ML20045H988

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LER 93-012-01:on 930405,TS Violation Occurred Due to Incorrect Settings of Several Molded Case Circuit Breakers. Reset Affected Unit 1 Breakers to Correct Settings. W/930713 Ltr
ML20045H988
Person / Time
Site: South Texas STP Nuclear Operating Company icon.png
Issue date: 07/13/1993
From: Groth J, Pinzon J
HOUSTON LIGHTING & POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LER-93-012, LER-93-12, ST-HL-AE-4514, NUDOCS 9307220230
Download: ML20045H988 (9)


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. The Light c o mp a ny S uth Texas Project Electric Generating P. O.Station Box 289 Wadsworth, Texas 77483 htm @% & P-l July 13, 1993 ST-HL-AE-4514 l File No.: G26 10CFR50.73 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Unit 1 Docket No. STN 50-498 Revision 1 to Voluntary Licensee Event Report 93-012 i Technical Specification Violation due to Incorrect Settings of Several Molded Case Circuit Breakers Pursuant to 10CFR50.73, Houston Lighting & Power (HL&P) submits the attached revision to Unit 1 Voluntary Licensee Event Report (LER)93-012 regarding a Technical Specification violation due to incorrect settings of several molded case circuit breakers.

This event did not have an adverse effect on the health and safety of the public.

This revision documents the result of the final operability determination of the affected loads for both units and the effect on the safety analysis. The results of the breaker testing of the 12 originally declared inoperable loads fed by improperly set breakers determined that these Motor Operated Valve (MOV) loads i were actually operable following analysis of the as-found breaker I settings. Based on these results, the event described in this LER would not be considered reportable per 10CFR50.73, and as such, this LER has been changed to a Voluntary LER. Changes are indicated by revision bars.

If you should have any questions on this matter, please contact Mr. J. M. Pinzon at (512) 972-8027 rmme at (512) 972-8664.

1 rh

. F. Groth ice President, Nuclear Generation JMP/pla

Attachment:

Rev. 1 to Voluntary LER 93-012 (South Texas, Unit 1)

LER-93\L93012R1.U1 Project Manager on Behalf of the Participants in the South Texas Project /g 73D7220230 930713 "" '

PDR ADOCK 05000498 'A g Ii S PDR  ; jj

i 1 l 0 Hous. ton Lighting & Power Company ST-HL-AE-4514 South Texas Project Electric Generating Station File No.: G26 Page 2 l

t c:

Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associate General Counsel 611 Ryan Plaza Drive, Suite 400 Houston Lighting & Power Company Arlington, TX 76011 P. O. Box 61867 Houston, TX 77208 l

Lawrence E. Kokajko Project Manager .

Institute of Nuclear Power

! U.S. Nuclear Regulatory Com:nission Operations - Records Center Washington, DC 20555 13H15 700 Galleria Parkway Atlanta, GA 30339-5957 j Senior Resident Inspector

! c/o U. S. Nuclear Regulatory Dr. Joseph M. Hendrie Commission 50 Bellport Lane P. O. Box 910 Bellport, NY 11713 Bay City, TX 77414 D. K. Lacker J. R. Newman, Esquire Bureau of Radiation Control i Newman & Holtzinger, P.C., STE 1000 Texas Department of Health l 1615 L Street, N.W. 1100 West 49th Street Washington, DC 20036 Austin, TX 78756-3189 D. E. Ward /T. M. Puckett U.S. Nuclear Regulatory Comm.

Central Power and Light Company Attn: Document Control Desk P. O. Box 2121 Washington, D.C. 20555 Corpus Christi, TX 78403 J. C. Lanier/M. B. Lee City of Austin Electric Utility Department ,

721 Barton Springs Road  !

Austin, TX 78704 l K. J. Fiedler/M. T. Hardt City Public Service P. O. Box 1771 San Antonio, TX 78296 1

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1 l

NRC FORM 366 U.S. NtILEAR REGULATC3Y COMMISSI(O APPROVED BY OMB No. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH LICENSEE EVENT REPORT (LER) gS ARD" C(MME

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S RECARDlNG BURD\N ST ATE b THE INFORMATION AND RECORDS MANAGEMENT BRANCH J (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, '

(See reverse for required number of digits / characters for each block) WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK l REDUC 71DN PROJECT (3150-0104), OFF1CE OF l MANAGEMENT ant} BUDGET , WASHING 10N, DC 20503. I IACILITY NAME (1) DOCKET NUMBER (2) PAGE (3)

South Texas, Unit 1 05000 498 1 OF 7 TITLE (4) Technical Specification Violation due to Incorrect Settings of c;evn ra l Molded c a e,n circnit Rreakore EVENT DATE (5) LER WlMBER (6) REPORT DATE (7) OIHER F ACILITIFS INVOLVED (8)

SEQUENTIAL REVISION FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR M NTH DAY YEAR South Texas, Unit 2 NUMBER NUMBER 05000 499 04 05 93 93 --

12 --

01 07 13 93 O 0O OPERATING TH m umT iS mns mSuANT To THE REouluMENu or 10 m e mek one or more) (n)

S CJDE (9) 20.402(b) 20.405(c) 50.73(a)(2)(iv) 73.71(b)

POWER "

0 20.405(a)(1)(ii) 50.36(c)(2) 50.73(a)(2)(vii)

LEt'EL (10) X OTHER 20.405(a)(1)(lii) 50.73(a)(2)(i) 50. 73(a)(2)(vi i i )( A) (Specify in 20.405(a)(1)(iv) 50.73(a)(2)(li) 50.73(a)(2)(viii)(B)

T 20.405(a)(1)(v) 50.73(a)(2)(lii) 50. 73(a)(2)( x ) 366A) Votmtary LICENSEE CONTACT FOR THIS LER (12)

NAME TELEPHONE NUMBER (include Area Code)

Jairo Pinzon - Senior Engineer (512) 972 - 8027 COMPLETE ONE LINE FOR EACH COMPONENT FAILURE DESCRIBED IN THIS REPORT (13)

BLE CAUSE SYSTEM COMPONENT MANUFACTURER p CAUSE SYSTEM COMPONENT MANUFACTURER g SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MON M DAY YEAR YES (If yes, complete EXPECTED SUBMISSION DATE). X No g3 CESTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten lines) (16)

On April 5, 1993, at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, Unit 1 was in Mode 5 at 0% power and Unit 2 was defueled while in a refueling outage. Plant personnel determined that a reportable condition existed because the setpoints of the Class 1E 480 VAC magnetic adjustable molded case circuit breakers were incorrect which could cause potentially unexpected breaker trips. Unit 1 had five loads which were declared inoperable until breaker testing could confirm otherwise. Unit 2 had seven loads declared inoperable. These loads are safety-related motor operated valves (MOVs) in various systems. The cause of this event was that the instructions for setting circuit breaker magnetic adjustable elements did not provide sufficient clarity to ensure consistent application. Corrective actions include revising the test procedure to clarify the methodology used to establish the breaker setpoints and conducting training on the procedure and test methodology. l Analysis of safety-related molded case circuit breakers was performed to i determine if the loads were, in fact, actually inoperable. The results of  !

the breaker testing of the 12 originally declared inoperable loads fed by improperly set breakers determined that these MOV loads were actually operable following analysis of the as-found breaker settings.

NRC FORM 366 (5-92) l

)

l LER-93\t93012R1.U1 i l

)

__ _ _ _ n

.NRC FORM 366A U.S. NUCLEAR REGULAI C Y COMMISSI C APPROVED BY OMB NO. 3150-0104 (5-92) ' EXPIRES 5/31/95 ESTIMATED BUSDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESilMATE TO THE LICENSEE EVENT REPORT (LER) INFORMATION AND RECORDS MANAGEMENT BRANCH (MNBE 7714), U.S. NUCLEAR REGULATORY COMMISSION, TEXT CONTINUATION WASHINGTON, DC 20555-0001 AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE Of MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NUMBER (2) LER NUMHFR (65 PACE (3)

SEQUENTIAL REVISION YEAR

"#8" "#8" South Texas, Unit 1 05000 498 2 OF 7 93 -- 12 -- 01 TEXT (If more space is reautred. use additional copies of NRC form 366A) (17)

DESCRIPTION OF EVENT:

On April 5, 1993, at 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, Unit 1 was in Mode 5 at 0% power and Unit 2 was defueled while in a refueling outage. Upon completion of reportability review, plant personnel determined that a Technical Specification violation had occurred due to the fact that setpoints of the Class 1E 480 VAC magnetic adjustable molded case circuit breakers were incorrect which could cause potentially unexpected breaker trips. This rendered several Unit 1 and Unit 2 loads, all safety-related Motor Operated Valves (MOVs) in various systems, inoperable.

On March 23, 1993, at 1655 hours0.0192 days <br />0.46 hours <br />0.00274 weeks <br />6.297275e-4 months <br />, station personnel identified the possibility j of a potential misapplication of the instructions contained in the Electrical i Setpoint Index. These instructions establish the setpoint for the calibration )

of the Class 1E 480 VAC magnetic adjustable molded case circuit breakers.

Operability and reportability reviews were initiated per procedure. A  ;

walkdown of all Class 1E 480 VAC motor control center breakers was performed 1 1

to determine the existing trip setpoints. This walkdown was completed on March 30, 1993, for Unit 1 and March 31, 1993, for Unit 2.

At 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, on April 5, 1993, plant personnel determined, based on the i reportability review, that incorrect breaker setpoints did exist and could l cause potentially unexpected breaker trips. l Unit 1 contained seven Class 1E breakers with setpoints below the required setting, four Class 1E penetration breakers above the required setting and three Class 1E non-penetration breakers above the required setting. Of these 14 breakers, five of the associated loads (5 of 7 breakers below the required l settings) were declared inoperable. I Unit 2 contained seven Class 1E breakers with setpoints below the required setting, one Class 1E penetration breaker above the required setting, and one Class 1E non-penetration breaker above the required setting. Of these nine breakers, seven of the associated loads (all breakers below the required setting) were declared inoperable.

Therefore, a total of 12 loads fed by improperly set breakers were de.-lared inoperable, until breaker testing could confirm otherwise. The 12 b: kers involved are of a population of 562 breakers. All of the inoperable 1c ,are MOVs in various safety-related systems.

LER-93\L93012R1.U1

,NRC FORM 366A U.S.. NUCLEAR REGULAT OY C0fstISSIC . APPROVED BY OMB No. 3150-0104.

(5-92) EXPIRES 5/31/95.

ESTIMATED BURDEN PEC RESPONSE TO COMPLY WITH THl!

~

INFORMATION COLLECTION REQUEST: 50.0- HRS.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE LICENSEE EVENT REPORT-(LER) INFORMATION AND RECORDS MANAGEMENT , BRANCH (MNBE TEXT CONTINUATION 7714), U.S. . NUCLEAR REGULATORY COMMIS$10N, WASHINGTON, DC 20555-0001 AND TO THE PAPERWORt .

REDUCTION PROJECT - (31$0-0104), OFFICE Of  ;

MANAGEMENT AND BUDGET,' WASHINGTON. DC 20503.' i FAcillTY NAfE (1) DOCKET Ml50BER (2) LFR NL50BER (6D PAGE (3)'

' YEAR SEQUENTIAL REVISION

"#8 E " "#" E "

South Texas, Unit 1 05000 498 3 OF.7  !

93 -- l 12 ' -- 01-  ;

TEXT (if more space is reautred, use additional copies of NRC Form 366A) (17)

DESCRIPTION OF EVENT (Cont'd)

! Unit 1 MOVs affected are: ,

Supplemental Containment Purge Supply Isolation (MOV0003)

L Auxiliary Feedwater to Steam Generator 1B Isolation ~(MOV0065).

L Containment Normal Purge Isolation (MOV0010) l Fire Protection Containment Isolation-(MOV0756).

Accumulator 1C Discharge Isolation'.(MOV0039C) ,

The Unit 2 MOVs affected'are: ,

I Residual Heat Removal' Inlet Isolation.(MOV0060A) l RCFC Chilled Water (MOV0070,'MOV0137)- '

Accumulator 2B Discharge Isolation.'(MOV0039B)

Component Cooling Water RCDT Heat. Exchanger Isolation-(MOV0392)- I

, Fire Protection Containment Isolation (MOV0756)-

l Component Cooling Water' Containment Isolation ~(MOV0404)

The USNRC was notified on April 6, 1993, at approximately 0955 hours0.0111 days <br />0.265 hours <br />0.00158 weeks <br />3.633775e-4 months <br />.

CAUSE OF EVENT:

I The cause of this event was that the instructions for setting circuit breaker magnetic adjustable elements did not provide sufficient clarity to' ensure consistent application. At some point during the maintenance history of these circuit breakers the trip setpoints were incorrectly set based on this misapplication. A contributing cause was that training materials'are not clear relative to this matter.

ANALYSIS OF EVENT:

l The utilization of different methodologies for the determination of magnetic i

adjustable molded case circuit breaker instantaneous overcurrent setpoints resulted in several suspect safety-related breaker setpoints. . As -a conservative measure the connected ' breaker loads were considered - to be inoperable. Determination of the time the setpoint changes occurred revealed that certain breaker loads, if in fact inoperable, would have resulted in failure to comply with the associated Technical Specification action statement and be reportable pursuant to 10CFR50.73 (a)'(2) (i) (B) . However, since none of the twelve MOV loads were actually inoperable, 'this condition. is not reportable per 10CFR50.73 and as such this LER is being submitted as a Voluntary LER.

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{ LER-93\L93012R1.U1

i

.NRC FORM 366A U.S. NUCLEAR REGULATORY CapellSS!C APPROVED BY OMB NO. 3150-0104 (5-92) ' EXPIRES 5/31/95

+

t '

ESTIMATED BURDEN PER RESPONSE TO COMPL7 WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

  • l .

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE LICENSEE EVENT, REPORT (LER) INFORMATION AND RECORDS MANAGEMENT BRANCH (MNBE TEXT CONTINUATION 771').- U.S. NUCLEAR REGULATORY COMMISSION, i

! WASHINGTON, DC 20555 0001 AND TO THE PAPERWORN I

  • REDUCTION ' PROJECT (31$0-0104), OFFICE. OF i

?

MANAGEMENT AND BUDGET, WASHINGTON, DC 20503. l IACILITY NAME (1) DOCKET NUMBER (2) tfR NL20BER (6h' PAGE (3)

SEQUENTIAL REVISION ,

YEAR

"*8" "#""

i South Texas, Unit 1 .05000 498 4 OF 7 93 --

12 --

01- l

- TEXT tif more space is reautred use additional copies of NRC Form 366A) (17)  ;

ANALYSIS OF EVENT: (Cont'd) 5 In the cases where the breakers supply MOVs, the low as-found trip settings .

could potentially result in a breaker trip _during normal: valve operations. .

Whether the subject MOV breakers will trip under these conditions was unknown,

until the actual as-found trip current was established ~ through breaker tests.

Therefore, the MOVs served by the-breakers were considered.to.be inoperable j until testing confirms otherwise. In the cases where the breakers supply-fan  ;

motors or traveling screen motors,'the as-found trip. settings are high enough i to preclude inadvertent breaker trips on motor starting current. This was  !

verified by an actual start of these loads from the~ Unit 1 Control Room on ,

March 31, 1993. The as-found trip settings'are.also.high enough that the j current required to trip the breakers'would only'be present during actual  !

fault conditions. Therefore, the fan motors and traveling screen. motors loads ,

were considered operable.

In the cases where the breakers were set high, a review of appropriate design and vendor documents indicated that.the higher as-found trip settings for the ,

penetration breakers do not.present a detrimental condition L af fecting r the i operability of the loads, and therefore do not render the' associated' loads .!

inoperable. At the higher trip settings, the loads will continue:to function  :

as per design. The higher settings of-the subj.ect circuit breakers are well within the limits established by the penetration : calculation and by the i penetration breaker thermal magnetic breaker surveillance test program. These limits and the backup thermal magnetic trips ensure' that- the associated .

penetration conductors are protected. l s

Therefore, it is determined that the loads associated with the Class 1E penetration breakers which were set high remained operable. The molded case i magnetic adjustable circuit breakers provide protection to the-feeder cables  !

for high current faults. The setting and function of the overcurrent thermal relays and backup thermal magnetic breakers are not affected by the increase in the primary breaker trip settings.

The non-penetrat ' ton magnetic adjustable circuit breakers provide protection to feeder cables under instantaneous current conditions. Raising the trip l settings for the Class 1E non-penetration breakers does not impact the  ;

operability of the associated loads. At the higher setting, the breakers I continue to allow for the starting surge of motors and motor operated valves.

A higher current is required to trip the breakers at this setting.than what would be required with the optimum trip settings.. These loads will thus perform their safety-related shutdown functions. Based on this' reasoning, the  ;

loads associated with the Class 1E non-penetration breakers were determined to remain operable.

LER-93\L93012R1.U1

tiRC FORA.366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED B7 OMB NO. 3150-0104 (5-92) EXPICES 5/31/05 ESTIMOTED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE LICENSEE EVENT REPORT (LER) INFORMATION AND RECORDS MANAGEMENT BRANCH (MNBE 7714), U.S. NUCLEAR REGULATORY COMMIS$10N, TEXT CONTINUATION WASHINGTON, DC 20555-0001 AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE of MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET NtMBE (2) LFR NUMBER (6) PAGE (3)

SEQUENTIAL REVISION YEAR

"" " """ 5 OF 7 South Texas, Unit 1 05000 498 93 --

12 -- 01 TEXT (If more space is reauired. use additional copies of NRC form 366A) (17)

ANALYSIS OF EVENT: (Cont'd)

A total of 12 safety-related loads were initially found to be inoperable. The 12 breakers involved are of a population of 562 breakers. Analysis of safety-related molded case circuit breakers was performed to determine if the loads were, in fact, actually inoperable. The results of the breaker testing and/or analysis of the 12 loads fed by improperly set breakers is described below.

The five Unit 1 MOVs affected are:

Supplemental Containment Purge Supply Isolation (MOV0003)

Auxiliary Feedwater to Steam Generator 1B Isolation (MOV0065)

Containment Normal Purge Isolation (MOV0010)

Fire Protection Containment Isolation (MOV0756)

Accumulator 1C Discharge Isolation (MOV0039C)

A review of breaker information for MOV0756 determined that this breaker was originally set correctly. The Electrical Setpoint Index contained a typographical error which stated the subject breaker to be a 3-amp unit.

However, following review of the associated single line diagram and verification of the installed field condition, the breaker was verified as a l 5-amp unit. The previous operability determination was based on the breaker i setting marks for a 3-amp unit. The as-found setting-marks based on the l correct 5-amp breaker are properly selected for the associated load. Thus, i this safety-related MOV load was operable. This same error occurred on the j Unit 2 breaker. These errors in the Electrical Setpoint Index have been l corrected. l The four remaining MOV loads are also considered operable following analysis of the as-found breaker settings. It was found that there is a substantial margin between the breaker settings and locked rotor currents of the  ;

associated loads. It has been documented that there is a minimum of 32%

margin between the minimum as-found breaker trip settings and the nominal i locked rotor currents of the four associated loads. This is considered to be acceptable margin to justify that these safety-related MOV loads were operable. .

The seven Unit 2 MOVs affected are:

1 Residual Heat Removal Inlet Isolation (MOV0060A)

RCFC Chilled Water (MOV0070, MOV0137)

Accumulator 2B Discharge Isolation (MOV0039B)

Component Cooling Water RCDT Heat Exchanger Isolation (MOV0392) l Fire Protection Containment Isolation (MOV0756) (See above) l Component Cooling Water Containment Isolation (MOV0404)

LER-93\L93012R1.U1 1

l!RC FORM *366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY DMB NO. 3150-0104 l EMPIRES 5/31/05  ;

(5-92)

ESilMATED BURDEN PER RESPONSE TO COMPLY WITH THl!

INFORMATION COLLECTION REQUEST: 50.0 HRS.

""" '" *IE LICENSEE EVENT REPORT (LER) $ $ t[0N""E"IS"*"$"" MAN 4ctMNy"s'g"ANCH aND ggC0RD MN TEXT CONTINUATION 7714), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555 0001 AND TO THE PAPERWORK REDUCTION PROJECT (31$0-0104), OFFICE OF l MANAGEMENT AND BUDGET, WASHINGTON. DC 20503.

]

FACILITY NAME (1) DOCKET NUMBER (2) LER NtMBER (65 PAGE (3)

SEQUENTIAL REVISION YEAR

""" " *"8" South Texas, Unit 1 05000 498 6 OF 7 93 --

12 -- 01 TEXT (If more space is reauired, use additional cooies of NRC Form 366A) (17)

ANALYSIS OF EVENT: (Cont'd)-

These six MOV loads are considered operable following analysis of the as-found breaker settings. It was found that there is a substantial margin between the breaker settings and locked rotor currents of the associated loads. It has been documented that there is a minimum of 44% ma.rgin between the minimum as-found breaker trip settings and the nominal locked rotor currents of the four associated loads. This is considered to be acceptable margin to justify that these safety-related MOV loads were operable.

Based on the fact the MOV loads were, in fact, operable, there was no safety significance of this event.

CORRECTIVE ACTIONS:

1. The affected Unit 1 breakers have been reset to the correct settings.

The Unit 2 breakers will be reset prior to Mode 4 entry. l

2. HL&P will revise the test procedure to clarify the methodology used to establish the molded case circuit breaker setpoints. The revised procedure will be in effect by August 30, 1993.
3. Interim guidance has been provided to Electrical Maintenance on the proper use of the Electrical Setpoint Index.
4. HL&P will conduct training on the test methodology used to establish the molded case circuit breaker setpoints. This training will be completed by July 23, 1993.
5. A review of the circuit breaker maintenance qualification training has been performed to identify any enhancements which should be made to this training. The maintenance qualification training was enhanced.
6. Analysis of safety-related molded case circuit breakers has been performed to determine if the breakers were, in fact, actually inoperable. The results of the breaker testing of the 12 originally i declared inoperable loads fed by improperly set breakers determined that these MOV loads were actually operable following analysis of the as-found breaker settings. Results are occumented in the Analysis 'of Event.
7. HL&P will revise the Electrical Setpoint Index to clarify the adjustable l magnetic breaker trip setting criteria. This action will be completed by August 26, 1993. l I

LER-93\L93012R1.U1

i

.WRC Fokn 366A U.S. NUCLEAR REGULATORY COMMISSI C APPROVED BY DMB NO. 3150-0104 (5-92) ' EXPIRES 5/31/05 ESilMATED BURDEN PER SESPONSE TO COMPLY UlTH THl!

INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO THE

. LICENSEE EVENT REPORT (LER) INFORMATION AND RECORDS MANAGEMENT BRANCH (MNBE TEXT CONTINUATION 771'), U.S. NUCLEAR REGULATORY COMM!$SION, WASHINGTON, DC 20555-0001 AND TO THE PAPERWORx REDUCTION PROJECT (3dO-0104), OFFICE Of MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

FACILITY NAMF (1) DOCKFT NtMBER (?) LFR WlMBER (6'l PAM (3)

SEQUENTIAL REVISION YEAR South Texas, Unit 1 05000 498 7 OF 7 93 --

12 --

01 TEXT (If more space is reouired, use additional copies of NPC Form 366_Al (17)

ADDITIONAL INFORMATION:

During the past two years there have been no events reported to the NRC which involved insufficient clarity of circuit breaker setpoint selection guidelines.

LER 93\L93012R1.U1