ML040770819

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Facility Comments and NRC Response to Initial Written Examination for the Kewaunee Initial Examination - February 2004
ML040770819
Person / Time
Site: Kewaunee 
Issue date: 03/12/2004
From: Lanksbury R
NRC/RGN-III/DRS/OLB
To: Coutu T
Nuclear Management Co
References
50-305/04-301
Download: ML040770819 (16)


Text

Page 1 of 16 Licensee Comments and NRC Response For Kewaunee Exam 2004 6/8/2006 RO1:

Add the word All at the start of the stem (prior to AC power has been lost Editorial done.

RO2:

Add the phrase narrow range between steam generator and water level (will read steam generator narrow range water level).

Comment incorporated. Better description of which SGWL instrument used. RKW RO3: No comment.

Removed abbreviation and spelled out degrees. RKW RO4: Stem needs clarification to reflect continued operation of the feedwater pump as the pump will start for all of the distractor conditions but wont continue to run if only one condensate pump is operating. Also note that this condition is a trip of the A FW pump so stem should specify start of the A FW pump as the second pump.

Comment incorporated. Stem reflects B MFWP operating then A MFWP trips. Also reflects that condition prevents continued operation. Air pressure signal changed from 200 psig to 210 psig to allow for reset value. Stem changed from singular to plural for main feedwater pumps. RKW RO5: No comment.

The question was reworded to read that the power supply was lost what component was impacted. This was done to increase the level of difficulty based on a NRC supervisory comment.

RO6: Need valve designators. Change standby high capacity air compressor to station air compressor. Change small capacity air compressor to instrument air compressor.

Comment incorporated. Deleted automatic control valve and replaced with noun name. Changed air compressors noun descriptors. Double jeopardy with B43 - so B43 rewritten. Replaced Standby high capacity A/C with station A/C to match station vernacular. Removed prefix 1' from designators. RKW RO8: Change Compressor F and G to Station Air Compressor F and G.

Comment incorporated. Also changed format of question from bullet format to statement format. RKW

Page 2 of 16 RO9: Change power level in stem to below POAH (~1 E-3%)

Editorial done.

RO10: Many minor edits needed.

Replaced psia with psig, added pressurizer in front of PORVs in distractor, removed control elements from root. Changed 2250 to 2235 psig. RKW RO11: Need to put in noun names for 4 RWST valves. (Collection of true/false questions?)

Put in valve noun names and numerical designators. Reworded distractors so that they were no longer in a true/false format. CJP RO13:

Replace fails with ruptures.

Comment incorporated. Replaced tap fails to pipe breaks. More clearer. RKW RO14:

Specify which SG the level instruments are associated with. Lower power level to 15% to preclude the AMSAC actuation possibility.

Lowered initial power level from 55% to 15%, added B to S/G level to make more specific. RKW RO15 Remove location of valve.

Removed location of LP letdown valve. RKW RO16: Add that both RXCPs are operating and A MFW pump is running.

Comments incorporated. Also combined the AFW A and AFW B columns into a single MDAFW column. RKW

Page 3 of 16 RO17: Revise question as follows:

SP-54-086, Turbine Stop and Governor Valve Operability directs depressing the CLOSE SV-1 pushbutton.

Which of the following statements identifies an expected response of the turbine control valves (CV-1 through CV-4) and turbine stop valve (SV-1) to this action?

A.

SV-1 closes, then CV-1 and CV-3 close.

B.

SV-1 closes, then CV-1 and CV-2 close.

C.

CV-1 and CV-2 close, then SV-1 closes.

D.

CV-1 and CV-3 close, then SV-1 closes.

Question reworded as shown above. Control Room valve position indications were removed from question and replaced with actual valve position. RKW RO19: No comment.

The question was reworded to take out references to TSs to get the question to an RO level. This change was based on a NRC supervisory comment.

RO20: Requirements to begin moving fuel with the reactor that is not a full core off load.

Need 2nd RHR pump when removing internals - Removed Comments incorporated - CDZ Replaced reactor water level with refueling cavity level. RKW Clarified Stem to indicate that the head and upper internal were already removed and that water level was high enough to begin refueling. CJP RO23: Change distractor C.

A.

Reactor trip breakers Comment incorporated as stated due to procedure change. RKW RO25: Capitalize NOT. Change RCPs to RXCPs.

Rxcps should be tripped in E1 Before getting to ECA1.1 Highly improbable question LOCA outside of containment what puts the operator in ECA1.1 Dont know how to write question to meet K/A?

Rewrote this question to address the comment about RXCPs should be tripped in E1 before ECA 1.1 and to better meet the K/A.

Page 4 of 16 B01 (RO 26, SRO 1):

Remove bullets and replace with numbers.

Removed bullets from stem conditions and replaced with numbers. RKW B02 (RO 27, SRO 2):

Double jeopardy with B29.

Rewrote question to prevent double jeopardy with B29 and to improve match with K/A.

RKW B03 (RO 28, SRO 3): SI instead of S signals Replaced S with SI. Changed Steamline flow numbers to logarithmic numbers. RKW B04 (RO 29, SRO 3):

Rename CVC-7 noun name.

CVC-7 name changed from RXCP labyrinth delta-P valve to ;Charging line flow Control valve. RKW I changed the question from bullet format to a statement format, and pulled CCP As speed will out of each distractor and placed in stem. I also added that CVC-7 was initially throttled to 70%. RKW B06 (RO 31, SRO 6): Edits needed.

After second OV, licensee added dont take readings on ICCMS, Selecting a CET does not affect the Honeywell display. The knowledge needed for this is what the range of a computer point is. This is not tied to the reference K/A.

Changed Incore Thermocouple Control panel to ICCMS, receiving changed to generating. RKW After 2nd OV, replaced question with licensee-provided question. RKW The licensee came up with a complete change to this question, but then left the change and the associated K/A reference on a desk uncontrolled overnight. This question and K/A now had to be replaced.

On the final submittal, the licensee provided an alternate question that met both the new K/A and the review of the NRC exam preparer.

B07 (RO 32, SRO 7): Edit needed.

Changed last bullet to Containment pressure has increased to 3.5 psig and is currently stable. Easier to read. RKW

Page 5 of 16 B08 (RO 33, SRO 8): Edit needed.

Added phrase At the completion of the SI sequence,.. and added SW descriptor in B, C & D distractors. RKW B09 (RO 34, SRO 9): Edit needed.

Added all 3' to last bullet to reflect A SGWL instruments are operating. Changed MFW condition from standby to pullout. RKW B12 (RO 37, SRO 12: No comment.

Reformated the question stem for ease of reading. Did not change details.

B14 (RO 39, SRO 14): RCP should be RXCP, add bullets to stem. Operators have implemented ES-0.2 to go to cold shutdown ASAP due to CST inventory concerns. SM has just determined that cooldown and depressurization must proceed as quickly as allowed.

Incorporated changes as suggested. RKW B15 (RO 40, SRO 15): Edit stem to clarify what conditions are changing.

Modified plant conditions in stem, lowered reactor power, clarified that K7 was not the most reactive rod, and changed initial Tave so that there would not be conflicting reactivity changes, and reworded all distractors for easier reading. RKW B16 (RO 41, SRO 16): Needs edit.

Changed B distractor from loop to wide range. RKW B17 (RO 42, SRO 17): Rewrite question - dont emergency borate at 80% power. FR-S.1 might work.

Changed question - to an inadvertent Emergency Boration to prevent confusion.

B18 (RO 43, SRO 18): Dont use inches use percent.

Removed 7.5 inches and replaced with 10% as per licensee request. Also, changed condensate pump condition from standby to pullout. RKW B21 (RO 46, SRO 21): use are instead of is.

Reworded stem to shorten stem and clarify condition. RKW

Page 6 of 16 B24 (RO 49, SRO 24): Needs edits.

Replaced CL with cold leg, and capitalized CANNOT. RKW B25 (RO 50, SRO 25): Needs edit.

Removed 449' and replaced with yellow channel (PT-449) IV. As written, was not a memory question, changed to higher. RKW B26 (RO 51, SRO 26): Change distractors, too confusing.

Deleted distractor B and replaced, changed will to cannot in distractor C.

B28 (RO 53, SRO 28):

Reformat the distractors so that each action in the distractor is on a separate line, e.g.

B.

Place Pzr spray valves in manual; Position Pzr pressure control switch to another position; Return Pzr spray valves to auto.

Editorial Implemented.

B29 (RO 54, SRO 29):

Double jeopardy with B02.

B02 was changed. Examiners identified that there were two correct answers. Distractor a was changed so that Control Bank B demand was greater than 35 steps to make the answer incorrect.

A post-exam review of this question by the examiners revealed that all 4 answers were correct and the question was removed from the exam.

B31 (RO 56, SRO 31):

Technical issue related to sequencing of the pumps and discharge valves. There are no interlocks or timers associated with these functions. Pumps would receive start signal at same time as discharge valves receiving their open signals. Also need valve numbers.

Replaced question with one from licensee bank. RKW

Page 7 of 16 B32 (RO 57, SRO 32):

What is the purpose of this question? Why do we need all of these items in each distractor?

Can this be rewritten to make it still evaluate the target KA and yet be more straightforward?

There were no technical or psychometric problems with this question. The licensee did not like the way the question was written. No changes were made. The beginning of the first distractor was edited to read only based on a NRC supervisor review comment.

The purpose was to make all the distractors appear more alike.

B33 (RO 58, SRO 33):

Use the acronym ICS in the stem instead of CS. In the distractors use CFCUs instead of RCFCs.

Editorial done.

B34 (RO 59, SRO 34):

Technical issues related to makeup capacity. The desired correct response may be wrong. B may be the highest capacity, short of using service water. While the stem addresses using A-SFP-21, conditions not identified in the stem but could be reasonable assumptions could lead to choosing A, Service Water. Need something in the stem to make A incorrect.

Reshuffled answers (editorial), added preferred to stem to make SW distractor incorrect, Changed answer from C to D, deleted reference to highest possible flow capacity. RKW After 2nd OV, deleted preferred from stem, changed stem so that answer A, SW is correct to follow procedure. Also changed stem format. RKW B35 (RO 60, SRO 35):

We would never do a manual load increase. It isnt in our procedures on purpose. Also, a 2 second manipulation of the manual CV pushbuttons would cause shrink or swell initially due to the steam flow demand change. Operation validity is questionable. Could be changed to be a manual load reduction using the same criteria. I would recommend changing the pushbutton operation to much longer or very much shorter to obtain the desired response.

After 2nd validation, question was deemed OK as is by licensee! RKW B36 (RO 61, SRO 36):

Double jeopardy with R16?

Replaced question (kept same KA) to remove double jeopardy with R16. MEB B37 (RO 62, SRO 37): Double jeopardy with B47. No correct response. Air ejector is normally aligned to the vent header.

Changed Question B47 to Monitor R-15, took out R-19 failure condition and modified correct answer to reflect NORMAL alignment. Added AR-6 (CV-31168) and changed normal to duct position and changed alternate to ATM position - to match licensee vernacular. RKW

Page 8 of 16 B38 (RO 63, SRO 38):

Needs major work. Response is contained in a local alarm response procedure. Questionable operational validity at the RO/SRO level. There is no correct response. Lots of problems.

Rewrote question and incorporated a correct response. Licensee comments to remove reference to procedures in distractors would result in the question not meeting the K/A.

RKW Reworded the Question by taking references to the procedures out of the distractors and puting a reference to the procedure in the stem to answer the K/A and ensure the question was at the RO level.

B39 (RO 64, SRO 39):

Change upon to prior to in stem (will read RHR heat exchanger prior to RHR pump start Editorial done.

B42 (RO 67, SRO 42): Highlight cannot in stem Editorial done.

B43 (RO 68, SRO 43): Double jeopardy with R06 and R08.

Rewrote question, changed K/A from K4.02 to K4.03 because the K/As for R06 and R08 were almost identical. RKW B44 (RO 69, SRO 44): TS LCO of greater than one hour, no references, also not appropriate for RO.

After 2nd validation, question was deemed OK as is! Added within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 3 distractors so question would be applicable to ROs IAW learning objective in lesson plan. RKW Added reference to question.

B45 (RO 70, SRO 45): Make 2 distractors less generic and more specific.

Added Bus 4' to 1st distractor and changed 3rd distractor from Reactor Protection Power to Reactor trip breaker shunt coil. RKW B46 (RO 71, SRO 46): No comment.

The question was reworded by saying that the power was lost to a bus and asking what component was impacted. This was to make the question more difficult based on a NRC supervisory comment.

Page 9 of 16 B47 (RO 72, SRO 47): Double jeopardy with B37. Also, how does the rad monitor fail.?

Changed Question B47 to Monitor R-15 from Monitor R-19. Changed failure from low to high in stem. Added noun names to choices 1 & 3 in stem. RKW B52 (RO 77, SRO 52): Technical issues about PR-2A indications and acoustic monitor indications. If you want to have them indicate open, have the red lamp on for the PR-2A and have the acoustic red light on.

Added descriptor indicating lights to PR-2A(B) and acoustic monitor in choices I and II in stem. RKW B53 (RO 78, SRO 53): It appears that the last two bulleted items in the stem are window dressing.

Licensee withdrew comment at 2nd validation. Changed format of question to read easier. RKW B55 (RO 80, SRO 55): Change item (II) in stem to Open Bus 33 and Bus 43 supply breakers.

Editorial, done. Added locally to 1st distractor. RKW B57 (RO 82, SRO 57): Annunciator titles are normally all caps.

Editorial done. Modified question stem to make it more direct. RKW B58 (RO 83, SRO 58): There may be tech issues associated with the issue of going from IC to proportional. Recommend limiting this to three blanks that address the original region of operation, voltage change, and resultant region.

Licensee Edited question. Incorporated some comments, changed stem and distractor to accept 2 blanks in lieu of existing 4 choices! RKW B59 (RO 84, SRO 59): Change stem to read:

A reactor startup is in progress with power at 1 x 106 cps on the source range nuclear instruments.

What is the expected indication on the intermediate range nuclear instruments for this condition?

Comment not completely incorporated. Comment above does not reflect the KA 000033A201 condition of a failed IR. Kept original question conditions of degrading intermediate NI and reworded question root to stress expected intermediate range indication. RKW

Page 10 of 16 B60 (RO 85, SRO 60): Add bulleted item to stem:

TLA-15, RMS Above Normal is in alarm Comment incorporated. Added redundant alarm to ensure condition is actual and not a failed indicator. Reformated question to make it read easier. Replaced transition to go. RKW B62 (RO 87, SRO 62): Change choice option to read:

C.

(1) Depressurize SG and establish condensate flow.

Comment incorporated. FR-H.1 has operators depressurize RCS then depressurize SG.

RKW B63 (RO 88, SRO 63): No correct answer. Distractors A & B are inplausible.

Rewrote question. Meets K/A and all distractors are plausible.

B64 (RO 89, SRO 64): No correct answer. Distractors A & B are implausible. Licensee rewrote question.

Incorporated new licensee question. Per telecon with Tom Hunt, verified correct answer and incorrect distractors since could not verify same with licensee-provided material.

Also changed question from higher to memory. RKW B65 (RO 90, SRO 65): Questionable operational validity.

Replaced question with licensee-provided question. RKW The licensee came up with a complete change to this question, but then left the change and the associated K/A reference on a desk uncontrolled overnight. This question and K/A now had to be replaced. On the final submittal, the licensee provided an alternate question that met both the new K/A and the review of the NRC exam preparer.

Page 11 of 16 B68 (RO 93, SRO 68): Revise stem as follows:

The plant is operating at 100% power on December 1, 2003 when the following timeline of events occur regarding the containment penetration isolation valves for the pressurizer liquid sampling line.

0100: RC-413, Pressurizer Liquid Sampling Isolation valve is determined to be inoperable.

0200: RC-412, Pressurizer Liquid Sampling Isolation valve is determined to be inoperable.

Which action or set of actions below would preclude the need to place the plant in HOT STANDBY per Technical Specification requirements?

A.

RC-413 is restored to operability at 0248 on 12/01/03.

D.

RC-412 is restored to operability at 0640 on 12/01/03.

E.

RC-413 is restored to operability at 0345 on 12/01/03; RC-412 is restored to operable status at 0220 on 12/02/03.

F.

RC-412 is restored to operable status at 1130 on 12/01/03; RC-413 is restored to operable status at 1615 on 12/01/03.

During 2nd validation the licensee wanted a change so that the question focused more on tracking the LCO instead of the LCO itself.

The question was revised to ask the applicant what were the logging requirements once a piece of equipment was identified as inoperable.

B69 (RO 94, SRO 69): Operational validity. You cant get there from anywhere that is plausible. If evaluating the Verify Flow step 2, then change the question.

While executing FR-C.3, Response To Saturated Core Cooling, step 2 contains actions to meet the high level action of Verify SI Flow In Both Trains.

Which of the following RCS condition and action statements satisfies the actions for that step?

RCS pressure is A.

375 psig; only SI flows are verified.

B.

225 psig; both RHR and SI flows are verified.

C.

175 psig; only RHR flows are verified D.

125 psig; only SI flows are verified.

Comment NOT incorporated - F-0.2 defines the region where FR-C.3 is applicable and the original question is in that region. The suggested alternative changes the question to merely recognizing pressures where certain pump flows can be verified. In addition, a good hint for the correct answer is also given in the stem. Minor edits were made to the question for clarity.

Page 12 of 16 B71 (RO 96, SRO 71): Change stem as follows:

Change Where is this valve located? to Which elevation of the auxiliary building is this valve located on?

Change distractors to:

A.

586 elevation B.

606 elevation C.

626 elevation D.

633 elevation Comment incorporated except that 633' plausible distractor was changed to 572' plausible distractor, Auxiliary Building was pulled out of distractors and added to root.

RKW B74 (RO 99, SRO 74): Change stem as follows:

A reactor startup is in progress per N-CRD-49B, Reactor Startup. The following plant conditions exist:

Reactor power is stabilized at the eight-fold power level.

The Eight-Fold Critical Rod Position is determined to be 65 steps on Control Bank C.

Which action is required in this situation?

Comment incorporated. Statement above more succinct than proposed question. RKW S01 (SRO 76):

Change bulleted item It is now being determined to Tech Spec 3.10.e, Rod Misalignment Limitations, evaluation is being performed.

Change the word gives to identifies in the question stem (now will read Which of the following identifies)

Editorial done.

Page 13 of 16 S03 (SRO 78):

This has several problems. A rod drop at 95% power would trip the reactor on negative rate, so it has operational validity issues.

Recommend changing stem as follows:

Replace Given with:

The plant is operating at 95% power.

Four hours ago, rod G7 in control bank C dropped (ratcheted) in to position 170 steps.

Delete the original first bulleted item.

Retain the original second bulleted item.

Comment incorporated. Pulled Order power reduced to below.. statement from all distractors and reworded stem to accommodate. Did not incorporate time element suggested by licensee since it would be considered a clue. Included ratcheted in stem.

Added 3rd condition in stem at licensee request. RKW S04 (SRO 79):

Spell out abbreviated words in distractors. Instead of two column format, just use prose for the distractors.

Comments incorporated. Eliminated 2-column format for easier reading and spelled out abbreviated words in distractors. RKW S05 (SRO 80): What is the operational significance of this question? This is a litany of long-term mitigation strategies that are driven by plant tech support staff, not operating crews. The link to the KA is weak. If this topical area is appropriate, suggest writing question such that it asks which of the distractors is a reason the ED would be consulted at that point in the IPEOP execution. Suggest using containment sump pH adjustment as the desired response.

Comment incorporated. Replaced question (kept same KA) to improve operational significance, provide a better link to KA, and incorporate containment sump pH adjustment as the desired response. MEB. After 2nd OV, deleted reference in stem that Hi-3 signal was NOT generated, and added, containment pressure peaked at 20 psig.

RKW

Page 14 of 16 S06 (SRO 81): Add the following as the start of the stem of the question, The plant is in HOT SHUTDOWN.

Edit question to read Which of the following choices identifies all of the components that are required to protect against RCS overpressurization assuming residual heat is not removed by any other means per the bases for Technical Specifications 3.1.a, Reactor Coolant System, Operational Components.

Comment not incorporated. If incorporated, question would not meet K/A statement of pressurizer pressure control system malfunction. Added only to distractors. RKW After 2nd verification of exam, reformatted question to read easier and added initial condition, the reactor tripped from 100% power. RKW S07 (SRO 82): Replace the first bulleted item in the stem to read Refueling operations are in progress.

Add a new, second bulleted item, The first assembly is being moved from the core to the reactor building upender for transfer to the spent fuel pool.

Distractor B & C only discriminate about the latched v. unlatched status of the bundle. Is this significant enough to test? Recommend replacing distractors B & C as follows:

B. Direct placing the assembly being moved into the upender in the reactor building and do NOT unlatch the bundle.

C. For the assembly being moved, direct the operator to immediately halt movement and evacuate containment.

Note: the issue of latched v. unlatched in B above is tied to being able to move the upender carriage from reactor building to the spent fuel pool. This prevents that from being done.

First 2 comments incorporated. Distractors not changed since they are from E-FH-53B, Subsequent Actions section and are incorrect. Incorporation of proposed distractor C would make 2 correct answers. RKW S08 (SRO 83): Delete last bulleted item in the stem. These are the sample discharge valves and they would remain aligned to the aux building vent, not have aligned. This is a confusing item to put in stem.

Comment not incorporated. First 4 bulleted items are indicative of R-13 and/or R14 rad monitors alarming. The last bullet eliminates R13 as the alarming unit and points to R14 as the alarming radiation monitor. RKW After 2nd Exam verification, deleted 2nd bullet in stem since it is unnecessary information. RKW

Page 15 of 16 S09 (SRO 84): Add this bulleted item to the stem, SW pumps A1, A2, and B1 and in service.

Replace the stem question with Which of the following statements describes the appropriate actions regarding the reactor and the service water pumps in this situation?

A.

Stop SW pumps in alternating trains until cavitation stops, then trip the reactor.

B.

Trip the reactor, then stop all SW pumps.

C.

Stop all SW pumps, then trip the reactor.

D.

Trip the reactor, then stop SW pumps in alternating trains until cavitation stops.

First comment incorporated however, distractors not changed since for SRO question, procedure references required by CFR55.43.b(5). Without procedure reference, could be viewed as a BOTH question! RKW S10 (SRO 85): Replace the first bulleted item with A plant startup is in progress at 6% power.

Add a bulleted item in stem with The main turbine is being rolled to 1800 rpm.

Change the last bulleted item in stem to The green and red lamps for MS-1B, Main Steam Isolation Valve are lit.

Comment incorporated. New question now more accurately describes as-seen plant conditions. RKW S11 (SRO 86): Change stem as follows:

A small break LOCA occurred and the reactor failed to trip. FR-S.1, Response to Nuclear Power Generation/ATWS is being performed. The following conditions exist:

Containment pressure: 6 psig SG narrow range levels: both 6%.

AFW pumps A and B are running.

Actions are proceeding to shut down the reactor.

What actions should be taken with respect to AFW in this situation?

A.

Place TD AFW pump to pullout and control AFW flow rate to maintain greater than 4%

narrow range SG level.

B.

Manually start the TD AFW pump and maintain AFW flow rate greater than 200 gpm.

C.

Manually start the TD AFW pump and maintain AFW flow rate greater than 400 gpm.

D.

Place the TD AFW pump to pullout and maintain AFW flow rate greater than 200 gpm.

The opening comment above tells examinee that ATWS has occurred. This question is a higher level question since examinee must determine ATWS has occurred from information provided. Incorporated some initial conditions and suggested distractors.

Provides for cleaner question. RKW

Page 16 of 16 S13(SRO 88): Add noun names for rad monitors in bulleted list.

Change question to read What is the correct procedure to transition to from ES-0.0, Rediagnosis.

Comment incorporated. Clarifies RM type/function, improves grammar in question.

RKW S16(SRO 91): Recommend deletion of last bulleted item.

Recommend reversing the sequence of the third and fourth bulleted items.

Reversed 3rd & 4th bullet. Did not incorporate deleting last bullet since last bullet is provided as an unusual event distractor. RKW S17(SRO 92): Specify accumulator and add SI Changed X accumulator to SI Accumulator X to make more specific. Changed time from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in 2nd distractor to make it incorrect. RKW S18 (SRO 93): Need to resolve initial conditions similarly to RO 20 question.

Comments incorporated - CDZ S20 (SRO 95): In stem, change the word INTENT to Change of Intent and NON-INTENT to Non-Change of Intent.

Comment incorporated to meet licensee vernacular. RKW