ML17349A209

Turkey Point 05000250, 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)

See also: IR 05000250/2017301

Text

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)

2) Supporting Documentation for Applicant

Comment (Q89)

3) Facility Position (Q89)

Attachment3ExecutiveSummaryof Challenged Questions and FPL RecommendationQuestion 34:This questionis being challenged in accordance with NUREG 1021 REV 11, ES-403for the followingreason: *a question with an unclear stem that confused theapplicants or did not provide all thenecessary information.Question 34provides the operator with a Loss of CCW scenario in whichone of the RCPs is experiencing High Motor Bearing temperatures.FPL recommends to accept bothA and D distractors as correct for question 34 since two procedures that are applicable during theconditions 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 followingreason: *a question with an unclear stem that confused the applicants or did not provide all thenecessary information.Question 89provides the operator with a scenario where one ICW/CCWstrainer and one ICW/TPCW strainer are being backwashed simultaneously. Subsequent failuresprevent restoration from backwashing operations.The questionisto determine if a procedurallimitation from 4-NOP-019, Intake Cooling Water System, has been violated and if the Unit Supervisoris required to apply TS 3.0.3. On question 89 it is unclear if an action statement was initially enteredwhen the ICW/CCW backwash was started.Due to conflicting answers as a result of a missing pieceof 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 followingreason: *a question with an unclear stem that confused the applicants or did not provide all thenecessary information.Question 94is relatedknowledge ofSTA responsibilities. At Turkey Point,our plant administrative procedure 0-ADM-200,Operations Management Manual,is more restrictivethan theTechnical Specifications. This question did notspecify which reference to usein order toformulate a response.Due to conflicting answers FPL recommends to delete question 94 from theexam.

Attachment 3

Applicant Commentson question 89:Question 89 presented theapplicant s with a situation in which the ICW/CCW Basket Strainerwasbeing backwashed at the same time as the ICW/TPCW Backwash Strainer. A

s stated in thestem ofthe question, during the subsequent restoration, 4-50-324, ICW/CCW BASKETSTRAINE R A INLETISOLATION, experience

s a sheared pin (handwheel spin

s freely) andremained closed, and POV-4-4883, ICW/TPCW HEADE

R B ISOLATIO

N VALVE, failed closed andwould not reopen. The questionthen a sks the student if the limitation

s of strainer backwashingper 4-NOP-019 (ARE/ ARE NOT)violated; and if the Unit 4 Unit Supervisor (IS/IS NOT) requiredto be in HOT SHUTDOWN within thefollowing 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.I chose answer (B) for the Limitation

s of 4-NOP-019 ARE violated, and the Unit Supervisor I

SNOTrequired to be in HOTSHUTDOWN within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. The keyed answer wa

s (D) in which theanswerstated the Limitation

s of 4-NOP-019 ARE NOT violated, and Unit Supervisor IS NOTrequired to be inHOT SHUTDOWN within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.Question 89 is not being contended for the second part ofthe qu estion. I agree that Unit 4 isNOT in aShutdown Action in accordance with Technical Specification 3.0.3. However, I amcontending that theanswer for the first part of Question 89 is incorrect.The limitation

s of 4-NOP-019 pertaining to the BasketStrainer s are found in section 2.2.3.3.Limitation 2.2.3.3 state

s a s follows: "While isolating an ICW/CCW Strainer, ICW flow

s below"Minimum Required ICW/CCW Flowrate" are permitted for up to 5 minutes, without declaringICWSystem inoperable. If flow isbelow the "Minimum Required ICW/CCW Flowrate" forgreater than 5minutes, then the ICW system shall be declared inoperable at the time whenflow initially went belowthe "Minimum Required ICW/CCW Flowrate."The Initial Conditions/Stem of the question statethat valve 4-50-324 ha

s a sheared pin and thevalveremains closed. However, there i

s no definitive indication about time, which leave

s theapplicant todetermine if the valve can be opened within 5 minutes to comply with Limitation2.2.3.3. Indicationsshow that the valve

's pin ha s sheared (handwheel spin

s freely) and thevalve remain

s closed. Valve4-50-324 i

s a manual operating valve and has no other means tooperate the valve in the opendirection. See attached P&ID, isometri

c drawing, and picture ofvalve 4-50-324.There i s no reasonable assumption that the valve can be opened within 5 minute

s to complywith thelimitation provided in the procedure. Therefore, I came to the answer that thelimitation to backwashfor le ss than 5 minutes IS violated andthu s answer (B) wa

s chosen toreflect thi

s condition. NUREG1021-Revision 11 Section D.1 state

s that "newly discoveredtechnical information that support

s achange in the answer key" can be used a

s a reason tosupport taking two answer

s for thi s questionorfor the removal of thi

s question.

Attachment 3Facility Position onApplicant Comment on question 89

FPL concurs with the applicants positionon deletion of question 89.Facility Comment

son question 89:This question is being challenged in accordance with NUREG1021 REV 11, ES

-403 for the followingreason: *a question with an unclear stem that confused the applicants or did not provide all thenecessary information.Question 89 provides the operator with a scenario where one ICW/CCWstrainer and one ICW/TPCW strainer are being backwashed simultaneously. Subsequent failuresprevent restoration from backwashingoperations. The question isto determine ifprocedurallimitationsfrom 4-NOP-019, Intake Cooling Water System, havebeen violated and if the UnitSupervisor 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 Strainerbackwashing without declaring the ICW header inoperable,during the backwash

the ICWflowrate through the CCW lowers below the Minimum Required,this requiresthe affected ICWHeaderto be declared inoperableif this condition lasts longer than 5 minutes. On the otherhand, at Turkey Pointis normal practice to declarethe affected ICW header inoperablepreemptively before aligning for backwash. Since question 89does not specifyif an actionstatement was initially entered when the ICW/CCW backwash was startedthe candidates arerequired tomake an assumption to answer this question,which couldlead to two differentanswers: Bor D.*If assuming that Tech Spec 3.7.3 Action C

(Reference 4

)was entered before starting thestrainer backwash, the candidate would conclude that no violation of the 4

-NOP-019limitationshave 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 strainerbackwash, the candidate would conclude that a violation of the 4

-NOP-019 limitations 2.2.3.3have occurred due to lowering ICW flowrate through the ICW/CCW heat exchanger for longerthan 5 minutes without declaring the affected ICW header inoperable.

4-NOP-019 allows forbackwashing ICW/TPCW basket strainers for up to 5 minutes without declaring the associatedICW header inoperable. Under the assumption that a backwash is being attempted to beperformed with both ICW headers operable and inside the 5 minute window, once the isolationvalve (3-50-324) pin shears, the ICW/CCW basket strainer willremain isolated for greater than5 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 arerequired to assume that an ICW Header is declaredinoperable or not at the beginning of the backwash, the candidates arrive at conflicting conclusions asit relates to the violation of the limitations of 4

-NOP-019.Due to conflicting answers as a result of

amissing 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-1 7-1 EXAM SECURE INFORMATION****

NRC L-1 7-1 EXAM SECURE INFORMATIONIncorrectIncorrect.IncorrectCorrect

NRC L-1 7-1 EXAM SECURE INFORMATION

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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, then a

condition report shall be initiated.

2.2.1 General 1.When in M O DE 1, 2, 3, and 4, t h e ICW System shall be OPERABLE y with three I C W pumps and two I C W headers. 2.When in M O DE 1, 2, 3, and 4, and there are NO T two O PERABLE I C W p um p s with inde p endent p ower su pp lies, then a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> L CO pp p p pp

Action S tatement is in e ff ect to restore two pumps from independent

p ower supplies to O PERABLE status. 3.When removin g an I C W header f rom servic e in M O DE 1, 2, 3, or 4, a g 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> L CO Action S tatement is in e ff ect until header is returned to se rvi ce. B ecause NO flow is being diverted

away from the CCW HXs, g y as when a strainer is bein g bac k washed, a continuous

watch is NO T g r equired to be posted when the header is out o f service. 4.When the U5 Well Water In j ection is in operation, the ICW System j p y s h ou l d NO T be o p erated with three I C W p um p s. In this condition, p pp the in j ection f low p ushes the f low rate throu g h the CC W HXs over j p g

their limit o f 10,000 G PM. Momen t ar y f low g reater than 10,000 G PM i s a ll o w ed. 2.2.2 ICW Pumps

1.I C W p um p s should NO T be operated with water level of the Pump pp p p

Well lower than 2 3 f eet 2 inches below the centerline

o f the p um p pp dischar g e which is 20 f eet 8 inches below the Intake f loor g ratin g. 2.I f I C W p um p motor heaters are OOS for more than five days, then pp y En g ineerin g is required to determine pump O PERABILITY.

3.The minimum flow for any ICW pump during continuous operation y pp g

s hould be g reater than or equal to 3200 g pm. 4.M aximum I C W f lowrate to each CC W HX during normal operation g p s hould N O T exceed 10,000 gp m p er HX durin g normal three HX gp p g

o p erations in order to minimize long term tube side erosion of the p g CC W HXs. (re f. 5610-019-DB-002) A.The I C W maximum f lowrate f or each CC W HX ma y be y

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

H X or Basket S trainer c leanin g s. (re f. 4-N O P-030) B.I f f low exceeds 10,000 gp m fo r more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, then a gp condition report shall be initiated.

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.

R EVI S I O N N O.: PR OC ED U RE TITLE: PA G E: 24 INTAKE COO LIN G WATER S Y S TEM 7 o f 1 58 PR OC ED U RE N O.: 4-N O P-0 1 9 T U RKEY P OINT U NIT 4 2.2.2 ICW Pumps (continued)

4. (continued)

C.I C W f low should be throttled t o m a int a in f l o w l ess th a n 10,000 gp m unless elevated f lows are re q uired (it is gp q (

acce p table to run three I C W p um p s with CC W HX f lows p pp greater than 10,000 gpm during periods of elevated canal g gp temperature) re f. C R 1987062 5.M aximum I C W Pum p f lowrate is pe r mitted u p to 18,500 gp m. I f an p p p gp

I C W Pum p is o p erated in excess of 18,500 gpm, then flow should be p p gp r educed to less than 18,500 gp m as soon as p ossible. I f an I C W gp p

pump has operated at flows greater

than 18,500 gpm for more than

rpp p g gp twent y (20) minutes, then once p um p f low has been reduced to y () pp

18,500 gp m or less, the I S T C oord inator should be notified to perform gp p vibration and p um p DP testin g p e r 4-OSP-019.1, Intake Cooling

r pp g p g Water Pump Inservice Test to ensur e inte g rit y o f t h e a ff ected pump. 6.C oncurrent o p eration o f both t h e I C W and C W p um p s in a sin g le p pp g

Intake Ba y with a S tationar y S creen installed is permitted only when y y p y determined

necessar y b y S hi f t M ana g er or Unit S u p ervisor to y y g p accommodate

p um p shi f tin g durin g emergent operating conditions. pp g g g pg S uch p eriods o f o p eration shall be l imit ed t o as s h o rt a du r a ti o n as p p possible, and an operator shall be stationed to continuously monitor

p the intake ba y. 7.Op eration o f either the I C W or t h e CW pump in a single intake bay p pp g

with a stationary screen installed is

permitted when sub j ect to the y f ollowin g restrictions:

A.Prior to p lacin g the I C W p um p in service, p um p well water pg pp pp levels shall be verified greater

than 2 0 f eet 8 i n c h es be l o w th e Intake f loor g ratin g. B.Foulin g o f the stationar y screen shall be monitored periodically g y py to ensure that minimum required water levels are present. The q p

f re q uenc y o f the surveillance

shall be determined

b y S hi f t qy y

M ana g er or Unit S upervisor based on current g rass in f lux rate. C.Any collected debris shall be re

moved f rom the stationar y y y s creen prior to reachin g the m i n imum required water level. D.If diving activities are being performed on the west side of the g g p

s tationar y screens, then the a ff ected I C W and C W p um p s y pp

shall be secured and declared out of service during the time th e d iv e r r e m a in s in th e w e ll.

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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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."

R EVI S I O N N O.: PR OC ED U RE TITLE: PA G E: 24 INTAKE COO LIN G WATER S Y S TEM 8 o f 1 58 PR OC ED U RE N O.: 4-N O P-0 1 9 T U RKEY P OINT U NIT 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 , pp

durin g the time the diver rema in s in th e w e ll. Th e r e a r e NOg specific limitations on ICW pump usage when diving activities p pp g g

are per f ormed on the east side o f the stationar y screens. 8.When startin g I C W Pum p s, the maxim u m f l o w r a t es fo r th e in-se rvi ce 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 g p Intake Well CW Pump should operate for at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> prior to p p s tartin g the associated

I C W Pump. 2.2.3 Basket Strainers

1.DP across the I C W Basket S tra iners at the CC W HXs should NO T exceed 1.5 psid and at the TPCW HXs should

NO T e x ceed 2.25 psid. 2.The maximum allowable I C W / CC W Basket S trainer element (screenin g) di ff erential p ressure is 10.0 p sid p er (g) p p p

S ection 7.1.2, Develo p mental R e f erence 6.P. Operation with p p di ff erential p ressures near or a t 10.0 p sid ma y challen g e the p p y g s tructural inte g rit y o f the Basket S trainer element (screenin g). 3.While isolatin g an I C W/CC W S tra iner, I C W flows below "Minimum g R e q uired I C W/CC W Flowrate" are permitted for up to 5 minutes, q p p without declarin g I C W Sy stem ino p er ab l e. I f f l o w i s be l o w th e g y p"Minimum Re q uired I C W/CC W Flowrat e" for greater than 5 minutes, q g then the I C W Sy stem shall be decl ared ino p erable at the time when y p f low initiall y went below the "Min imum Required ICW/CCW Flowrate."

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 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 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 105 F. 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.

R EVI S I O N N O.: PR OC ED U RE TITLE: PA G E: 24 INTAKE COO LIN G WATER S Y S TEM 9 o f 1 58 PR OC ED U RE N O.: 4-N O P-0 1 9 T U RKEY P OINT U NIT 4 2.2.4 CCW Heat Exchangers

1.I C W outlet temperature

f rom CC W HXs should NO T exceed 120

0 F. 2.M aximum I C W f lowrate to each CC W HX durin g normal o p eration g p s h ou l d NO T exceed 10,000 gp m in order to minimize long term tube gp g s ide erosion o f the CC W HXs. T h e I C W f lowrate f or each CC W 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 y gp p

acco mm oda t e HX o r B as k e t S trainer cleanin g s. 3.M inimum I C W f lowrate to CC W H X s durin g normal operation should be de t e rmin ed as fo ll o w s: If three CCW HXs are in serv

ice, 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 U sin g Flow Rate C urves or Manual Calculation.

To decrease the Minimum R

eq uired I C W/CC W Flowrate , the q , CC W HX with hi g hest tube resistance

ma y be declared OOS g y

at the discretion of the Shift Manager while the basket strainer g

is OOS. I f a CC W HX is decla r ed OOS , then the I C W flow throu g h that CC W HX can NO T be used t o ca l cu l a t e th e g M inimum Required I C W/CC W Flowrate.

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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 NoCan the question be answered solely by knowing the LCO/TRM information listed "above the line?"

Y es RO question

No Can the question be answered solely by knowing the TS safety limits?

YesRO question

NoDoes 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 NoQuestion might not be linked to 10 CFR 55.43(b)(2) for SRO-only

a pplication o

f r equired a ctions (T S Sectio n3) and S Rs (TS pp q ()Section 4) in accordance with rules of a

pplication )requirements

(T S Section 1)a pplication of

generic LCO re

quirements (LCO 3.0.1 thr ou ghppg q 3.0.7 and SR 4.0.1 thr ou gh 4.0.4)

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 rema

ins 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 maximu

m 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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 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 inoper

able. If flow is below the

"Minimum Required ICW/CCW Flowrate

" for greater than 5 minutes, then the ICW System shall be decl

ared inoperable at the time when flow initially went below the "Minimum Required ICW/CCW Flowrate."

5) Facility Comment (Q34)

Attachment3ExecutiveSummaryof Challenged Questions and FPL RecommendationQuestion 34:This questionis being challenged in accordance with NUREG 1021 REV 11, ES-403for the followingreason: *a question with an unclear stem that confused theapplicants or did not provide all thenecessary information.Question 34provides the operator with a Loss of CCW scenario in whichone of the RCPs is experiencing High Motor Bearing temperatures.FPL recommends to accept bothA and D distractors as correct for question 34 since two procedures that are applicable during theconditions 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 followingreason: *a question with an unclear stem that confused the applicants or did not provide all thenecessary information.Question 89provides the operator with a scenario where one ICW/CCWstrainer and one ICW/TPCW strainer are being backwashed simultaneously. Subsequent failuresprevent restoration from backwashing operations.The questionisto determine if a procedurallimitation from 4-NOP-019, Intake Cooling Water System, has been violated and if the Unit Supervisoris required to apply TS 3.0.3. On question 89 it is unclear if an action statement was initially enteredwhen the ICW/CCW backwash was started.Due to conflicting answers as a result of a missing pieceof 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 followingreason: *a question with an unclear stem that confused the applicants or did not provide all thenecessary information.Question 94is relatedknowledge ofSTA responsibilities. At Turkey Point,our plant administrative procedure 0-ADM-200,Operations Management Manual,is more restrictivethan theTechnical Specifications. This question did notspecify which reference to usein order toformulate a response.Due to conflicting answers FPL recommends to delete question 94 from theexam.