ML20085L469
| ML20085L469 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/25/1991 |
| From: | Hairston W ALABAMA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9111040179 | |
| Download: ML20085L469 (2) | |
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, 5-cp Octeber 25, 1991 Milhillllli POWCf
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Docket No. 50-348
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10 CFR 2.201 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant, Unit 1 Reply to Notice of Violation Report Number 50-348/91-18-01 MC__10spection of Auaget 19 - Sep1 mber 17. 199[
Gentlemen:
This letter refers to the violation cited in the subject inspection report.
The violation states:
Technical Specification 6.8.1 requires that applicable written procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, 1978 shall be establ'shed, implemented and maintained.
Procedure FNP-0-AP-52, Equipment Status Control And Maintenance Authorization, Revision 16, Section 5.1, requires corrective maintenance to be requested and documented on a maintenance work request (MWR).
Section 7.6 requires that prior to performing maintenance, proper unit or system conditions must be established, formal permission must be granted and an MWR must be filled out prior to releasing the system, subsystem, train, component or device.
Procedure FNP-0-AP-14, Safety Clearance and Tagging, Revir, ton 11 Section 3.14, states in part " Personnel shall not be used in lieu of (clearance) hold tags.
Such live clearances are not adequate protection and are explicitly forbidden."
Section 3.2, requires all operational and maintenance practices used in conjunction with safety clearance and tagging to comply with the applicable sections of the Alabama Power Company Safety and Health Manual.
This manual, Section 102.04, Clearance Procedures - Electrical and Mechanical, requires employees to comply with written clearance procedures for the work to be performed and consider all installed mechanical equipment to be in service until the equipment has been properly tagged.
Contrary to the above, on Aug"st 27, 1991, at approximately 10:00 p.m., maintenance was initiated on the "l-2A" diesel generator (D/G) "A" air start system air compressor, without first obtaining an approved MWR. Additionally, a plant system operator was used as a " live clearance" to prevent operation of the D/G air start air compressor, in lieu of properly authorized hold tags.
.This is a Severity Level IV violation (Supplement 1).
O 911104017? 011029 l
PDR ADOCK 05000345 11)
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U. S. Nuclear Regulatory Commission Page ?
Mmisttoisr_ pen tal lhe above violation occurred as described in the subject report.
In addition to the procedures listed in the violation, Administrative Procedure INP-0-AP-6, " Procedure Adherence," Revision 2, Section 5.1, states, "In cases of emergency, all personnel are authorlied to depart from plant procedures provided that such departure is necessary to prevent injury to personnel, danger to the public, or damage to the facility."
Section 5.4 requires, "At the termination of the emergency, an incident report shall be ptepared by the person invoking the emergency changes...."
At the time of the event described above, the IC Diesel Generator was out of service, lhe IC and 1-2A Diesel Generators supply Irain A emergency power for both Units 1 and ?.
If the 1-2A Diesel Generator had become inoperable,1 rain A emergtncy power for both units would have been unavailable.
Iha Shift Supervisor evaluated the potential loss of both air compressors on the 1-?A Diesel Generator and decided that if4P Al'6 was applicable.
Reascalor_Ylolativa 1his violation was caused by personnel error in that the Shift Supervisor f ailed to document his actions i.er liiP-0-AP-6, # Procedure Adherence."
C Deft t11YLAt t10 R._lde rL A!KLRnu llLAthiC Y C d An MWR was prepared documenting and functionally accepting the maintenance work performed. Deviation from INP-0-AP-14 and liiP-0-AP-52 was documented on incident Report Number (IR) 1-91-264 per INP-0-AP-6.
C0 mil i ydt t p s_t 0_AYDJilurther_Y101A11001 1his event has been discussed with all Shift Supetvisors.
DalL0ilVlLCOTplj ante September 30, 1991 sfitrMt.19B 1 affirm that this response is true and complete to the best of my knowledge, information, and belief.
lhe information contained in this letter is not considered to be of a proprietary nature.
Respect f ully submit ted, Al AllAMA POWL R LOMPAfiY
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W. G. Ilairston, 111 WCH, !!!/lillW: map 1143 cc: Mr. S. D. Ibneter Mr. S. 1. Hoffman Mr. G. I. Maxwell
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