L-2013-104, Comments for the 2013 Written NRC License Post Initial Examination
| ML13113A145 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 04/22/2013 |
| From: | Kiley M Florida Power & Light Co |
| To: | Mccree V NRC/RGN-II |
| References | |
| L-2013-104 | |
| Download: ML13113A145 (9) | |
Text
0 PLe March 22, 2013 L-201 3-104 Victor McCree Regional Administrator, Region II U. S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, GA 30303-1257 Attention: Gerard Laska, Examiner Re:
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-25 1 FPL Comments for the 2013 Written NRC License Examination In accordance with provisions of NUREG-1021, Operator Licensing Examiner Standards, Examiner Standards ES-402, Administering Initial Written Examinations, Section E, Post-Examination Reviews, Paragraph 4, Florida Power & Light Company (FPL) has collected and considered comments from the applicants regarding the written portion of the License Examination administered at Turkey Point on March 15, 2013.
FPL has three comments for your review based on the applicants feedback.
Attachments I and 2 provide the challenged questions, the answers, and references. Each question states the comment and provides FPLs recommendation. The enclosure provides supporting information.
Should there be any questions, please contact Mark Similey at (305) 246-6691.
Sincerely, Michael Kiley Vice President Turkey Point Nuclear Plant Attachments and Enclosure cc:
Chief, Operations Branch, Division of Reactor Safety, Region II, USNRC (w!o enclosure)
Chief Examiner, Region Il, USNRC (w/o enclosure)
Senior Resident Inspector, USNRC, Turkey Point Plant (w/o enclosure)
Document Control Desk, USNRC, Washington, D.C. (w/o enclosure)
Florida Power & Light Company
9760 SW 344 St Homestead, FL 33035
ATTACHMENT I TO L-2013-104 Executive Summary of Challenged Questions and FPL Recommendation Question 8: This question requires the operator to determine the most effective method of reducing RCS pressure in mode 3 with the 3C RCP running. 3-NOP-041.02, Pressurizer Operation, does not allow the use of Auxiliary Spray with RCPs running. FPL recommends accepting distracter B ONLY as the only correct answer.
Question 34: This question requires the candidate to identify the maximum allowable ICW flow rate to each CCW HX under normal conditions and to state the reason why. Distracters B and D properly identify the need to minimize long-term tube side erosion in the CCW HXs. Two maximum flow rates are specified in 3-NOP-Ol 9, Intake Cooling Water System, dependent on plant configuration, both of which are considered normal alignments. During operations with no other evolutions in progress for ICW, the maximum allowable flow rate is 10000 gpm as specified by distracter B. The maximum allowable flow rate during basket strainer back flush is 12,850 gpm as specified by distracter D. Approved plant documentation identifies both of these system alignments as normal. Therefore distracter D is also correct as it describes the maximum allowable flow rate as 12,850 gpm. FPL recommends accepting both answers B and D as correct.
Question 62: This question requires the candidate to verify RIL TS Limits and determine the required action for boration based on an event causing a Turbine Runback. The question did not provide distracters for required actions from 3-ONOP-089, Turbine Runback. Since the ONOP takes precedence over other ARP actions per 0-ADM-21 1, Emergency and Off-Normal Operating Procedure Usage, the operator would use the procedural guidance within 3-ONOP-089 to borate in 50 gallon increments, withdraw control rods, and clear the TS RIL issue. FPL recommends deleting question 62 from the exam.
ATTACHMENT 2 TO L-2013-104 Exam Questions, Answers and References
ATTACHMENT 2 TO L-201 3-1 04 QUESTION B
Plant Coridifions:
Unit 3 is in Mode 3.
Tavs1. it.nø-load valw Reactor Coolant Pump 3C is operating with 3A arid 3B are secured Which ON of the following would be most effective at lowering PZR pressure?
A.
Spray Valve PCV3-455A Open Spray Valve-PC-V--34SD Open Spray Valve PCV-3-455A Open Spray Valve PCV-3-45513 Closed C
Spra Valve PGV3-458A Ckeu Spray Valve PCV3-465 Open D,
Spray Valve PCV-3-455A Closed Spray Valve PCV-3455B Closed Auxiliary Spray CV331 1 Open 5.0 INFREQUENT OPERATIONS B is only correct Answer.
D is not Iluwed by procedure.
RFVID4 NO-piO.twPr intr 1AGL 2
PIESSURIZER OPERATION
- 34. of 87 PR.FIIRF tO,:
a-NOP-041.92 1.RKEY POINT UNIT 3 5.1 PressurIzer Auxiliary Snrav Ooeralions 1.
CHECK CVCS normal Charging and Letdown in service, 2c CHECK NO RCPs runnln 3.
CHECK a P essurIer steam bubbta exIsts.
LS Next Pagej
ATTACHMENT 2 TO L-201 3-1 04 Question # 8 provides the operator with a scenario with RCP 3C in service, and asks which set of conditions would be the most effective at lowering PZR pressure.
Distracter A is incorrect, as opening PCV-3-455B, thereby short-cycling spray, thus making spray flow from PCV-3-455A ineffective.
Distracter B will provide effective spray as PCV-3-455A is open delivering full available spray flow, without short-cycling spray through PCV-3-455B.
Distracter C is incorrect, as the open spray valve is from the secured RCP, there will be no spray.
Distracter D would provide effective spray, however it is not allowed by plant procedures.
Recommend accept B as the only correct answer.
ATTACHMENT 2 TO L-201 3-1 04 QUESTION 34 Plant conditions:
Unit 3 Is operating at 100% power.
Three CCW Heat Exchangers are in service.
I In accordance with 3-NOP-al 9, 1taJe4liqg Water System, und4r ncrma4onditlons which ONE of the following identifies th maximum allowable ICW fiowr toeabCW Heat Exchanger, AND the reason for this4lmltjk.)
A.
lO 1
000gpm; Provont runoit ofthoKWpump.
l0O0O gpm; Minimize long-term tube-sico erosion C.
12,0Cgptr:
Provent runo.toft4GWjip.
D.
12,850 gpm; Mlnitmze ong-terrrt tube-side &osion.
See NextPage
ATTACHMENT 2 TO L-2013-104 Question # 34 requires the candidate to identify the maximum allowable ICW flow rate to each CCW HX under normal conditions and why. Distracters B and D properly identify the need to minimize long-term tube side erosion. The second determination is the maximum flow rate.
There are two maximum flow rates, 10,000 gpm and 12,850 gpm.
As both distracters are correct values in accordance with 3-NOP-019, the student must discern which normal to use.
Either the normal operation within the context of 3-NOP-Ol 9 step 2.2.4.2:
2.2.4 CCW Heat Exchangers 1.
ICW outlet temperature from CCW HXs should NOT exceed 120°F.
2.
Maximum ICW flowrate to each CCW HX during normal operation should NOT exceed 10,000 gpm In order to minimize long term tube side erosion of the CCW HXs. The ICW flowrate for each CCW HX may be increased to 12,850 gpm for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period to accommodate HX or Basket Strainer cleanlngs.
-OR-Normal Operations as defined by the Turkey Point Plant Radiological Emergency Plan:
Normal Plant Operations
- Activities at the plant site associated with routine testing.
maintenance, or equipment operations. in accordance with normal operating or administrative procedures. Entry into abnormal or emergency operating procedures. or deviation froni normal security or radiological controls posture. is a departure from NORMAL PLANT OPERATIONS.
If a competent operator understands that the plant routinely backwashes basket strainers on a near-weekly basis, he should identify this as a normal evolution, and that under these conditions, the plant is allowed to raise ICW flow rate to the maximum flow rate to 12850 gpm.
Recommend accept B and D as correct answers.
ATTACHMENT 2 TO L-201 3-1 04 QUESTION 62 Plant conditIons:
Un[L3isat 1flfl/n pQwe all systems in normal alignments.
- A turbine runback occurs The unit fbII[+/-ed at 82% power.
Annunciator B 8/2, ROD BANK AIB/CID EXTRA LO LIMIT Is In alarm.
Control Bank D Indicates 130 steps.
Which ONE of the following correctly completes the statement below?
The technical specification LCO for Rod Insertion Lirrilts _(1)_ exceeded. The operator must immediately stop driving rods and _(2)_.
A.
(1)is (2) commence emergency boration lAW 3-ONOP-46. 1, Emergency Boration.
B.
(1)is (2) borate 16 gpm lAW O-OP-046, CVCS - Boron Concentration Control.
C.
(1)1sNOT (2) borate In 50 gallon increments lAW 0-OP-046, CVCS - Boron Concentration Control.
D.
(1)isNOT (2) borate 16 gpm lAW 3-OP-46, CVCS Boron Concentration Control.
1NO t Of t 1
There are no correct Answers LIACTOWEXPECTEDRE$PONBEI BEEPONIENOT OBTAINEOj 3.2 Subsequent Antlons contlnued)
MONI1flR Aooi,ncb,, 8 8t2 ROD PRRFOSM the F, hwig os.w,esory
<_.I BANK AifitCic E)CTFA 1.0 LIM
tr the jback:
CLEAR (fl WHEN tunbo. wnboch is oonpt.te. THEN PLACE Ot,boI iud,lif.inuel SET b00 no a lo1 SO gallons.
DETERMIFE bc.rl non fLaw into JO ootOn,tn.d by the Unit Si4in.
PLACE the Renctor Mikeup S.fnotc Soitnh to BORATE.
PLACE.huRCO Mk.o
\\/j owrbfll Swibhtn SA8 ADJUSTOrC s.tpolnt on the BoiioAckt Co,troll,r FC4-l 13A:o ttte dee rod flow f
into no rrthtatodonFp-3.113.
j )
WITHDRAW Control Rods to Wnblish op b31..,OREATERTHAN T..untlt An,uno star 862 Is CLEAR.
H.
REPEATSSOTIOO 32 STep IT RNO steps jnt0 Mnurcint*
BA2 is CLEAR.
ATTACHMENT 2 TO L-201 3-1 04 Question 62 gives the event of a runback followed by Annunciator B 8/2 in alarm. Bank D rods past the Rod Insertion Limit would happen as a result of the runback. 3-ONOP-089, Turbine Runback, has Immediate Operator Actions and would be entered directly. During the subsequent actions, the RIL condition would be addressed in step 3.3.10. Per the rules of use specified in 0-ADM-21 1, the ARP actions would not be used since the operator is already in the correct procedure to address the RIL condition caused by the runback.