ML20113G213

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Revises 911025 Response to Violations Noted in Insp Rept 50-348/91-18 on 910819-0917.Corrective Actions:Maint Work Request Prepared,Documenting & Functionally Accepting Maint Work Performed on Diesel Generator Air Start Sys
ML20113G213
Person / Time
Site: Farley Southern Nuclear icon.png
Issue date: 10/28/1991
From: Hairston W
ALABAMA POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9111050019
Download: ML20113G213 (3)


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Docket No. 50-348 10 CfR 2.201 U. S. Nuc1 car Regulatory Commission Attention:

Document Control Desk Washington, DC 20555 Joseph M. f arley Nuclear Plant, Unit 1 Reply tr. Notice of Violation Report Number 50-348/91-18-01, Revision 1 MLLOJuttilstL9Lhlu191t_L2 - SfninAer 17. IL91 Cent 1 3.nen :

Ihis letter revises Alabama Power Company's previous reply to the subject vi_olation dated October 25, ;991 in order to clarify the statement of admission, lhe violation states:

Technical Specification 6.8.1 req'llres that applicable written procedures reconnended in Aprendix A of Regulatory Guide (RG) 1.33. Revision 2, 1978 shall be established, implemented and maintained.

Procedure FNP-0-AP-52, Equirwnt Status Control And Mainter,ance Authorization, Revision 16 Sectton 5.1, requires corrective maintenance to be requested and documented on a maintenance work request (MWR).

Section 7.0 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, Revision 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 r

all operational and maintenance practices used in conjunction with safety clearance and taggin<, 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 siearance pi

  • dures for the work to be performed and consider all installea mechanical equipment to be in service until the equipment has been properly tagged.

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U. S. Nuclear Regulatory Commission Page 2 Contrary to the above, on August 27, 1991, at approximately 10:00 p.m., maintenance was initiated on the "l-2A" diesel generator (0/0)

"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 tie 0/G air start air compressor, in lieu of properly authorized hold tags.

This is a Severity Level IV violation (Supplement 1).

Admission or Dn ial The above violation occurred as described in the subject report.

In addition to the procedures listed in the violation. Administrative Procedure FNP-0-AP-6, " Procedure Adherence," Revision 2. Section 5.1, states, "In cases of emergency, all personnel are authorized to depart from plant irocedures 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 prepared by the person invoking the emergency changes...."

At the time of the event described above, the 10 Diesel Generator was out of service.

The IC and 1-2A Olesel Generators supply Train A emergency power for both Units 1 and 2.

If th9 l-2A Diesel Generator had become inoperable,. Train A emergency power for both units would have been unavailable.

The Shift Supervisor evaluated the potential loss of both air comortssors on the 1-2A Diesel Generator and decided that an emergency l

situation existed.

Reason for Viol _a dE0 1

This violation was caused by personnel error in that the Shift Supervisor failed to document his actions per FNP-0-AP-6, " Procedure Adherence.,"

Correcti.ye Action Taken and Reiults Achievtd An MWR was prepared documenting and functionally accepting the maintenance work performed. Deviation from FNP-0-AP-14 and FNP-0-AP-52 was documented on incident Report Number (IR) 1-91-264 per FNP-0-AP-6.

[orrective $1 cps to Avoid further Violatiq u This event has been discussed with all Shift Supervisors.

Qate of full Compliance September 30, 1991 L

O U. S. Nuclear Regulatory Commission Page 3 Affirmation I affirm that this response is true and complete to the best of my knowledge, information, and belief.

The information contained in this le'.ter is not considered to be of a proprietary nature.

Respectfully submitted.

ALABAMA POWER COMPANY

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W. G. llairston, 111 WGil, Ill/BHW: map 1143 cc:

Mr. S. D. Ebneter Mr. S. 1. Hoffman Mr. G. F. Maxwell I

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