ML20091M424

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Responds to NRC Re Violations Noted in Insp Rept 50-266/91-019 & 50-301/91-019.Corrective Actions Are Stated in .Planking Not Loose & Did Not Require Addl Mooring
ML20091M424
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 01/23/1992
From: Zach J
WISCONSIN ELECTRIC POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-92-007, CON-NRC-92-7 VPNPD-92-043, VPNPD-92-43, NUDOCS 9201290082
Download: ML20091M424 (2)


Text

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.Wisdonsin

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'Becinc POWER COMPANY r

231 W Mdhypq, Po Box 2046 wwoukee. W153201 (414)2202345 E

LVPNPD-92-043

'NRC-92-067

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January 23,:1992-zU.[S.-.40 CLEAR REGUT.ATORY COMMISSION Docr. ment Control Desk Maji Station F1-137 Washington, D.

C.

20555 Gentlemen:-

DOCKETS 50-266 AND 50-3Q1 AMENDED RESPONSE TG NOTICE OF VIOLATION y

_ INSPECTION REPORT 50-265/91019 (DRP);

50-3 01/91019 - (DRP)

POINT BEACH NUCLEAR' PLANT. UNITS 1 AND 2

. l;:

~

On October 128, 1991,. a Notice of-Violation (NOV) was issued with fthefsubject Inspectiel Report as a-result of findings during a

. routine unannounced safety inspection conductedLby the=NRC Resident Inspectors.

We initially responded to the NOV in a letter. dated NovemberT27,-.-1991.

Violation "B" of theLNOV

-addressed scaffolding whichfwas' improperly erected in the

vicinityfor the plant safety in4ection pumps. -This-is an

' amendment to'that response.

a<

R In,our response to this citation, we acknowledged-the violation.

However, we.tcok11ssue with the portion ~of-the citation a

2concerning thu securing =of~the-planking;to.the. scaffold.

iCheck1list MT-114 requires scaffold =pianks-in safe shutdown arcan tv beicleated'or:wiredTdown.

During our initial. investigation of j;

fthisLevent, it1was - our urr'.erstanding that (backlist _ MT-114 had been properly completediand that, therefore, the' planking was not j

11oose and did.not, require. additional mooring, m,[I IAfter submittalLof4thisLresponse,-the issue of securing of the P

plankinpfwaalagain' questioned by our Resident. Inspector, Mr.

Gadzala.. We subsequently 1 investigated 1thisfissue-moro closely.

4 1After?furthor'discussionsLwith.the involved personnel, we now believe.thatitheEplankinglhad not been secured to~the-scaffold l structure by' cleats or wires.

Thus, the description of'the state of the: scaffold planking in the NOV was correct as. stated.

As a-e result of this additional 1 investigation, we acknowledge that our initial respor.se to:this violation improperly characterized the

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  • January 23, 1992 l

page-2 condition.of'the scaffolding.

However, we have concluded t. hat corrective Lctions committed to in our November 27, 1991, letter regarding this violation remain applicable, x

a The Inr.pection Report also cited _an additional example of improper construction of a scaffold near the switchgear room bypass alternate shutdown panel.

The Inspection Report stated that a scaffold had been erected in a safe-shutdown area but the area was not delineated as such on~the maps included in PBNP 3.4.8, "Trancient Comburtible Control."

The report also stated

- tnat PBNP 3.4.8 appeared somewhat ambiguous.in its description of safe shutdown areas..

~ 11 ~ response to this concern, PBNP 3.4.8 has been revised

-(c'.evision 9, to be issuod in January _1992) to clarify the above ambiguities.

The definition of safe shutdown area has been changed to include only those identified fire zones whi;h contain

-or, expose-systems, components, or cables that, if damaged by fire, vould require tho-use of an alternate system or component to achieve plant. cold shutdown in accordance with Appendix R requirements.

Using this clarification, the switchgear room bypass alternate shutdown' panel has been determined not to'be located in a-safe shutdown area and will not be delineated as

- such on the figures of PBNP:3.4.8.

In addition, the figures highlighting the safe chutdown_ areas remain unchanged from Revision 8=(issued November 3, 1989).

However, the method of delineating the safe shut awn areas on the figures will be

- referenced in the text of the-procedure to clarify the ambiguity

' indicated in the Inspectior. Report.

If you.have any questions concerning this information, please

-contact us.

. Sincerely, r

g c4 c

-Jam S J.

Zach Vice President Nuclear Power copies to NRC Regional Administrator, Region III

.NRC Resident Inspector

.