Text

251/2017-301 Post-Exam Comments
	ML17349A209
Person / Time
Site:	Turkey Point
Issue date:	12/15/2017
From:	; NRC/RGN-II
To:	; Florida Power & Light Co
References
	50-250/OL-17-01, 50-251/OL-17-01
	Download: ML17349A209 (84)
	v • d • e

Turkey Point 2017-301

Post Exam Comments

1) Applicant Comment (Q89)

2) Supporting Documentation for Applicant

Comment (Q89)

3) Facility Position (Q89)

4) Supporting Documentation for Facility

Position (Q89)

5) Facility Comment (Q34)

6) Supporting Documentation for Facility

Comment (Q34)

7) Facility Comment (Q94)

8) Supporting Documentation for Facility

Comment (Q94)

1) Applicant Comment (Q89)

(

!Question Feedback from Applicant

Question 89 Contention:

Question 89 presented the applicants with a situation in which the ICW/CCW Basket Strainer

was being backwashed at the same time as the ICW/TPCW Backwash Strainer. As stated in the

stem of the question, during the subsequent restoration, 4-50-324, ICW/CCW BASKET

STRAINER A INLET ISOLATION, experiences a sheared pin (handwheel spins freely) and

remained closed, and POV-4-4883, ICW/TPCW HEADER B ISOLATION VALVE, failed closed and

would not reopen. The question then asks the student if the limitations of strainer backwashing

per 4-NOP-019 (ARE/ARE NOT) violated; and if the Unit 4 Unit Supervisor (IS/IS NOT) required

to be in HOT SHUTDOWN within the following 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months .

I chose answer (B) for the Limitations of 4-NOP-019 ARE violated, and the Unit Supervisor IS

NOT required to be in HOT SHUTDOWN within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months . The keyed answer was (D) in which the

answer stated the Limitations of 4-NOP-019 ARE NOT violated, and Unit Supervisor IS NOT

required to be in HOT SHUTDOWN within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months .

Question 89 is not being contended for the second part of the question. I agree that Unit 4 is

NOT in a Shutdown Action in accordance with Technical Specification 3.0.3. However, I am

contending that the answer for the first part of Question 89 is incorrect.

The limitations of 4-NOP-019 pertaining to the Basket Strainers are found in section 2.2.3.3.

Limitation 2.2.3.3 states as follows: "While isolating an ICW/CCW Strainer, ICW flows below

"Minimum Required ICW/CCW Flowrate" are permitted for up to 5 minutes, without declaring

ICW System inoperable. If flow is below the "Minimum Required ICW/CCW Flowrate" for

greater than 5 minutes, then the ICW system shall be declared inoperable at the time when

flow initially went below the "Minimum Required ICW/CCW Flowrate."

The Initial Conditions/Stem of the question state that valve 4-50-324 has a sheared pin and the

valve remains closed. However, there is no definitive indication about time, which leaves the

applicant to determine if the valve can be opened within 5 minutes to comply with Limitation

2.2.3.3. Indications show that the valve's pin has sheared (handwheel spins freely) and the

valve remains closed. Valve 4-50-324 is a manual operating valve and has no other means to

operate the valve in the open direction. See attached P&ID, isometric drawing, and picture of

valve 4-50-324.

There is no reasonable assumption that the valve can be opened within 5 minutes to comply

with the limitation provided in the procedure. Therefore, I came to the answer that the

limitation to backwash for less than 5 minutes IS violated and thus answer (B) was chosen to

reflect this condition. NUREG 1021-Revision 11 Section D.1 states that "newly discovered

technical information that supports a change in the answer key" can be used as a reason to

support taking two answers for this question or for the removal of this question.

2) Supporting Documentation for Applicant

Comment (Q89)

3) Facility Position (Q89)

Attachment 3

Executive Summary of Challenged Questions and FPL Recommendation

Question 34:

This question is being challenged in accordance with NUREG 1021 REV 11, ES-403 for the following

reason: a question with an unclear stem that confused the applicants or did not provide all the

necessary information. Question 34 provides the operator with a Loss of CCW scenario in which

one of the RCPs is experiencing High Motor Bearing temperatures. FPL recommends to accept both

A and D distractors as correct for question 34 since two procedures that are applicable during the

conditions described on the stem direct different actions, which are both applicable and correct.

Question 89:

This question is being challenged in accordance with NUREG 1021 REV 11, ES-403 for the following

reason: a question with an unclear stem that confused the applicants or did not provide all the

necessary information. Question 89 provides the operator with a scenario where one ICW/CCW

strainer and one ICW/TPCW strainer are being backwashed simultaneously. Subsequent failures

prevent restoration from backwashing operations. The question is to determine if a procedural

limitation from 4-NOP-019, Intake Cooling Water System, has been violated and if the Unit Supervisor

is required to apply TS 3.0.3. On question 89 it is unclear if an action statement was initially entered

when the ICW/CCW backwash was started. Due to conflicting answers as a result of a missing piece

of information FPL recommends to delete question 89 from the exam.

Question 94:

This question is being challenged in accordance with NUREG 1021 REV 11, ES-403 for the following

reason: a question with an unclear stem that confused the applicants or did not provide all the

necessary information. Question 94 is related knowledge of STA responsibilities. At Turkey Point,

our plant administrative procedure 0-ADM-200, Operations Management Manual, is more restrictive

than the Technical Specifications. This question did not specify which reference to use in order to

formulate a response. Due to conflicting answers FPL recommends to delete question 94 from the

exam.

Attachment 3

Applicant Comments on question 89:

Question 89 presented the applicants with a situation in which the ICW/CCW Basket Strainer was

being backwashed at the same time as the ICW/TPCW Backwash Strainer. As stated in the stem of

the question, during the subsequent restoration, 4-50-324, ICW/CCW BASKET STRAINER A INLET

ISOLATION, experiences a sheared pin (handwheel spins freely) and remained closed, and POV-4-

4883, ICW/TPCW HEADER B ISOLATION VALVE, failed closed and would not reopen. The question

then asks the student if the limitations of strainer backwashing per 4-NOP-019 (ARE/ ARE NOT)

violated; and if the Unit 4 Unit Supervisor (IS/IS NOT) required to be in HOT SHUTDOWN within the

following 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months .

I chose answer (B) for the Limitations of 4-NOP-019 ARE violated, and the Unit Supervisor IS NOT

required to be in HOT SHUTDOWN within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months . The keyed answer was (D) in which the answer

stated the Limitations of 4-NOP-019 ARE NOT violated, and Unit Supervisor IS NOT required to be in

HOT SHUTDOWN within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months .

Question 89 is not being contended for the second part ofthe qu estion. I agree that Unit 4 is NOT in a

Shutdown Action in accordance with Technical Specification 3.0.3. However, I am contending that the

answer for the first part of Question 89 is incorrect.

The limitations of 4-NOP-019 pertaining to the Basket Strainers are found in section 2.2.3.3.

Limitation 2.2.3.3 states as follows: "While isolating an ICW/CCW Strainer, ICW flows below

"Minimum Required ICW/CCW Flowrate" are permitted for up to 5 minutes, without declaring ICW

System inoperable. If flow is below the "Minimum Required ICW/CCW Flowrate" for greater than 5

minutes, then the ICW system shall be declared inoperable at the time when flow initially went below

the "Minimum Required ICW/CCW Flowrate."

The Initial Conditions/Stem of the question state that valve 4-50-324 has a sheared pin and the valve

remains closed. However, there is no definitive indication about time, which leaves the applicant to

determine if the valve can be opened within 5 minutes to comply with Limitation 2.2.3.3. Indications

show that the valve's pin has sheared (handwheel spins freely) and the valve remains closed. Valve

4-50-324 is a manual operating valve and has no other means to operate the valve in the open

direction. See attached P&ID, isometric drawing, and picture of valve 4-50-324.

There is no reasonable assumption that the valve can be opened within 5 minutes to comply with the

limitation provided in the procedure. Therefore, I came to the answer that the limitation to backwash

for less than 5 minutes IS violated and thus answer (B) was chosen to reflect this condition. NUREG

1021-Revision 11 Section D.1 states that "newly discovered technical information that supports a

change in the answer key" can be used as a reason to support taking two answers for this question or

for the removal of this question.

Attachment 3

Facility Position on Applicant Comment on question 89: FPL concurs with the applicants position

on deletion of question 89.

Facility Comments on question 89:

This question is being challenged in accordance with NUREG 1021 REV 11, ES-403 for the following

reason: a question with an unclear stem that confused the applicants or did not provide all the

necessary information. Question 89 provides the operator with a scenario where one ICW/CCW

strainer and one ICW/TPCW strainer are being backwashed simultaneously. Subsequent failures

prevent restoration from backwashing operations. The question is to determine if procedural

limitations from 4-NOP-019, Intake Cooling Water System, have been violated and if the Unit

Supervisor is required to apply TS 3.0.3. due to the failures.

4-NOP-019, Intake Cooling Water System, (Reference 3) allows for ICW/CCW Strainer

backwashing without declaring the ICW header inoperable, during the backwash the ICW

flowrate through the CCW lowers below the Minimum Required, this requires the affected ICW

Header to be declared inoperable if this condition lasts longer than 5 minutes. On the other

hand, at Turkey Point is normal practice to declare the affected ICW header inoperable

preemptively before aligning for backwash. Since question 89 does not specify if an action

statement was initially entered when the ICW/CCW backwash was started the candidates are

required to make an assumption to answer this question, which could lead to two different

answers: B or D.

If assuming that Tech Spec 3.7.3 Action C (Reference 4) was entered before starting the

strainer backwash, the candidate would conclude that no violation of the 4-NOP-019 limitations

have occurred. In this case D distractor is the correct answer.

Attachment 3

If assuming that Tech Spec 3.7.3 Action C was NOT entered before starting the strainer

backwash, the candidate would conclude that a violation of the 4-NOP-019 limitations 2.2.3.3

have occurred due to lowering ICW flowrate through the ICW/CCW heat exchanger for longer

than 5 minutes without declaring the affected ICW header inoperable. 4-NOP-019 allows for

backwashing ICW/TPCW basket strainers for up to 5 minutes without declaring the associated

ICW header inoperable. Under the assumption that a backwash is being attempted to be

performed with both ICW headers operable and inside the 5 minute window, once the isolation

valve (3-50-324) pin shears, the ICW/CCW basket strainer will remain isolated for greater than

5 minutes without declaring the affected ICW header inoperable. This constitutes a violation of

4-NOP-019 limitations 2.2.3.3. In this case B distractor is the correct answer.

FPL recommendation: As the candidates are required to assume that an ICW Header is declared

inoperable or not at the beginning of the backwash, the candidates arrive at conflicting conclusions as

it relates to the violation of the limitations of 4-NOP-019. Due to conflicting answers as a result of a

missing piece of information FPL recommends to delete question 89 from the exam.

References:

3. 4-NOP-019, Intake Cooling Water System.

4. Tech Spec 3.7.3.

4) Supporting Documentation for Facility

Position (Q89)

NRC L-17-1 EXAM SECURE INFORMATION

Page 251

Examination Outline Cross-

reference:

Level

RO

SRO

Tier #

2

Group #

1

Topic and K/A #

076

2.1.23

Importance

Rating

4.4

Conduct of Operations: Ability to perform specific system and integrated plant

procedures during all modes of plant operation.

Proposed Question: SRO Question # 89

Given the following conditions:

Unit 4 is operating at 100% power.

Backwashing 4A ICW/CCW and 4B ICW/TPCW strainers, is in progress.

While restoring:

4-50-324, ICW/CCW Basket Strainer A Inlet Isol, experiences a sheared pin

(valve handwheel spins freely) and remains closed.

POV-4-4883, ICW to TPCW Heat Exchangers Isolation Valve, is failed closed

and will not re-open.

Which one of the following completes the statements below?

4-NOP-019, Intake Cooling Water System, limitations for strainer backwashing

(1)

violated.

Unit 4 US

(2)

required to be in at least HOT SHUTDOWN within the

following 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months .

A.

(1) are

(2) is

B.

(1) are

(2) is NOT

C.

(1) are NOT

(2) is

NRC L-17-1 EXAM SECURE INFORMATION

494

NRC L-17-1 EXAM SECURE INFORMATION

Page 252

D.

(1) are NOT

(2) is NOT

Proposed Answer: D

A.

Incorrect

Both parts incorrect and plausible per discussion below. Both parts are

plausible independently and taken as a whole.

Part 2 incorrect; plausible because POV-4-4883 failure to re-open does not

affect ICW tech specs, since the valve is in its prescribed accident position.

B.

Incorrect.

Part 1 incorrect; plausible since 3-NOP-019 ensures that opposite train (of

the same kind ) strainer is in service before removing any strainer from

service.

C.

Incorrect

Part 2 incorrect; plausible since an ICW header is already OOS and POV-

4-4883 failure would drive actions for TS 3.0.3.

D.

Correct

IAW 4-ONOP-019 and TS 3.7.3/3.0.3

Technical

Reference(s)

4-NOP-019

TS 3.7.3/ 3.0.3

(Attach if not previously

provided)

Proposed Reference to be provided to applicants

during examination:

N

Learning

Objective:

6902277 Objective 4 and 6

(As available)

Question Source:

Bank

PTN 2013

Audit

Modified Bank

X

(Note changes or attach

parent)

New

Question History:

Last NRC

Exam:

NRC L-17-1 EXAM SECURE INFORMATION

495

NRC L-17-1 EXAM SECURE INFORMATION

Page 253

Question Cognitive Level:

Memory or Fundamental

Knowledge

Comprehension or

Analysis

X

10 CFR Part 55 Content:

55.41

55.43

2

Facility operating limitations in the technical specifications and their bases.

Comments:

NRC L-17-1 EXAM SECURE INFORMATION

496

REVISION NO.:

PROCEDURE TITLE:

PAGE:

24

INTAKE COOLING WATER SYSTEM

6 of 158

PROCEDURE NO.:

4-NOP-019

TURKEY POINT UNIT 4

2.2

Limitations

2.2.1

General

1.

When in MODE 1, 2, 3, and 4, the ICW System shall be OPERABLE

with three ICW pumps and two ICW headers.

2.

When in MODE 1, 2, 3, and 4, and there are NOT two OPERABLE

ICW pumps with independent power supplies, then a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months LCO

Action Statement is in effect to restore two pumps from independent

power supplies to OPERABLE status.

3.

When removing an ICW header from service in MODE 1, 2, 3, or 4, a

72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months LCO Action Statement is in effect until header is returned to

service. Because NO flow is being diverted away from the CCW HXs,

as when a strainer is being backwashed, a continuous watch is NOT

required to be posted when the header is out of service.

4.

When the U5 Well Water Injection is in operation, the ICW System

should NOT be operated with three ICW pumps. In this condition,

the injection flow pushes the flow rate through the CCW HXs over

their limit of 10,000 GPM. Momentary flow greater than 10,000 GPM

is allowed.

2.2.2

ICW Pumps

1.

ICW pumps should NOT be operated with water level of the Pump

Well lower than 23 feet 2 inches below the centerline of the pump

discharge which is 20 feet 8 inches below the Intake floor grating.

2.

If ICW pump motor heaters are OOS for more than five days, then

Engineering is required to determine pump OPERABILITY.

3.

The minimum flow for any ICW pump during continuous operation

should be greater than or equal to 3200 gpm.

4.

Maximum ICW flowrate to each CCW HX during normal operation

should NOT exceed 10,000 gpm per HX during normal three HX

operations in order to minimize long term tube side erosion of the

CCW HXs. (ref. 5610-019-DB-002)

A.

The ICW maximum flowrate for each CCW HX may be

increased to 12,850 gpm for a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months period to accommodate

HX or Basket Strainer cleanings. (ref. 4-NOP-030)

B.

If flow exceeds 10,000 gpm for more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , then a

condition report shall be initiated.

2.2.1

General

1.

When in MODE 1, 2, 3, and 4, the ICW System shall be OPERABLE

y

with three ICW pumps and two ICW headers.

2.

When in MODE 1, 2, 3, and 4, and there are NOT two OPERABLE

ICW pumps with independent power supplies, then a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months LCO

p

pp

Action Statement is in effect to restore two pumps from independent

power supplies to OPERABLE status.

3.

When removing an ICW header from service in MODE 1, 2, 3, or 4, a

g

72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months LCO Action Statement is in effect until header is returned to

service. Because NO flow is being diverted away from the CCW HXs,

g

y

as when a strainer is being backwashed, a continuous watch is NOT

g

required to be posted when the header is out of service.

4.

When the U5 Well Water Injection is in operation, the ICW System

j

p

y

should NOT be operated with three ICW pumps. In this condition,

p

the injection flow pushes the flow rate through the CCW HXs over

j

p

g

their limit of 10,000 GPM. Momentary flow greater than 10,000 GPM

is allowed.

2.2.2

ICW Pumps

1.

ICW pumps should NOT be operated with water level of the Pump

p

Well lower than 23 feet 2 inches below the centerline of the pump

p

discharge which is 20 feet 8 inches below the Intake floor grating.

2.

If ICW pump motor heaters are OOS for more than five days, then

p

y

Engineering is required to determine pump OPERABILITY.

3.

The minimum flow for any ICW pump during continuous operation

y

p

g

should be greater than or equal to 3200 gpm.

4.

Maximum ICW flowrate to each CCW HX during normal operation

g

p

should NOT exceed 10,000 gpm per HX during normal three HX

gp

p

g

operations in order to minimize long term tube side erosion of the

p

g

CCW HXs. (ref. 5610-019-DB-002)

A.

The ICW maximum flowrate for each CCW HX may be

y

increased to 12,850 gpm for a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months period to accommodate

gp

p

HX or Basket Strainer cleanings. (ref. 4-NOP-030)

B.

If flow exceeds 10,000 gpm for more than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , then a

gp

condition report shall be initiated.

NRC L-17-1 EXAM SECURE INFORMATION

497

REVISION NO.:

PROCEDURE TITLE:

PAGE:

24

INTAKE COOLING WATER SYSTEM

7 of 158

PROCEDURE NO.:

4-NOP-019

TURKEY POINT UNIT 4

2.2.2

ICW Pumps (continued)

4.

(continued)

C.

ICW flow should be throttled to maintain flow less than

10,000 gpm unless elevated flows are required (it is

acceptable to run three ICW pumps with CCW HX flows

greater than 10,000 gpm during periods of elevated canal

temperature) ref. CR 1987062

5.

Maximum ICW Pump flowrate is permitted up to 18,500 gpm. If an

ICW Pump is operated in excess of 18,500 gpm, then flow should be

reduced to less than 18,500 gpm as soon as possible. If an ICW

pump has operated at flows greater than 18,500 gpm for more than

twenty (20) minutes, then once pump flow has been reduced to

18,500 gpm or less, the IST Coordinator should be notified to perform

vibration and pump DP testing per 4-OSP-019.1, Intake Cooling

Water Pump Inservice Test to ensure integrity of the affected pump.

6.

Concurrent operation of both the ICW and CW pumps in a single

Intake Bay with a Stationary Screen installed is permitted only when

determined necessary by Shift Manager or Unit Supervisor to

accommodate pump shifting during emergent operating conditions.

Such periods of operation shall be limited to as short a duration as

possible, and an operator shall be stationed to continuously monitor

the intake bay.

7.

Operation of either the ICW or the CW pump in a single intake bay

with a stationary screen installed is permitted when subject to the

following restrictions:

A.

Prior to placing the ICW pump in service, pump well water

levels shall be verified greater than 20 feet 8 inches below the

Intake floor grating.

B.

Fouling of the stationary screen shall be monitored periodically

to ensure that minimum required water levels are present. The

frequency of the surveillance shall be determined by Shift

Manager or Unit Supervisor based on current grass influx rate.

C.

Any collected debris shall be removed from the stationary

screen prior to reaching the minimum required water level.

D.

If diving activities are being performed on the west side of the

stationary screens, then the affected ICW and CW pumps

shall be secured and declared out of service during the time

the diver remains in the well.

REVISION NO.:

PROCEDURE TITLE:

PAGE:

24

INTAKE COOLING WATER SYSTEM

7 of 158

PROCEDURE NO.:

4-NOP-019

TURKEY POINT UNIT 4

2.2.2

ICW Pumps (continued)

4.

(continued)

C.

ICW flow should be throttled to maintain flow less than

10,000 gpm unless elevated flows are required (it is

gp

q

(

acceptable to run three ICW pumps with CCW HX flows

p

greater than 10,000 gpm during periods of elevated canal

g

gp

temperature) ref. CR 1987062

5.

Maximum ICW Pump flowrate is permitted up to 18,500 gpm. If an

p

gp

ICW Pump is operated in excess of 18,500 gpm, then flow should be

p p

gp

reduced to less than 18,500 gpm as soon as possible. If an ICW

gp

p

pump has operated at flows greater than 18,500 gpm for more than

r

p

g

gp

twenty (20) minutes, then once pump flow has been reduced to

y (

)

p

18,500 gpm or less, the IST Coordinator should be notified to perform

gp

p

vibration and pump DP testing per 4-OSP-019.1, Intake Cooling

r

p

g p

g

Water Pump Inservice Test to ensure integrity of the affected pump.

6.

Concurrent operation of both the ICW and CW pumps in a single

p

g

Intake Bay with a Stationary Screen installed is permitted only when

y

p

y

determined necessary by Shift Manager or Unit Supervisor to

y y

g

p

accommodate pump shifting during emergent operating conditions.

p

g

p

g

Such periods of operation shall be limited to as short a duration as

p

possible, and an operator shall be stationed to continuously monitor

p

the intake bay.

7.

Operation of either the ICW or the CW pump in a single intake bay

p

g

with a stationary screen installed is permitted when subject to the

y

following restrictions:

A.

Prior to placing the ICW pump in service, pump well water

p

g

p

levels shall be verified greater than 20 feet 8 inches below the

Intake floor grating.

B.

Fouling of the stationary screen shall be monitored periodically

g

y

p

y

to ensure that minimum required water levels are present. The

q

p

frequency of the surveillance shall be determined by Shift

q

y

Manager or Unit Supervisor based on current grass influx rate.

C.

Any collected debris shall be removed from the stationary

y

screen prior to reaching the minimum required water level.

D.

If diving activities are being performed on the west side of the

g

g p

stationary screens, then the affected ICW and CW pumps

y

p

shall be secured and declared out of service during the time

the diver remains in the well.

NRC L-17-1 EXAM SECURE INFORMATION

498

REVISION NO.:

PROCEDURE TITLE:

PAGE:

24

INTAKE COOLING WATER SYSTEM

8 of 158

PROCEDURE NO.:

4-NOP-019

TURKEY POINT UNIT 4

2.2.2

ICW Pumps (continued)

7.

(continued)

E.

If diving activities are being performed on the east side of the

stationary screens, the affected CW pumps shall be secured

during the time the diver remains in the well. There are NO

specific limitations on ICW pump usage when diving activities

are performed on the east side of the stationary screens.

8.

When starting ICW Pumps, the maximum flow rates for the in-service

HXs may be exceeded. The high flow rate is acceptable provided the

duration of high flow is minimized.

9.

If time permits following the raking of an Intake Well, the respective

Intake Well CW Pump should operate for at least 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to

starting the associated ICW Pump.

2.2.3

Basket Strainers

1.

DP across the ICW Basket Strainers at the CCW HXs should NOT

exceed 1.5 psid and at the TPCW HXs should NOT exceed

2.25 psid.

2.

The maximum allowable ICW / CCW Basket Strainer element

(screening) differential pressure is 10.0 psid per

Section 7.1.2, Developmental Reference 6.P. Operation with

differential pressures near or at 10.0 psid may challenge the

structural integrity of the Basket Strainer element (screening).

3.

While isolating an ICW/CCW Strainer, ICW flows below Minimum

Required ICW/CCW Flowrate are permitted for up to 5 minutes,

without declaring ICW System inoperable. If flow is below the

Minimum Required ICW/CCW Flowrate for greater than 5 minutes,

then the ICW System shall be declared inoperable at the time when

flow initially went below the Minimum Required ICW/CCW Flowrate.

REVISION NO.:

PROCEDURE TITLE:

PAGE:

24

INTAKE COOLING WATER SYSTEM

8 of 158

PROCEDURE NO.:

4-NOP-019

TURKEY POINT UNIT 4

2.2.2

ICW Pumps (continued)

7.

(continued)

E.

If diving activities are being performed on the east side of the

g

g p

stationary screens, the affected CW pumps shall be secured

y

,

p

during the time the diver remains in the well. There are NO

g

specific limitations on ICW pump usage when diving activities

p

g

are performed on the east side of the stationary screens.

8.

When starting ICW Pumps, the maximum flow rates for the in-service

g

p

HXs may be exceeded. The high flow rate is acceptable provided the

y

g

duration of high flow is minimized.

9.

If time permits following the raking of an Intake Well, the respective

f

p

g

p

Intake Well CW Pump should operate for at least 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to

p

starting the associated ICW Pump.

2.2.3

Basket Strainers

1.

DP across the ICW Basket Strainers at the CCW HXs should NOT

exceed 1.5 psid and at the TPCW HXs should NOT exceed

2.25 psid.

2.

The maximum allowable ICW / CCW Basket Strainer element

(screening) differential pressure is 10.0 psid per

(

g)

p

Section 7.1.2, Developmental Reference 6.P. Operation with

p

differential pressures near or at 10.0 psid may challenge the

p

y

g

structural integrity of the Basket Strainer element (screening).

3.

While isolating an ICW/CCW Strainer, ICW flows below Minimum

g

Required ICW/CCW Flowrate are permitted for up to 5 minutes,

q

p

without declaring ICW System inoperable. If flow is below the

g

y

p

Minimum Required ICW/CCW Flowrate for greater than 5 minutes,

q

g

then the ICW System shall be declared inoperable at the time when

y

p

flow initially went below the Minimum Required ICW/CCW Flowrate.

NRC L-17-1 EXAM SECURE INFORMATION

499

REVISION NO.:

PROCEDURE TITLE:

PAGE:

24

INTAKE COOLING WATER SYSTEM

9 of 158

PROCEDURE NO.:

4-NOP-019

TURKEY POINT UNIT 4

2.2.4

CCW Heat Exchangers

1.

ICW outlet temperature from CCW HXs should NOT exceed 120qF.

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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months period to

accommodate HX or Basket Strainer cleanings.

3.

Minimum ICW flowrate to CCW HXs during normal operation should

be determined as follows:

If three CCW HXs are in service, then the minimum required

ICW flow rate is 11,000 gpm TOTAL, and at least 3500 gpm

through each CCW HX.

If less than three CCW HXs are in service, or flow through any

HX is less than 3500 gpm, the Minimum Required ICW/CCW

Flowrate will be determined by the STA or Shift Manager per

Attachment 5, Instructions for Determining Minimum Flow

Using Flow Rate Curves or Manual Calculation.

To decrease the Minimum Required ICW/CCW Flowrate, the

CCW HX with highest tube resistance may be declared OOS

at the discretion of the Shift Manager while the basket strainer

is OOS. If a CCW HX is declared OOS, then the ICW flow

through that CCW HX can NOT be used to calculate the

Minimum Required ICW/CCW Flowrate.

2.2.5

TPCW Heat Exchangers

1.

ICW outlet temperature from TPCW HXs should NOT exceed 105qF.

2.

Maximum ICW flowrate to a TPCW HX during normal operation is

12,000 gpm.

3.

Minimum ICW flowrate to each in service TPCW HX is 8000 gpm. If

flowrate decreases to less than this value, then the System Engineer

should be notified.

4.

Attachment 8, Alternate Method to Determine ICW Flow Through the

TPCW Heat Exchangers, may be used to determine ICW flow

through a TPCW HX in the event the normal flow device is

unavailable.

REVISION NO.:

PROCEDURE TITLE:

PAGE:

24

INTAKE COOLING WATER SYSTEM

9 of 158

PROCEDURE NO.:

4-NOP-019

TURKEY POINT UNIT 4

2.2.4

CCW Heat Exchangers

1.

ICW outlet temperature from CCW HXs should NOT exceed 120

0qF.

2.

Maximum ICW flowrate to each CCW HX during normal operation

g

p

should NOT exceed 10,000 gpm in order to minimize long term tube

gp

g

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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months period to

y

gp

p

accommodate HX or Basket Strainer cleanings.

3.

Minimum ICW flowrate to CCW HXs during normal operation should

be determined as follows:

If three CCW HXs are in service, then the minimum required

q

ICW flow rate is 11,000 gpm TOTAL, and at least 3500 gpm

through each CCW HX.

If less than three CCW HXs are in service, or flow through any

,

g

HX is less than 3500 gpm, the Minimum Required ICW/CCW

gp

q

Flowrate will be determined by the STA or Shift Manager per

y

g

p

Attachment 5, Instructions for Determining Minimum Flow

g

Using Flow Rate Curves or Manual Calculation.

To decrease the Minimum Required ICW/CCW Flowrate, the

q

,

CCW HX with highest tube resistance may be declared OOS

g

y

at the discretion of the Shift Manager while the basket strainer

g

is OOS. If a CCW HX is declared OOS, then the ICW flow

through that CCW HX can NOT be used to calculate the

g

Minimum Required ICW/CCW Flowrate.

NRC L-17-1 EXAM SECURE INFORMATION

500

TURKEY POINT - UNITS 3 & 4

3/4 0-1

AMENDMENT NOS. 235 AND 230

3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS

3/4.0 APPLICABILITY

LIMITING CONDITIONS FOR OPERATION

3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is

required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet

the Limiting Conditions for Operation, the associated ACTION requirements shall be met, except as provided in

Specification 3.0.6.

3.0.2

Noncompliance with a specification shall exist when the requirements of the Limiting Condition for

Operation and associated ACTION requirements are not met within the specified time intervals, except as

provided in Specification 3.0.6. If the Limiting Condition for Operation is restored prior to expiration of the

specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION

requirements, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months action shall be initiated to place the unit, as applicable, in:

a.

At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

b.

At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and

c.

At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Where corrective measures are completed that permit operation under the ACTION requirements, the action may

be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting

Condition for Operation. Exceptions to these requirements are stated in the individual specifications.

This specification is not applicable in MODES 5 or 6.

3.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made when the conditions for

the Limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they are not

met within a specified time interval. Entry into an OPERATIONAL MODE or specified condition may be made in

accordance with ACTION requirements when conformance to them permits continued operation of the facility for

an unlimited period of time. This provision shall not prevent passage through or to OPERATIONAL MODES as

required to comply with ACTION requirements. Exceptions to these requirements are stated in the individual

specifications.

NRC L-17-1 EXAM SECURE INFORMATION

501

TURKEY POINT - UNITS 3 & 4

3/4 7-17

AMENDMENT NOS. 263 AND 258

PLANT SYSTEMS

3/4.7.4 ULTIMATE HEAT SINK

LIMITING CONDITION FOR OPERATION

3.7.4 The ultimate heat sink shall be OPERABLE with an average supply water temperature less than or equal to

104F.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTION:

With the requirements of the above specification not satisfied, be in at least HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and

in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . This ACTION shall be applicable to both units

simultaneously.

SURVEILLANCE REQUIREMENTS 4.7.4

The ultimate heat sink shall be determined OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying the average supply

water temperature* is less than or equal to 104F.

b.

At least once per hour by verifying the average supply water temperature* is less than or equal to

104F, when water temperature exceeds 100F.

Portable monitors may be used to measure the temperature.

NRC L-17-1 EXAM SECURE INFORMATION

502

Exam: Turkey Point 2017 NRC Exam - Question Worksheets

Examination Outline Cross-reference:

Level

RO

SRO

Tier #

2

Group #

1

Topic and K/A #

076

2.1.23

Importance Rating

4.4

Conduct of Operations: Ability to perform specific system and integrated plant

procedures during all modes of plant operation.

Proposed Question: SRO Question # 88

Given the following conditions:

Unit 4 is operating at 25% power.

TPCW/ICW Isolation Valves, POV-4-4882 and 4883 have failed CLOSED.

The crew has entered 4-ONOP-019, Intake Cooling Malfunction.

POV-4-4882 has been opened manually using the local handwheel.

POV-4-4883 will NOT open.

Which one of the following identifies the status of TPCW cooling, and identifies the

technical specification implications of this event, if any?

A.

TPCW Cooling has been restored; Declare the 4A ICW header inoperable ONLY,

enter the action statement for LCO 3.7.3, Intake Cooling Water System, and

restore the inoperable header within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

B.

TPCW Cooling has been restored; Declare the 4A ICW header AND 4A train of

Safety Injection Automatic Actuation Logic inoperable and enter action for LCO 3.3.2, Engineered Safety Feature Actuation System, and restore the inoperable

train within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

C.

TPCW Cooling has NOT been restored; Declare the 4A ICW header AND 4A train

of Safety Injection Automatic Actuation Logic inoperable and enter action for LCO 3.3.2, Engineered Safety Feature Actuation System, and restore the inoperable

train within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

D

TPCW Cooling has NOT been restored; Declare the 4A ICW header inoperable,

enter the action statement for LCO 3.7.3, Intake Cooling Water System, and

restore the inoperable header within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Proposed Answer: A

Page 8

NRC L-17-1 EXAM SECURE INFORMATION

503

ES-401, Page 21 of 52

ES-401

5

Attachment 2

Figure 2-1 Screening for SRO-Only Linked to 10 CFR 55.43(b)(2)

(Technical Specifications)

Can the question be answered solely by knowing

-hour TS/TRM Action?

RO question

Yes

No

Can the question be answered solely by knowing

the LCO/TRM information listed above the line?

Yes

RO question

No

Can the question be answered solely by knowing

the TS safety limits?

Yes

RO question

No

Does the question involve one or more of the following for the

TS, TRM, or ODCM:

application of required actions (TS Section 3) and SRs (TS

Section 4) in accordance with rules of application

requirements (TS Section 1)

application of generic LCO requirements (LCO 3.0.1 through

3.0.7 and SR 4.0.1 through 4.0.4)

knowledge of TS bases that is required to analyze

TS-required actions and terminology

SRO-only

question

Yes

No

Question might not be linked to

10 CFR 55.43(b)(2) for SRO-only

application of required actions (TS Section 3) and SRs (TS

pp

q

(

)

Section 4) in accordance with rules of application

)

requirements (TS Section 1)

application of generic LCO requirements (LCO 3.0.1 through

pp

g

q

3.0.7 and SR 4.0.1 through 4.0.4)

NRC L-17-1 EXAM SECURE INFORMATION

504

REVISION NO.:

PROCEDURE TITLE:

PAGE:

24

INTAKE COOLING WATER SYSTEM

8 of 158

PROCEDURE NO.:

4-NOP-019

TURKEY POINT UNIT 4

2.2.2

ICW Pumps (continued)

7.

(continued)

E.

If diving activities are being performed on the east side of the

stationary screens, the affected CW pumps shall be secured

during the time the diver remains in the well. There are NO

specific limitations on ICW pump usage when diving activities

are performed on the east side of the stationary screens.

8.

When starting ICW Pumps, the maximum flow rates for the in-service

HXs may be exceeded. The high flow rate is acceptable provided the

duration of high flow is minimized.

9.

If time permits following the raking of an Intake Well, the respective

Intake Well CW Pump should operate for at least 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to

starting the associated ICW Pump.

2.2.3

Basket Strainers

1.

DP across the ICW Basket Strainers at the CCW HXs should NOT

exceed 1.5 psid and at the TPCW HXs should NOT exceed

2.25 psid.

2.

The maximum allowable ICW / CCW Basket Strainer element

(screening) differential pressure is 10.0 psid per

Section 7.1.2, Developmental Reference 6.P. Operation with

differential pressures near or at 10.0 psid may challenge the

structural integrity of the Basket Strainer element (screening).

3.

While isolating an ICW/CCW Strainer, ICW flows below Minimum

Required ICW/CCW Flowrate are permitted for up to 5 minutes,

without declaring ICW System inoperable. If flow is below the

Minimum Required ICW/CCW Flowrate for greater than 5 minutes,

then the ICW System shall be declared inoperable at the time when

flow initially went below the Minimum Required ICW/CCW Flowrate.

TURKEY POINT - UNITS 3 & 4

3/4 7-16

AMENDMENT NOS. 263 AND 258

PLANT SYSTEMS

3/4.7.3 INTAKE COOLING WATER SYSTEM

LIMITING CONDITION FOR OPERATION

3.7.3

The Intake Cooling Water System (ICW) shall be OPERABLE with:

a.

Three ICW pumps, and

b.

Two ICW headers.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTION:

a.

With only two ICW pumps with independent power supplies OPERABLE, restore the inoperable

ICW pump to OPERABLE status within 14 days or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The provisions of Specification 3.0.4 are

not applicable.

b.

With only one ICW pump OPERABLE or with two ICW pumps OPERABLE but not from

independent power supplies, restore two pumps from independent power supplies to OPERABLE

status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN

within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

c.

With only one ICW header OPERABLE, restore two headers to OPERABLE status within

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the

following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS 4.7.3

The Intake Cooling Water System (ICW) shall be demonstrated OPERABLE:

a.

In accordance with the Surveillance Frequency Control Program by verifying that each valve

(manual, power-operated, or automatic) servicing safety-related equipment that is not locked,

sealed, or otherwise secured in position is in its correct position; and

b.

In accordance with the Surveillance Frequency Control Program during shutdown, by verifying

that:

1)

Each automatic valve servicing safety-related equipment actuates to its correct position

on a SI test signal, and

2)

Each Intake Cooling Water System pump starts automatically on a SI test signal.

3)

Interlocks required for system operability are OPERABLE.