 Houston Lighting & Power Company-Arlington, TX 76011- P. 0. Box 1700 ,

ac . - Houston, TX' 77001 George Dick, Project Manager .

t U.S. Nuclear Regulatory Commission- ' INPO.

e Washington,'DC 20555. Records Center 1100 Circle 75 Parkway- .

m[p,y~

JTI(\Tapia- . Atlanta, GA 130339 3064 )

-Senior Resident Inspector

c/o;U. S.' Nuclear Regulatory Dr. Joseph M. Hendrie

Commission 50 Be11 pore Lane P.

5P. 0. Box 910 Be11 port, NY 11713 Bay. City, TX 77414 D. K. Lacker sc J. R. : Newman, Esquire Bureau of Radiation Control 3k lNewman_& Holtzinger,:P.C.. Texas Department of Health' JE 1615 L Street, N.W.E 1100 West 49th Street "6 Washington,- DC 20036 Austin, TX 78704 l R.'.L.= Range /R. P..Verret

<lyp (Central Power & Light Company

"" :P. 0. Box.2121.

r; . Corpus-Christi','TX 78403-

'J.:C. Lanier Director-of Generations.

City of Austin Electric Utility 1721 Barton' Springs Road

~ Austin, TX 78704

- R~. J. Costello/M. T. Hardt

. City Public1 Service Board P. O. Box 1771

, San Antonio, TX 78296

s Revised 11/15/89 L4/NRC/

s = -  % m---- w == w + a,ve -r , y

% 'N a

-s 'I _ ATTACHME T

1. • ST-HbAE- -

• • 4l"' , PAGE- M OF #5 v ' auca=vmoav ===oa APPROVID Out NO 3194 0104 1

(

3 LICENSEE EVENT REPORT (LER) Ex*mts

• we l 1

• ACILITV NAmt m .

DOCet!T Nuesnah m raus m l South' Texas, Unit 1 0 ls I o l o 1 o I41918 MoFl013 )

Voluntary Licensee Event Report 89-018 Regarding Improper Installation of Reg. l 4 Guide IL97 Catecorv 2 Instrumentation Due to An Error In the Installation Details  ;

EVENT DATS (S) Lt h NU.A.E R tel REPORY DATE 17. OTHER F ACILITIES 4NVOLVEO ten 38Q '^4 MONTH DAY YEAR YEAR u , d Q',su q MONTH DAY YEAR ' ACILIT Y hawas DOCKE T NVwatRIS) j South Texas Unit 2 ol510tolo1 4;991 l

~ -

0l9 2l2 89 8l 9 0 l lj 8 0l1 1l1 2l4 8l9 oistogojo, l l

,,,,,,,,,, T n PORT .v mO PUR.uANT TO T 6 = OumiME Nu o, . C.R i ,CA . .. ., - ., ,~ ,.,,...,, m >

====> 6 ,, mi., nom un.iu.i n m.i yg o i o, o n simmm w.wmm ee nmu.i nmi ,

n.,

n mmmi .

imm

==mm mn .imm w.iun an.im...onAi x

=, ggg;,,

o m aammiNi u nenene u nmiu"***' Voluntary  ;

. .Os t.It1 H.6 50 nt.H2Hm 90 731.H2Hal l

LICENSEE CONTACT Post THl3 LER 112)

NAME TELEPHONE NUMBtm ARE A COOT Charles Ayala-Supervisor Licensing Engineer 5,1,2 9,7,2, ,8,6 COMPLETE ONE LINE FOR E ACM COMPONENT F AILURE DESCMISED IN THl$ REPORT (13:

3 Q CAUSE SYSTEM COMPONENT "AyyTg A C- O N,a s' CAU$t $V ST E M COMPONENT "'y AC "3gy",T,Agt iL .

1 I I l l l l l 1 I I I I I

• l ^l I l~ l l l I I f 1 l l l EUPPLEMENTAL REPORT EXPECTED H4i MONTH DAv vtAR SU8 Mis $ TON

~~~) st$ no v ..-Pi.,. exPecreo sveviss 08 Oa rts D NO y l 'l l A=YRACT a,,.,,n,,= .o .. . ,.. ,,,,, ,, - . ...o nei On September 22, 1989 Unit 2 was in Mode 6 in a refueling outage and Unit 2 was in Mode 3, it was determined that the construction installation procedure for Regulatory Guide 1.97 Category 2 instrumentation did not include installation details that would assure the devices are qualified to the requirements of 10CFR50.49 and IEEE 323-1974. This was discovered as a result

~

R of the followup investigation into concerns raised curing the NRC Environmental Qualification audit conducted on site from September 18, 1989 to September 22, 1989. Potentially deficient equipment was identified, inspected and restored to a qualified installation prior to the affected Unit returning j' to power. 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. Although some of theso Post-Accident Monitoring Instruments required rework of cable splices, plant safety systems l would have functioned properly under all required conditions and would not have j eopardized recovery f rom 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 condition is not reportable pursuant

(~ to 10CFR50.73. As such, this is a voluntary LER.

NL.LER89018.U1 l ~"s t- -

K . - _ _ _ _ _ _ _

0g ' __

ATTACHMENT '

ST HL MAE 32M t.a '*

BAAF Ar #"  !

LICENSEE EVENT RE RT (LER) T XT CbNTINUATION

• no so o o LXPintS 8/3126

l paceteTv asaast tis oocetti muassan Gi tan ausssa toi pass tal =

I

, .. y= -

=.;: '

South Texas, Unit.1 rena ..m.n mm-omcu mmvnn o s lo lo o l4 l 9l 8 8l9 --

O l.ll 8 --

0l1 0l 2 0F 0l3 l

, DESCRIPTION OF OCCURRENCE:

On September 22, 1989 Unit 1 was In Mode 6 in a refueling outage and Unit 2 l was in Mode 3. -It was discovered that the construction installation-requirements for the Regulatory Guide 1.97 Category 2 instrumentation did not include the installation of qualified splices for wiring tenninations 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 i f addition, the_ installation requirements did not epecify that the devices-required to operate after a Safe Shutdown Seismic event, or their associated tubing, be mounted in a manner to ensure proper operability following a Safe Shutdown Seismic event ~as required by the Regulatory Julde and.IEEE 344-1975.

A review was performed to identify the potentially non-qualified devices. The installation of these devices and their casociated cabi.ing and tubing was inspected to determine if they were properly installed. The deficient equipment was identified and restored to a' qualified installation prior to-the 1 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-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: '

Regulatory 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 det gn requires functionality in a harsh environment or after a seismic event, respectively. However, the devices are not required to be powered from a j Class IE source. In addition, the devices are not subject to 10CFR50 Appendix

'B,'but there are requirements that are implemented which provide control over ~

activities affecting quality to an extent consistent with the importance to safety of the instrumentation.

l The installation requirements at the South Texas Project (STP) are determined by the quality classification of the devices. Regulatory Guide 1.97 Category 2 instrumentation is classified as " Instrumentation Class IC-II*".

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

the requirements to assure environmental qualification.

NL.LER89018.U1 l g,,o- m,

,~ ,

ATTACHMENT -

e w.* -

ST Hl. AE- M49 ,

senc ewa asea - FPut 7 UF c' -

u s avetta e erva'oav co=aa'as'o=

• • 'f -

'

• LICENSEE EVEluT ner uni ism isai Lw,... ATION_ anaono ove =o ano-oio.

E XPIRE S 8731 46 faCILifY AlaAAS Og DOCKET NutSit GI ggn Nyassia tel Pact 01

"^a "d,W -

"'J' *.'N I South Texas, Unit' 1 -

olslololol4 l9l8 8l 9 0l1l8 0l1 0 l3 or 0 l3 ,;

rixv n . w mm.wanc e mmun ANALYSIS OF EVENT Cont'd.:

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 "Instrumentatien Class IC-II*", be installed to the requirements.

of IEEE'323-1974 and 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' vere no safety concerns. Plant safety systems woul.d- ,

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 g in additional risk to the public. As such, this condition is not reportable pursuant to 10CFR50.73.

CORRECTIVE ADTION:

1.) The deficient construction installation procedure is no longer in use, l-2.) A review was performed to identify the potentially non-qualified devices.

The installation of these devices and their associated cabling and tubing l.

was inspected to determine if they were properly installed. Non -

conforming conditions were documented and discrepancies were resolved i prior to the Units' return to power.  ;

i 3.) The mounting details were examined for the devicer., and they were ,

.. determined to be. installed in a manner which would ensure seismic l- operability. 1 l 4.) The installation program followed subsequent to the construction phase of

! STP was reviewed to assure that splices installed to the present program L requirements are acceptable. During this review performed under Station l Problem Report 890706, the need to modify the specifications governing i

the installation of cable splices and instrument tubing asacciated with Regulatory Guide 1.97 instrumentation was identified to prevent

, , recurrence of the identified conditions during future modification / maintenance activities. These specification / procedure

(~ revisions will be tracked under this Station Problem Report. No l

additional corrective actions are necessary to prevent recurrence of this event.

L 1.

l l

NL.LER89018.U1 g,oau au

.- . . . - _ . _ .