ML13018A013

Initial Exam 2012-301 Post Exam Comments

ML13018A013
Person / Time
Site:	Saint Lucie
Issue date:	01/18/2013
From:	NRC/RGN-II
To:
References
Download: ML13018A013 (23)

Text

ES-501 St. Lucie Facility I Applicant NRC Written Exam Comments Attachment I Question #7 Given the following conditions on Unit 1:

The unit is currently in Mode 6, shutdown for a refueling outage.

Time since reactor shutdown is 500 hrs.

The Reactor Head is being de-tensioned.

BOTH trains of Shutdown Cooling (SDC) are in service.

Reactor Coolant System (RCS) temperature is 105° F.

The RCS level 35 feet.

A Loss of Offsite Power (LOOP) has just occurred.

BOTH Emergency Diesel Generators (EDGs) started and loaded onto their respective busses.

1) AT THIS TIME, the LPSI pumps_(1)

2) If the LPSI pumps did NOT start, the Time to Boil is approximately_(2)_

minutes.

A. 1) require manual re-start after the vital busses are re-energized 2)30 B. 1) auto started on EDG load sequencing 2)30 C. 1) require manual re-start after the vital busses are re-energized 2)41 D. 1) auto started on EDG load sequencing 2)41 Comment: Part 2 of Question 7 requires the use of Attachment 1 of I -AOP 03.02, Shutdown Cooling Abnormal Operations. The reference provided to the applicants as part of the exam package was Rev. 5 of I -AOP-03.02 (Refer to the As-Given Exams for this submittal). However, the official answer key reflected an answer (30 minutes) calculated from Rev.6 of 1-AOP-03.02 (Refer to St.Lucies written exam sent to the NRC as part of the 45 day submittal). All thirteen applicants performed the time to boil calculation using the provided reference (Rev.5) and derived a time to boil of approximately 40 minutes. Based on that, all thirteen applicants chose answer selection C.

FPL Utility Position: Based on the fact that the candidates correctly computed the time to boil from the references given to them and that there was an answer selection that closely matched that calculated value, accept answer selection C as the correct answer.

1

ES-501 St. Lucie Facility I Applicant NRC Written Exam Comments Attachment I Attached are the candidates original calculations from Attachment I of 1-AOP-03.02 Rev.5. as well as an answer key using 1-AOP-03.02 for comparison.

2

Aisu2 io E-63W+ US(Jt REVISION NO.:

PROCEDURE TITLE:

PAGE SHUTDOWN COOLING ABNORMAL OPERATIONS 19 of 31 PROCEDURE NO 1-AOP-03.02 ST. LUCIE UNIT 1 ATTACHMENT I Estimated Time to Core Boiling (Page 1 of 5)

DETERMINE estimated time to core boiling as follows (Section 6.2 Commitment 2):

A.

RECORD the following information at the time SDC was lost:

Time Shutdown Cooling Lost from Section 4.2 Step 2 RCS Temperature from Section 4.2 Step 2 jQS

°F Vessel / Cavity Level ft Time since shutdown (hours) 00 B.

RECORD time to boil at mid-loop per Table 1:

30.

(minutes)

C.

RECORD additional time to boil for a 100 ft3 volume per Table 2:

2-. IS (minutes / 100 ft 3

).

0.

RECORD additional 100 ft3 volumes above mid-loop per Table 3:

4.44 (100ft 3

)

E.

CALCULATE Time to Boil as follows:

3o4

+

2 4

• 1 = 4.o.os Time to boil Additional time to boil Additional 100 ft3 volumes Time to Boil Stepl.B Stepl.C Stepl.D 2.

IF core shuffle or reload has NOT been competed, THEN CALCULATE time boiling will occur as follows:

+

=

Time SDC Lost Time to Boil Time Boiling Will Occur Step 1.A Step 1.E

REVISION NO.:

PROCEDURE TITLE:

PAGE:

SHUTDOWN COOLING ABNORMAL OPERATIONS 20 of 31 PROCEDURE NO.:

1-AOP-03.02 ST. LUCIE UNIT 1 ATTACHMENT I Estimated Time to Core Boiling (Page 2 of 5) 3.

IF core shuffle or reload has been completed, THEN CALCULATE time boiling will occur as follows (Section 6.1.3 Management Directive 1):

+

x(1.35)

=

Time SDC Lost Time to Boil Time Boiling Will Occur Step 1.A Step 1.E

ATTACHMENT I Estimated Time to Core Boiling NOTE Temperatures between columns, select higher temperature.

Time since shutdown between rows, select the lesser time.

Table 1 Time to Boil (minutes) at Mid-Loop Shutdown 60 80 90 100 110 120 130 140 200 Time (Hours) 24 14.7 12.7 11.8 10.8 9.81 8.84 7.87 6.91 1.21 48 17.9 15.6 14.4 13.2 12.0 10.8 9.61 8.44 1.48 60 19.4 16.8 15.5 14.3 13.0 11.7 10.4 9.13 1.60 72 20.8 18.1 15.7 15.3 13.9 12.5 11.2 9.80 1.72 90 22.9 19.8 18.3 16.8 15.3 13.8 12.3 10.8 1.89 102 24.1 20.9 19.3 17.7 16.1 14.5 12.9 11.4 1.99 120 25.9 22.5 20.8 19.1 17.3 15.6 13.9 12.2 2.14 132 27.1 23.5 21.7 19.9 18.1 16.3 14.5 12.7 2.23 144 28.1 24.4 22.5 20.6 18.8 16.9 15.1 13.2 2.32 240 34.7 30.1 27.8 25.5 23.2 20.9 18.6 16.3 2.86 300 37.8 32.8 30.3 27.7 25.3 22.8 20.3 17.8 3.12 360 40.6 35.2 32.5 29.8 27.1 24.4 21.7 19.1 3.35 480 45.8 39.7 36.6 33.6 27.6 24.5 21.5 3.78 600 50.8 44.0 40.7 37.3 33.9 30.6 27.2 23.9 4.19 840 60.6 52.5 48.5 44.5 40.5 36.5 32.5 28.5 5.00 1440 82.7 71.7 66.2 60.7 55.3 49.8 44.3 38.9 6.82 RCS Temperature (°F REVISION NO.:

PROCEDURE TITLE:

PAGE:

SHUTDOWN COOLING ABNORMAL OPERATiONS 21 of 31 PROCEDURE NO.:

1-AOP-03.02 ST. LUCIE UNIT 1 (Page 3 of 5)

ATTACHMENT I Estimated Time to Core Boiling (Page 4 of 5)

NOTE Temperatures between columns, select higher temperature.

Time since shutdown between rows, select the lesser time.

Table 2 Additional Time To Boil (minutes) for Each 100 cubic feet of RCS Volume (Section 6.1.3 Manaqement Directive 2)

Shutdown Time (Hours) 60 80 90 100 110 120 130 140 200 24 1.02 0.886 0.818 0.750 0.683 0.615 0.548 0.481 0.0843 48 1.25 1.08 0.999 0.917 0.834 0.752 0.669 0.587 0.103 60 1.35 1.17 1.08 0.992 0.903 0.813 0.724 0.635 0.111 72 1.45 1.26 1.16 1.06 0.969 0.873 0.777 0.682 0.120 90 1.59 1.38 1.27 1.17 1.06 0.958 0.853 0.749 0.131 102 1.68 1.46 1.35 1.23 1.12 1.01 0.901 0.791 0.139 120 1.81 1.57 1.45 1.33 1.21 1.09 0.968 0.850 0.149 132 1.88 1.63 1.51 1.38 1.26 1.13 1.01 0.886 0.155 144 1.96 1.70 1.57 1.44 1.31 1.18 1.05 0.920 0.161 240 2.41 2.09 1.93 1.77 1.61 1.45 1.29 1.014 0.199 300 2.63 2.28 2.11 1.93 1.76 1.58 1.41 1.024 0.217 360 2.82 2.45 2.26 2.07 1.89 1.70 1.51 1.33 0.233 480 3.18 2.76 2.55 2.34 1.92 1.71 1.50 0.263 600 3.53 3.07 2.83 2.60 2.36 2.13 1.89 1.66 0.292 840 4.22 3.66 3.38 3.10 2.82 2.54 2.26 1.98 0.348 1440 5.75 4.99 4.61 4.23 3.85 3.46 3.08 2.71 0.475 RCS Temperature (°F REVISION NO.:

PROCEDURE TITLE:

PAGE:

SHUTDOWN COOLING ABNORMAL OPERATIONS 22 of 31 PROCEDURE NO.:

1-AOP-03.02 ST. LUCIE UNIT 1

REVISION NO.:

PROCEDURE TITLE:

PAGE:

SHUTDOWN COOLING ABNORMAL OPERATIONS 23 of 31 PROCEDURE NO.:

1-AOP-03.02 ST. LUCIE UNIT 1 ATTACHMENT I Estimated Time to Core Boiling (Page 5 of 5)

NOTE If elevation is between rows, select the lesser value.

Table 3 Additional Volume (100 cubic feet) Above Mid-Loop (Section 6.1.3 Management Directive 2)

Vessel Head

Vessel Head

Vessel Head Installed or Not Installed

Not Installed

Not Installed Elevation Additional Elevation Additional Elevation Additional Volume

Volume

Volume Feet 100 ft3

Feet 100 ft3

Feet 100 ft3 29.5 0.00 36.5 14.20 48.5 229.00 30.0 0.40 37.0 23.15 49.0 237.95 30.5 0.81

37.5 32.10

49.5 246.90 31.0 1.21

38.0 41.05

50.0 255.85 31.5 1.61

38.5 50.00

50.5 264.80 32.0 2.02

39.0 58.95

51.0 273.75 32.5 2.42 39.5 67.90 51.5 282.70 33.0 2.82 40.0 76.85 52.0 291.65 33.5 3.23

40.5 85.80

52.5 300.60 34.0 3.63

41.0 94.75

53.0 309.55 34.5 4.04 41.5 103.70 53.5 318.50 35.0

42.0 112.65

54.0 327.45 35.5 4.84

42.5 121.60 54.5 336.40 36.0 5.25 43.0 130.55 55.0 345.35 43.5 39.50 55.5 354.30 44.0 148.45

56.0 363.25 44.5 157.40

56.5 372.70 45.0 166.35

57.0 381.15 45.5 175.30 57.5 390.10 46.0 184.25

58.0 399.05 46.5 193.20

58.5 408.00 47.0 202.15

59.0 416.95 47.5 211.10 59.5 425.90 48.0 220.05 60.0 434.85

ES-O1 St. Lucie Facility I Applicant NRC Written Exam Comments Attachment I Question #59 Unit 1 is at 90% power, increasing power to 100% at 3MWe / mm. The 1A Main Feedwater Regulating valve (HPFRV) stops responding to the power increase and has failed as is.

Assuming NO Operator actions and the power increase progresses, which of the following states the 1A SG level response?

IA SG level will initially:

A. lower from setpoint until the Low Power FRV opens to return SG level to setpoint.

B. lower from setpoint and continue to lower resulting in IA SG level low alarm.

C. lower from setpoint until the 100% FW Bypass initially opens to control SC level at setpoint.

D. remain at setpoint with the Low Power FRV controlling SC level.

Answer Key: A Comment: The proper answer to question should be answer selection B.

The applicant should correctly assume, from the given conditions, that BOTH the High Power Feed Reg Valve (HPFRV) and the Low Power Feed Reg Valve (LPFRV) would be in automatic (normal operating mode) for the power increase.

With BOTH the HPFRV and the LPFRV in AUTO, then the LPFRV will NOT open to restore SC level for the stated conditions in the stem of the question.

Above 40% [30% on Unit 2] steam flow, the LPFRV gets a hard close signal if both the HPFRV and LPFRV controllers are in AUTO. This is supported in the St.Lucie student lesson text 0711408 and the Foxboro prints marked up by the DCS contractor (attached).

Looking at sheet 4 of the Foxboro prints, the hard close signal is sent to the LPFRV (15% bypass valve) when the steam flow bistable is satisfied at some value between 25-40% steam flow (circle 12) and both controllers are in AUTO (circle 27). Circle 27 is developed on sheet 2 and is ONLY met if BOTH controllers are NOT in manual (i.e.in AUTO).

Therefore since the question does not state that the HPFRV controller is in manual, the LPFRV should not respond to lowering SC level and answer selection B would be the actual plant response.

3

ES-501 St. Lucie Facility I Applicant NRC Written Exam Comments Attachment I A note in 1-AOP-09.O1 also supports the fact that with the HPFRV in manual, the LPFRV could reposition (with its controller in auto).

FPL Utility Position: Based on the above discussion, accept answer selection B as the correct answer.

4

a power levels. For example, a steam flow of 20% (of rated steam flow) will require about 25% power from the reactor. Efficiency is gained as power is increased so any efficiency lost at lower power levels is made up for as power increases.

In the end it all averages out as 100% feedflow (1.2 X i0 7 lbm/hr) equals 100% reactor power (2700 MWT).

The following valve positioning occurs during a plant startup:

The first 3% to 15% feedflow, the 15% Bypass Valve opens alone with the MFRV remaining fully shut.

When the 15% Bypass valve has a 44% Demand-Open signal (15% feedflow), the MFRV gets a signal to Open. This is accomplished by the 44% Demand-Open signal triggering a logic signal back to itself to actuate a negative bias signal. This signal subtracts from the actual Feedflow Demand (FFD) signal coming from the FWCS and results in the 15% Bypass Valve starting to Close (by an amount equal to the bias). The closing of the 15% Bypass Valve is tracked by the MFRV through its own Summer that calculates total FFD and what percentage of that total is being supplied by the 15%

Bypass Valve. Since the 15% Bypass Valve is now supplying less than the total FFD, the deficit is automatically made up by the MFRV.

The output from the MFRV Summer calculates this deficit and it turns out to initially be about 5% flow (and by coincidence 5% open on the MFRV). The 15% Bypass \\/alve ends up at approximately 32% open when this initial flow transfer is complete. Following this transfer, the 15% Bypass Valve again opens alone (and the MFRV remaining steady at 5% Open) until it gets back to 44% Open.

When the 15% Bypass Valve gets back to 44% Open, the MFRV starts to open with it and they share the flow from this point forward. The sharing here is from this point forward only so the 15% Bypass Valve still has the bulk of the flow.

At 20% VALIDATED feedflow, the control system switches from Single-Element to 3-Element control. This is only detectable by the Mode Label on the 1A (1 B) SIG OVERVIEW screen changing from LOW POWER MODE to a HIGH POWER MODE indication.

[30%] steam flow increasing, the 15% BYPASS Valve gets a closed signal.

It is at approximately 85% [60%] Open at this point.

It will ramp closed in about 3

- 4 minutes with the MFRV taking up the additional flow in the same manner as it initially opened, i.e., by PSL 0711408 rev 23 Training Use Only 52 of 101

I making up the difference between total FED and the 15% Bypass Valves share of total FFD.

Above 40% [30%] steam flow, all of the FFD is accommodated by the MFRV. The 15%

Bypass Valve does not open again until a downpower to at least 30% [20%] steam flow as there is a 10% deadband for the Closing /Opening of the 15% Bypass Valve.

FWCS Milestones During An Downpower (Assuming Auto/Auto M/A Station alignment)

A downpower from 100% power is the reverse of the up power with a few differences. One being the requirement for actuation setpoints to have a reset or deadband in order to prevent cycling when plant power is stationary (at a setpoint). DCS deadbands range anywhere from 5%

- 20% depending on the signal and its purpose. The following will describe the milestones in a typical downpower from 100%:

From 100% to 30% (steam flow signal) the MFRV will close in response to the reduced feedflow demand from decreasing power level. Recall that the 15% Bypass Valve closed upon reaching 40% [30%] (steam flow) during the up power so it has been and remains closed up to this point (30% [20%] steam flow).

At 30% [20%] steam flow, the auto close signal that the 15% Bypass Valve received at 40%

[30%] (steam flow) is automatically removed. The 15% Bypass Valve will now respond to SG feedflow demand based on a programmed algorithm. At 30% [20%] steam flow, this programmed response calls for most of the total feedflow demand to be taken by the 15%

Bypass Valve so it responds by going open. This auto opening is detected by the MFRV from the 15% Bypass Valves Feedback-to-MFRV summer circuit and responds by closing an amount equal to the flow amount being taken by the 15% Bypass Valve. How far open the 15% Bypass gets to before it starts to close again depends mainly on the rate of the downpower as feedflow demand is decreasing during a downpower so ultimately both feed water control valves will end up fully closing. As it Opens beyond 44% though it picks up its Bias signal again though which limits its share of the FED to at least 5% less than the total.

At 20% decreasing, the 15% Bypass Valve would not re-open as far as it did on the uppower as there is a 10% difference in feedflow demand (30% vs. 20%). At 20% Steam Flow, the MFRV would initially settle out at an opening that would supply whatever percentage of the total feedflow demand that the 15% Bypass Valve did not take.

PSL 0711408 rev 23 Training Use Only 53 of 101

REVISION NO.:

PROCEDURE TITLE:

PAGE:

4 PROCEDURE NO.:

1 -AOP-09.O1 I INSTRUCTIONS I FEEDWATER CONTROL SYSTEM ABNORMAL OPERATIONS ST. LUCIE UNIT 1 I CONTINGENCY ACTIONS I 6 of 48 4.0 OPERATOR ACTIONS 4.1 Immediate Operator Actions 1.

VERIFY SIC levels between 60%

and 70% NR AND stable.

2.

VERIFY SIG levels are greater than 50% NR.

1.1 IF automatic level control is malfunctioning, THEN TAKE manual control of feed flow and STABILIZE SIG levels to 60% to 70% NR.

2.1 TRIP reactor.

2.2 IF any 100% bypass valve is

open, THEN CLOSE it.

2.3 GOTO 1-EOP-01, Standard Post Trip Actions NOTE A high power feed regulating valve (HPFRV) and its associated low power feed regulating valve (LPFRV) have flow-compensation logic such that operating one in manual with the other in auto may cause the valve in auto to reposition in at attempt to keep the feed flow rate constant.

ES-501 St. Lucie Facility! Applicant NRC Written Exam Comments Attachment I

)

Question #70:

Which ONE of the following is used to administratively control an annunciator that has been out of service for 10 days?

A.

ADM-09.03, Administrative Control Of Defeated Annunciators B.

ADM-0010432, Control Of Plant Work Orders C. ADM-1 7.18, Temporary Modifications D.

OP-AA-101-1000, Clearance and Tagging Answer Key: C

References:

ADM-09.03, Administrative Control Of Defeated Annunciators ADM-1 7.18, Temporary Modifications Comment: BOTH A and C are correct.

Basis: ADM-09.03, Administrative Control OF Defeated Annunciators step 6.4.3 (attached)

A defeated annunciator shall NOT be administratively controlled under this procedure for more than seven (7) consecutive days.

A. The annunciator shall be considered defeated at the date and time of Shift Manager Approval to defeat the annunciator.

B. Prior to exceeding the seven (7) day time limit, one of the following measures shall be satisfied:

1. Restore the annunciator to normal operation, including testing of the annunciator.

OR

2. Temporary circuit modifications to be installed on components that are out of service, i.e., in the Out of Service Log, may be excluded from the TSA process and controlled under a Work Order using ADM-08.12-F01, Maintenance Configuration Control.

OR 5

ES-501 St. Lucie Facility I Applicant NRC Written Exam Comments Attachment I

3. Implement ADM-1 7.18, Temporary System Alteration, and transfer administrative control of the defeated annunciator from ADM-09.03, Administrative Control of Defeated Annunciators to ADM-1 7.18, Temporary System Alteration.

The stem of the question does not state that the annunciator in question has been defeated. It states that the annunciator is Out of service. Out of Service is not a defined term in ADM-09.03 and as used at St. Lucie simply means that the device/component is not In Service.

With no information in the stem as to whether or not the annunciator had been defeated, the student could logically conclude that the annunciator had not yet been defeated and he is being asked what procedure is utilized to defeat the annunciator because the stem does not state that it has been defeated simply that it is Out of Service. This would be time zero, the appropriate procedure to control the annunciator would be ADM-09.03, Administrative Control OF Defeated Annunciators for the first seven days.

FPL Utility Position: accept BOTH A and C as correct.

6

REVISION NO.:

PROCEDURE TITLE:

PAGE:

8 ADMINISTRATIVE CONTROL OF DEFEATED 13 f 21 PROCEDURE NO.:

ANNUNCIATORS ADM-09.03 ST. LUCIE PLANT 6.4 Tracking of Defeated Annunciators 1.

Following Shift Managers approval to defeat an annunciator, Appendix A, Defeated Annunciator Worksheet, and Appendix B, Defeated Annunciator Log Sheet, shall be maintained in the Units Equipment Out of Service Log.

2.

Each shift, the Shift Manager shaH review all defeated annunciators to determine if any defeated annunciator may be returned to service.

A.

The Shift Manager shall expedite efforts to correct problems with the defeated annunciator such that the annunciator may be returned to service as soon as possible.

B.

Actions in progress to correct problems associated with the defeated annunciator should be communicated to the Unit Supervisor (US).

C.

Compensatory monitoring measures shall be reviewed and communicated to the Unit Supervisor (US).

3.

A defeated annunciator shall NOT be administratively controlled under this procedure for more than seven (7) consecutive days.

A.

The annunciator shall be considered defeated at the date and time of Shift Manager Approval to defeat the annunciator.

B.

Prior to exceeding the seven (7) day time limit, one of the following measures shall be satisfied:

1.

Restore the annunciator to normal operation, including testing of the annunciator. (Ref 3.C.1)

OR 2.

Temporary circuit modifications to be installed on components that are out of service, i.e., in the Out of Service Log, may be excluded from the TSA process and controlled under a Work Order using ADM-08.12-FO1, Maintenance Configuration Control. (Ref 3.C.2)

OR 3.

Implement ADM-1 7.18, Temporary System Alteration, and transfer administrative control of the defeated annunciator from ADM-09.03, Administrative Control of Defeated Annunciators to ADM-17.18, Temporary System Alteration.

(Ref 3.C.3)

REVISION NO.:

PROCEDURE TITLE:

PAGE:

8 ADMINISTRATIVE CONTROL OF DEFEATED 14 of 21 PROCEDURE NO.:

ANNUNCIATORS ADM-09.03 ST. LUCIE PLANT 6.4 Tracking of Defeated Annunciators (continued) 3.

(continued)

C.

The defeated annunciator will be removed from the administrative control of this procedure when any of the following conditions have been satisfied.

1.

Independent verification of defeated annunciator restoration and testing as documented on a form similar to Appendix A is complete.

OR 2.

Temporary circuit modifications to be installed on components that are out of service, i.e., in the Out of Service Log, are being controlled under a Work Order using Fig. 4.

OR 3.

The Shift Manager transfers administrative control of the defeated annunciator to the TSA process using ADM-17.18, Temporary System Alteration.

END OF SECTION 6.4

REVISION NO.:

PROCEDURE TITLE:

PAGE:

8 ADMINISTRATIVE CONTROL OF DEFEATED 4

f 21 PROCEDURE NO.:

ANNUNCIATORS ADM-09.03 ST. LUCIE PLANT 3.0 RESPONSIBILITIES 3.1 Requestor I Originator Each individual requesting that an annunciator be defeated shall be responsible for the following:

1.

Ensure NPWO(s) submitted to correct nuisance condition.

2.

Recommendation that an annunciator is a nuisance annunciator.

3.

Recommendation of the method for defeating the annunciators input process signal that causes the nuisance condition.

4.

Recommendation of the compensatory monitoring measures necessary to monitor the defeated input process signal while the annunciator is defeated.

5.

Recommendation of the restoration and testing method for restoring the defeated annunciator to service.

Manager (SM)

SM is responsible for the following:

Determination that an annunciator is a valid nuisance annunciator.

Determination that defeating the nuisance annunciator is appropriate.

Approval of the method used to defeat the nuisance annunciator input process signal.

4.

Approval of the compensatory monitoring measures utilized to monitor the defeated input process signal while the annunciator is defeated.

5.

Approval of the restoration and testing methods for defeated annunciators.

6.

Ensure the defeated annunciator is entered in the Equipment Out of Service Log.

7.

Ensuring that defeating the annunciator does NOT require a License Amendment Request.

8.

Ensuring that compensatory monitoring measures are performed for all defeated annunciators.

9.

Ensuring that the time limit for defeating annunciators is NOT exceeded.

10.

Ensuring that defeated annunciators are returned to normal operation in a timely manner.

E-3tL? Q 7C3 3.2 Shift The 1.

2.

3.

ES-501 St. Lucie Facility I Applicant NRC Written Exam Comments Attachment I

)

Question #83:

Unit us performing a liquid release of the 1 A Waste Monitor Tank when the following alarm is received:

Liquid Waste Rad High N-37 Liquid release flow control valve, FCV-6627X indicates open and will not close from the RTGB.

Chemistry has reported that samples taken just offshore of the discharge canal were over 20 times the applicable concentrations specified in 1 OCFR2O part B.

lAW 1-AOP-06.02, Uncontrolled Release of Radioactive Liquids which ONE of the following is a required SUBSEQUENT Operator action AND what are the reportability requirements per IOCFR5O.72 and IOCFR5O.73?

1) Stop the 1A Waste Monitor pump (1)

2) Initiate an (2)

A. 1) from the Liquid Waste Control panel, AND close FCV-6627X locally

2) LER within 60 days B. 1) locally AND lock closed V21462, Waste Monitor Pumps Discharge to Discharge Canal Isolation valve

2) LER within 60 days C. 1) locally AND lock closed V21462, Waste Monitor Pumps Discharge to Discharge Canal Isolation valve

2) Emergency Notification System (ENS) notification within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

D. 1) from the Liquid Waste Control panel, AND close FCV-6627X locally

2) Emergency Notification System (ENS) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

Answer Key: B 7

ES-501 St. Lucie Facility I Applicant NRC Written Exam Comments Attachment I

References:

APOOI 0721, NRC Required Non-Routine Notifications and Reports NuReg 1022 Section 3.2.9 10 CFR 50.72 10 CFR 50.73 EPIP-Ol, Classification of Emergencies EPIP-02, Duties and Responsibilities of the Emergency Coordinator EPIP-08, Off-Site Notifications and Protective Action Recommendations Comment: BOTH Choices B and C are correct.

Basis:

In accordance APOO1 0721, 60 day LER requirements,....Liquid effluent released to an unrestricted area exceeds 20 times the concentration specified in 10 CFR 20, Appendix B, Table 2, for all radionuclides except tritium and dissolved noble gases, averaged over 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. {50.73(a)(2)(viii)(B)}.

This supports the selected answer B.

In addition to selected answer, also accept proposed choice C.

In accordance with EPIP-Ol, St. Lucie Plant Classification Tool Hot Conditions:

RUI Any Release of Gaseous or Liquid Radioactivity to the Environment Greater Than 2 times the ODCM for 60 Minutes or Longer.

3. Confirmed sample analyses for gaseous or liquid releases indicates concentrations OR release rates greater than 2 times ODCM Limits for 60 minutes or longer.

The stem of the question DOES NOT specify the length of time the release occurred. In addition, the stem provided:

Chemistry has reported that samples taken just offshore of the discharge canal were over 20 times the applicable concentrations specified in I OCFR2O part B In consideration of the time it takes to go off shore and take samples, analyze the samples, AND the stem not defining the length of time to isolate the discharge flow patch, it can be implied that the release continued to occur for greater than 60 minutes.

This would meet the threshold for RUI unusual event classification category.

8

ES-501 St. Lucie Facility I Applicant NRC Written Exam Comments Attachment I In accordance, AP0010721 {50.72(a)(1), (a)(2), (a)(3), and (a)(4),

Immediately after notification of State and local agencies, but not later than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after declaration of emergency class defined in EPIP-Ol.

This supports the stem question:

..what are the reportability requirements per 10CFR5O.72 and 10CFR5O.73?

Additionally, EPIP-02 and EPIP-08:

2.

NRC Notification

a. The NRC is notified using the Emergency Notification System If the stem of the question specified a finite time period to isolate, this point may be mute.

FPL Utility Position: Accept BOTH B and C as correct.

9

REVISION NO.:

PROCEDURE TITLE:

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76 NRC REQUIRED NON-ROUTINE NOTIFICATIONS AND REPORTS 19 of 44 PROCEDURE NO.:

0010721 ST. LUCIE PLANT Immediate ENS notifications and notifications to be made ENS notification as soon as practical as soon as practical and in all cases within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and NUREG-1 022 Event or Condition (within I or 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) other NRC notifications 60-day LER and Special Reports Section RADIOACTIVE RELEASES Airborne radioactivity releases Airborne radioactivity released to an 3.2.9 unrestricted area exceeds 20 times the concentration specified in 10 CFR 20, Appendix B, Table 2, averaged over 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 50.73(a)(2)(viii)(A)}

Liquid effluent releases Liquid effluent released to an unrestricted 3.2.9 area exceeds 20 times the concentration specified in 10 CFR 20, Appendix B, Table 2, for all radionuclides except tritium and dissolved noble gases, averaged over 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

{50.73(a)(2)(viii)(B)}

INTERNAL THREAT TO Any event that posed an actual threat to the 3.2.10 PLANT SAFETY safety of the nuclear power plant or significantly hampered site personnel in the performance of duties necessary for the safe operation of the nuclear power plant including fires, toxic gas releases, or radioactive releases. {50.73(a)(2)(x)}

(Page 5 of 6)

APPENDIX A 10 CFR 50.72 AND 50.73 REPORTS

REVISION NO.:

PROCEDURE TITLE:

PAGE:

75 NRC REQUIRED NON-ROUTINE NOTIFICATIONS AND REPORTS 15 of 43 PROCEDURE NO.:

0010721 ST. LUCIE PLANT APPENDIX A 10 CFR 50.72 AND 50.73 REPORTS (Page 1 of 6)

Immediate ENS notifications and notifications to be made ENS notification as soon as practical as soon as practical and in all cases within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and NUREG-1022 Event or Condition (within I or 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) other NRC notifications 60-day LER and Special Reports Section EMERGENCY CLASS Immediately after notification of State Note

- Although not specifically mentioned 3.1.1 and local agencies, but not later than 1 in 10 CFR 50.73, many emergency class hour after declaration of emergency events involve reportable events involve class defined in EPIP-Ol {(50.72(a)(1),

reportable situations.

(a)(2), (a)(3) and (a)(4))

TECHNICAL SPLCIFICATIONS (TS):

Plant shutdown required by TS Initiations of shutdown required by TS Completion of shutdown required by TS 3.2.1

{50.72(b)(2)(i)} (4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> report)

{50.73(a)(2)(i)(A))

TS prohibited operations or Operation or condition prohibited by TS 3.2.2 conditions

{5073(a)(2)(i)(B)} except when: (1) The Technical Specification is administrative in nature; (2) The event consisted solely of a case of a late surveillance test where the oversight was corrected, the test was performed, and the equipment was found to be capable of performing its specified safety functions; or (3) The Technical Specification was revised prior to discovery of the event such that the operation or condition was no longer prohibited at the time of discovery of the event.

TS deviation authorized by Deviation from TS authorized by Criterion {50.73(a)(2)(i)(C)} same as ENS 1 3.2.3 50.54(x) 50.54(x) {50.72(b)(1)} (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> report) hour

Alert I

Any Release of Gaseous or Liquid Radioactivity to the Environment Greater Than 200 Times the ODCM for 15 Minutes or Longer.

ng Mode Applicability:

All lues:

Note

-nergency Coordinator should not wait until the applicable time has d, but should declare the event as soon as it is determined that the a duration has exceeded, or will likely exceed, the applicable time.

In the e of data to the contrary, assume that the release duration has exceeded olicable time if an ongoing release is detected and the release start time 7OWfl.

0 reading on ANY of the following greater than the Reading shown for 15 ites or longer.

UNIT1:

Monitor Channel Pathway Reading RSC 26-i, Plant Vent (PV) 4 E-01 uCi/cc Eberline 01-07 Normal Ops RSC 26-1, P1 t V t PV Eberline 01-07 an tAS 1.1 E+0i uCi/cc Eberline 01-09 RSC 26-4, Fuel Handing Building 5 3 E+00 uC/cc Ebertine 04-07 (FHB)

I RE 26-62, A Main Steam Line 2 0 E+02 hr Eberline 05-01 Monitor m

RE 26-63, B Main Steam Line 2 0 E+02 mR/hr Eberline 05-02 Monitor RY-23910-i,\\

A S/G Blowdown 9.5 E+05 cpm RY-23920-1\\

B S/G Blowdown 9.5 E+05 cpm UNIT 2:

Monitor Channel Pathway Reading RS 26-90, Plant Vent (PV) 1 0 E+O0 PC-li 622 Normal Ops U

CC RS26-90, Plant Vent (PV) 1 1 E+01 PC-li 622 post-SIAS U

1CC RS 26-90 w/ FHB Diverted to PC-li 622 Plant Vent E-01 uCi/cc RS 26-12, Fuel Handing Building Diverted to Plant PC-il 413 (FHB)

Vent RIM 26-71, A Main Steam Line PC-li 631 Monitor 2.0 E+02 1miir RIM 26-72, B Main Steam Line PC-il 632 Monitor 2.0 E+02 mR/hr RS-26-5, 121 A SIG Blowdown 9.5 E-03 uCi/mi RS-26-6, 122 B SIG Blowdown 9.5 E-03 uCiJml OR D reading on ANY effluent monitor that exceeds 200 times the alarm int established for a current radioactivity discharge permit for 15 minutes iger.

OR irmed sample analyses for gaseous or liquid releases indicates entratioris OR release rates greater than 200 times 00CM Limits for 1 5.._

tes or longer.

1. VALID reading on ANY of the following greater than the Reading shown for 60 minutes or longer.

Monitor Channel Pathway Reading RSC 26-I, Plant Vent (PV) 9.4 E-03 uCi/cc Eberline 01-05 Normal Ops RSC 26-i, PlaritVent(PV) 1.1 E-0i uCi/cc Eberline 01-07 post-SIAS RSC 26-4, Fuel Handing Building 5.3 E-02 uCi/cc Z

Eberline 04-05 (FHB)

Ebertine 04-07 RE 26-62, A Main Steam Line 2.0 E+00 mR/hr

.J Eberline 05-01 Monitor u..

RE 26-63, B Main Steam Line 2.0 E+00 mR/hr Eberline 05-02 Monitor RY-23910-i, A S/G Blowdown 1.0 E+04 cpm Ch44 RY-23920-i, B S/G Blowdown 2.5 E+04 cpm Ch45 o.

UNIT2:

Monitor Channel Pathway Reading 5

RS 26-90, Plant Vent (PV) 1.0 E-02 uCi/cc PC-li 621 Normal Ops RS26-90, Plant Vent (PV) 1.1 E-Oi uCi/cc PC 11 622 post SIAS RS 26 90 w/ FHB Diverted to 9 4 E 03 uCi/cc 4i PC-li 621 Plant Vent RS 26-12, Fuel Handing Building 4.6 E-02 uCi/cc PC-il 413 (FHB)

RIM 26-71, A Main Steam Line 2.0 E+0O mR/hr PC-il 631 Monitor B Main Steam Line Monitor RS-26-5, PC-li 121 A S/G Blowdown 2.5 E-04 uCi/mI RS-26-6, PC-li 122 B S/G Blowdown 2.5 E-04 uCi/mI OR

2. VALID reading on ANY effluent monitor reading greater than 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.

3. Confirmed sample analyses for gaseous or liquid releases indicates concentrations OR release rates greater than 2 times 00CM Limits for 60 minutes or longer.

I L

I Any Release of Gaseous or Liquid Radioactivity to the Environment Greater Than 2 Times the 00CM for 60 Minutes or Longer.

Operating Mode Applicability:

All ognitiori eq EAL Values:

Note The Emergency Coordinator should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the release duration has exceeded, or will likely exceed, the applicable time.

In the absence of data to the contrary, assume that the release duration has exceeded the applicable time if an ongoing release is detected and the release start time is unknown.

UNIT I:

Iz LUD

-J LL U-Ui C.)

CD0

-I0 RIM 26-72, PC-li 632 2.0 E+00 mR/hr kSSIFICATION TOOL R

HOT CONDITIONS 6