ML051720142

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NRC Comments to Initial Submittal Including ES-410-9 and Operating Comments for the Quad Cities Initial Examination - May 2005
ML051720142
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 05/31/2005
From: Melodee Jensen
Exelon Generation Co
To:
Office of Nuclear Reactor Regulation
Shared Package
ML051610145 List:
References
50-254/05-301, 50-265/05-301, ES-410-9
Download: ML051720142 (17)


Text

NRC COMMENTS TO INITIAL EXAM SUBMITTAL INCLUDING ES-410-9 AND OPERATING COMMENTS FOR THE QUAD CITIES INITIAL EXAMINATION MAY 2005

1. 2. 3. PsychometricFlaws 4. Job Content Flaws 5. Other 6. 7.

Q# LOK LOD (FIH) (1-5) Stem Cues T/F Cred. Partial Job- Minutia #/ Back- Q= SRO UIWS Explanation Focus Dist. Link units ward WA Only 1 F 2 S Bank.

2 H 2 E Bank. 1) Change LOK from Fundamental to Higher Cognitive Level.

2) Why is the phrase "After 10 minutes" inserted into the question stem instead of just omitting the phrase?

RESOLUTION: 1) Comment incorporated. 2) The phrase "After 10 minutes" was deleted.

3+ H 1 U New. LOD = 1, since can read 120 Volts from Figure and easily get correct answer that the 125 Volt system is malfunctioning.

RESOLUTION: Replaced question (Fundamental, New) with one with the same WA.

4 F 2 S New.

Instructions

[Refer to Section D of ES-401 and Appendix B for additional information regarding each of the following concepts.]

I. Enter the level of knowledge (LOK) of each question as either (F)undamentalor (H)igher cognitive level.

7 Enter the level of difficulty (LOD) of each question using a 1 - 5 (easy - difficult) rating scale (questions in the 2 - 4 range are acceptable).

3.

Check the appropriate box if a psychometricflaw is identified:

The stem lacks sufficient focus to elicit the correct answer unclear intent, more information is needed, or too much needless information).

.. Check the appropriatebox if a job content error is identified:

.. The question is not linked to the job requirements (Le., the question has a valid WA but, as written, is not operational in content).

The question requires the recall of knowledge that is too specific for the closed referencetest mode (i.e., it is not requiredto be known from memory).

. The question contains data with an unrealistic level of accuracy or inconsistent units (e.g., panel meter in percent with question in gallons).

The question requires reverse logic or applicationcompared to the job requirements.

2. Check Questionsthat are samoled for conformance with the approved WA and those that are designatedSRO-only (WA and license level mismatches are unacceptable).

>. Basedon the reviewer's judgment, is the questionas written (U)nsatisfactory (requiring repair or replacement), in need of (E)ditorial enhancement, or (S)atisfactory?

le. At a minimum, explain any "U" ratings (e.g., how the Appendix B psychometricattributes are not being met).

A "+" in the "Q#" column indicates that question was reviewed as part of the representative sample of 30 questions.

ES-401 2 Form ES-401-9

- ies May 2005 Exam QL IdC 7.

3. PsychometricFlaws
4. Job Content Flaws
ues Kq-7 units
  • lack- Explanation Dist. Link -

5 H

- New.

1

~~

6+ F E New. In the question stem, change the word "should" to "are required to". This comment applies in two places in the question stem.

- RESOLUTION: Comment incorporated.

7 H E ,New. Change LOK from Fundamental to Higher Cognitive Level.

-RESOLUTION:Comment incorporated.

8 H S 1 New.

9+ F S 1 Bank.

10 F 11 H I I S INew.

12 H

-3 13+ F 2 U New. Questions associatedwith background knowledge of the SAMGs are not appropriatefor an ILT exam.

RESOLUTION: Replaced question (Fundamental, Bank) with one with

- the same WA.

14 H 2 U New. Distractors A and B are not plausible that an increase in torus water temperaturewould cause a decrease in torus water level or an increase in torus airspace (since almost everyone knows that water expands when heated). Suggest deleting the first three words of each distractor and adding The resultant" instead. 2) By doing the change suggested in item l ) , it would result in distractor B also being correct.

Would need to then change distractor B .

RESOLUTION:Comments incorporated.

15 F 2 E New. In the question stem and in the distractors. need to delete the word "should and replace with "shall" or "are required to be"..

- - RESOLUTION: Comment incorporated.

3. PsychometricFlaws I 4. Job Content Flaws 5. Other 6. 7.

Ainutia UIEIS Explanation

~~

16+ E New. 1) In the question stem change "RCIC should ._."to"RCIC is ...".

2) With the Torus level at10.5 feet and Torus pressure at 12.0 psig per the question stem, the QGA-200, Figure L, "Pressure Suppression Pressure" limit would be exceeded and a blowdown would be required per the Primary Containment Pressure leg of the flowchart.

RESOLUTION:Comments incorporated.

7 17 E Bank. In distractor B. change wording to "... because RHR systems are injecting at rated flow".

NOTE: Question requires reference.

- RESOLUTION: Comment incorporated.

18 E Modified. 1) Parts of QGA-101 should not be available to answer this question. Otherwise, it is a direct lookup. 2) Delete the word "should" from the question stem and replace with "shall".

NOTE: Question requires reference.

RESOLUTION: 1) QGA-101 will be available as a reference, but part of

- QGA-101 will be blanked out. 2) Comment incorporated.

19+ S New.

7 20 7

S New.

21 E New. In distractor A delete the words "by the NSO".

- - RESOLUTION: Comment incorporated.

22 S New. The supportingmaterial provided does not support distractor A as the correct answer for all EOP situations in which there is high drywell pressure. QGA 200 does not monitor drywell rad levels when drywell pressure is high. The reference provided is only for QGA 500-4, "RPV Flooding". One could argue that the question stem is misleading. Also, the step in the flowchart for QGA-500-4 that checks for core damage occurring is associated with a transition to the SAMGs, which is not appropriate at the RO level.

RESOLUTION:Another reference provided (QCOA 0201-01, "Increasing

- - Drywell Pressure") that supports distractor A as the correct answer.

23+ E Modified. Distractor C is not plausible that an LP Heater String Bypass Valve closed could cause the indications mentioned in the question stem, since one would expect this valve to be closed. Suggest replacing distractor with an SRV that is open.

- RESOLUTION:Comment incorporated.

Explanation its ward WA Only S New.

E New. Editorial: Add "psig" after 1' 125"in the question stem.

RESOLUTION:Comment incorporated.

S New.

E New. Distractor C is not plausible that a loss of 125 VDC on Unit 2 would make both the normal and reserve power supplies to the Unit 1 ADS valve solenoids unavailable.

RESOLUTION:Comment incorporated. Question was re-phrasedand t S S

distractors changed such that all are plausible.

New.

New.

S New. On the Written Exam Answer Key for the question, change the "Importance RO" from 3.60to 2.60.

RESOLUTION: Comment incorporated.

E New. In the second sentence in the question stem, reword to delete the word "should" (e.g., "when is the voltage to be compared).

RESOLUTION:Comment incorporated.

E New. 1)Tech Spec Table 3.3.8.1-1 allows a range of as low as 3885 VAC for the Degraded Voltage setpoint. Also, QOA 900-8G-12 page 1 states that the "4KV Bus 14-1Voltage Degraded" alarm setpoint is 3820 V. Thus, to ensure that the Unit is in a condition where the alarm and Degraded Voltage actuation should have occurred, change the voltage in the question stem from '3890 VAC" to "3700VAC".

2) In the question stem delete the word "should" and replace with"are to
3) Editorial: In distractor B in the third sentence, change wording to " ...

CANNOT be restoredwithin 5 minutes, ...".

NOTE: Question requires reference.

RESOLUTION:Comments incorporated.

47 F 3 S New.

48 H 3 S New.

49+ F 2 I I I S New.

I I I 6 I KqT -

4. Job Content Flaws 5. Other 7.

f 7

Back- SRO UIWS Explanation units ward 7 -

New. Distractor B mentions a "LOCA load shed", but in the question stem it does not state that a LOCA has occurred. Should the question stem be changed to state that a LOCA occurred?

- RESOLUTION:Comment incorporated.

New. Distractor B is not plausible that instrument air is used for breathingair.

- ~~

RESOLUTION:Comment incorporated. Distractor B was changed.

Modified.

S New.

S New.

S New.

Tl I I I I I E l S Bank. In the question stem delete the second and third bulleted (-)

items, since they are not necessary to answer the question.

RESOLUTION: Comment incorporated.

New.

S New.

~~ ~~

E New. 1) In the question stem change the Drywell temperature from 290 degF to 240 degF, so that initially one is not at the RPV saturation temperature. Also, change the question stem to state that Drywell temperature is STEADY, so that one would expect temperature to increase when Torus cooling flow is increased on Loop6 (and thus taking flow away from Drywell sprays). 2) In the question stem delete the word "sooner". 3) In all the distractors change "may" to "could".

- RESOLUTION:Comments incorporated.

S Bank.

~ ~

3. PsychometricFlaws 4. Job Content Flaws 5. Other 6. 7.

62 I

Job- Minutia Link UIE/S E

Explanation New. Distractor B is not plausible that the Steam Seal System will prevent generator seal oil leakage. Does QC have any other oil pumps associated with the turbine (e.g., Seal Oil Backup Pump) that could be place in the distractor?

RESOLUTION:Comment incorporated. Changed distractor B to "NOT

- change because the Emergency Bearing Oil Pump is still in service".

New.

63+ S 64 E Modified. In the question stem change the beginning of the first sentence from The plant was ..."to "Unit 1 was ...".

- RESOLUTION:Comment incorporated.

~~

65 H 3 s IBank.

NOTE: Question requires reference.

66+ F E New. 1) In the question stem add that Unit 1 is in Mode 2. Due to this delete the mention of Mode 2 in distractor D. 2) Change distractor C to referencesomething other than an RPV water level that would require entry into the EOPs. 3) Change distractor B from "1006 psig" to "1020 psig", since a pressure of only 1 psig above the Tech Spec limit may keb one to the 1005 limit.

- - RESOLUTION: Comments incorporated.

67 H E New. In the question stem add words to the effect that the reactor is with reactor power at 36% and core flow at 52 Mlbhr.

NOTE: Question requires reference.

-- - RESOLUTION:Comment incorporated.

68 H X U Bank. 1) This question is at the SRO level [10CFR55,43(b)(3)]. 2) In thc question stem add the words "before implementation",since otherwise distractor D could be consideredcorrect since the procedure itself would have required a 50.59 screening.

RESOLUTION: Replaced question (Fundamental,New) with one with

-- - the same WA.

69+ F S New. This question is at the SRO level [10CFR55,43(b)(2)],unless the ROs have a specific LearningObjective to know the Safety Limits from memory.

RESOLUTION:Question is Satisfactory. The ROs have a specific 7 - LearningObjective to know the Safety Limits from memory.

~ ~ ~~

3. PsychometricFlaws 4. Job Content Flaws 5. Other Explanation Bank. 1) This question is at the SRO level [10CFR55,43(b)(2)].
2) The correct answer appears to distractor A, since the switch is inoperable when it is valved out (since it is not capable of performing its intended function).

RESOLUTION: Replaced question (Fundamental,New) with one with a different WA.

Bank.

m:Question requires reference.

Bank. 1) In the question stem change "should" to "shall'. 2) To make distractor B more plausible, change the time from "60 minutes" to "45 minutes". RESOLUTION:Comment incorporated.

73+ 2 New. In the question stern change "should" to "are required to"

- - RESOLUTION: Comment incorporated.

74 2 New. In distractors A and C, change "Q(C)OAs" to "QOAs or QCOAs".

- - RESOLUTION:Comment incorporated.

75 3 New. In the question stem change "should" to "are required to".

- RESOLUTION:Comment incorporated.

2 New.

3 3 New.

3 Modified. 1) The explanationfor distractor C being incorrect is not right.

It states that Pressureand Temperature are within the D w e l l Spray Initiation Limit. However, the DSlL has not been reached yet. If the DSlL was reached, then distractor C would be the correct answer.

2) The explanation that distractor A is incorrect is that the Heat Capacity Limit is not being threatened because Torus water temperature is lowering. However, the question stem states that Torus water temperature is rising. This would make distractor A also a correct answer. Suggest changing the question stem to state that Torus water temperature is lowering.

NOTE: Question requires reference.

- RESOLUTION: Comments incorporated.

3 New.

7.

Explanation New. To increasethe Level of Difficulty of the question, suggest asking

... that would REQUIRE a site assembly (if a site assembly is only REQUIRED at the Site Area Emergency level and above).

NOTE: Question requires reference.

RESOLUTION: Comment incorporated.

___ ~ ~

Modified. The suggested reference is QCOA 0010-12 Attachment C pages 4 and 5. To avoid directing the applicant to the correct answer, suggest giving the applicant the entire CODY of QCOA 0010-12 (if this informationwould not assist answeringany other question).

NOTE: Question requires reference.

RESOLUTION: Comment incorporated.

Bank.

New. With the Tech Spec referencesprovided, this question is a direct lookup and LOD = 1.

RESOLUTION: Comment incorporated. Revised question so that no referencesare required.

Bank.

NOTE:Question requires reference.

~~~ ~

NI 1) With Tech Spec 3.5.1 provided as a reference, answering the second part of the question becomes a direct lookup. Suggest changins the question stem so that Loop A becomes the broken discharge line foi Core Spray instead of Loop B. The correct answer then becomes distractor D, based on entering LCO 3.0.3 (13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> clock to Mode 3).

with LCO 3.0.3 not providedas a reference. 2) On the Written Exam Answer Key for the question, change the Importance RO from 3.20 to 3.30, and change the Importance SRO from 3.20 to 3.60.

RESOLUTION: 1) Comment incorporated. Also, deleted Tech Spec 3.5.1 as a reference. 2) Comment incorporated.

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QUAD CITIES MAY 2005 INITIAL LICENSE EXAM OPERATING EXAM COMMENTS

  1. Source Comment I Resolution 1 Scenario No. 1 For Event 2, change the Event Type for the SRO from Comment incorporated.

R to N ,since only the RO can get credit for an R.

Scenario Outline Sheet

2. Scenario No. 1 Add Tech Spec 3.5.1 Conditions F and H as Comment incorporated.

applicable to this event.

Event 5 [Comment during onsite validation]

Page 5 of 10

3. Scenario No. 1 Add steps required to start the SSMP from the Comment incorporated.

hardcard. [Comment during onsite validation]

Event 8 Page 8 of 10

- I I

4. Scenario No. 1 In the SRO action to verify recirc pumps and drywell Comment incorporated.

coolers tripped, delete the requirement that this is a Event 8 Critical Task, since this action is only a verification of Page 9 of 10 an action that should have occurred automatically.

[Comment during onsite validation]

5. Scenario No. 2 For Event 6, change the Event Type for the SRO from Comment incorporated.

(Not Validated - R to N , since only the RO can get credit for an R.

Extra Spare)

Scenario Outline

- Sheet

6. Scenario No. 2 Need to add to the Turnover that APRM #1 is Comment incorporated.

(Not Validated - bypassed (per Summary on next page of scenario).

Extra Spare)

Scenario Outline Sheet I

7. Scenario No. 3 For Event 5, change the Event Type for the SRO from Comment incorporated.

R to IN, since only the RO can get credit for an Fi.

Scenario Outline

- Sheet

~ ~ ~ ~~

8. Scenario No. 3 In the Turnover, delete the statement that HPCl is Comment incorporated.

OOS, since if HPCl was 00s it would cause a Tech Scenario Outline Spec 3.0.3 entry during Event 1, which is not Sheet desirable. [Comment during onsite validation]

[NOTE: This comment makes Event 1 initially Unsatisfactory.]

9. Scenario No. 4 Move Event 2 ( A CRD pump trip) to after the current Comment incorporated.

(Validated Spare) Event 4, in case the crew decides to scram the Reactor during this event.

Scenario Outline [Comment during onsite validation]

- Sheet

QUAD CITIES MAY 2005 INITIAL LICENSE EXAM OPERATING EXAM COMMENTS

  1. Source Comment Resolution
10. Scenario No. 4 For Event 5, change the Event Type as follows: Comment incorporated.

(Validated Spare) BOP gets a C RO gets an R Scenario Outline SRO gets a C

- Sheet

~~~ ~

11. Scenario No. 4 Make the A TBCCW pump trip embedded in Event 5 Comment incorporated.

(Validated Spare) a separate event (Event 6).

Event 5 Page 6 of 11

- ~~ ~~ ~

12. Scenario No. 4 Delete mention of the Lead Examiner (LE) directing Comment incorporated.

(Validated Spare) the simulator operator to perform certain actions. The examiners can not be involved in the scenario.

Events 7, 8 Change to have the applicant contact the simulator Page 9 of 11, operator to perform certain actions.

Page 10 of 11

13. Scenario No. 4 For the SRO/RO actions to report RPV level, delete Comment incorporated.

(Validated Spare) these as Critical Tasks.

[Comment during onsite validation]

Event 8 Page 10 of 11

14. Generic Need a Task Standard specified for each JPM per the Comment incorporated.

Comment for All Examiner Standards, Appendix C, page 3 of 10.

- JPMs

~ ~~ ~~ ~

15. JPM SYS-c For step D.2.a,b, add: Verifies closed M O 1-2301-5. Comment incorporated.

- Page 8 of 15

16. JPM SYS-c Add step F.7.f to verify the Emergency Oil Pump is off. Comment incorporated.

Page 12 of 15

- ~~

17. JPM SYS-c For step F.7.i, add to the Standard: Comment incorporated.

Pump discharge pressure 5 1250 psig

- Page 13 of 15

18. JPM SYS-d For step F.2.h, rewrite the Standard to reflect that the Comment incorporated.

A RHR pump is started approximately 2 seconds Page 8 of 10 after the discharge valve starts to open.

[Comment during onsite validation]

19. JPM SYS-d Delete step F.2.k from the JPM, since this step would Comment incorporated.

be performed after the JPM is already complete per Page 8 of 10 the Initiating Cue.

- [Comment during onsite validation]

Page2of 5

QUAD CITIES MAY 2005 INITIAL LICENSE EXAM OPERATING EXAM COMMENTS

  1. Source Comment Resolution
20. JPM SYS-e Change Site Emergency to Site Area Emergency. Comment incorporated.

- Page 6 of 10

21. JPM SYS-e Add to the Initiating Cue that RPS and ESS are Comment incorporated.

energized. [Comment during onsite validation]

- Paae 6 of 10

22. JPM S Y S f Can not have the Evaluator asking the simulator Comment incorporated.

operator to request that the speed droop be set to 0.

Page 7 of 10 Need to have the applicant call the simulator operator to have this action completed.

23. JPM SYS-g After step F.5, add a CUE that alarm 901-3 C16 is in Comment incorporated.

alarm, since the applicant would not be able to verify Page 7 of 9 this alarm from the back panel while holding the TRIP CHECK pushbutton in.

[Comment during onsite validation]

24. JPM SYS-g This JPM is listed as an Alternate Path on this page. Comment incorporated.

However, this JPM is not an alternate Path, since Page 8 of 9 there is no success path after the surveillance test failure associated with the failure of the high trip setpoint to work properly. The JPM Outline Sheet correctly lists this JPM as not an Alternate path.

7 ~~

25. JPM SYS-j Change the Initial Conditions as follows: Comments incorporated.

Add that all control rods are in.

Page 4 of 8 Change Unit Supervisor to Shift Manager to agree with wording in procedure QCOP 1100-08.

Add that the SBLC tank in not available.

lComments durina onsite validation1

26. JPM SYS-k Make the first step to obtain the procedure and Comment incorporated.

equipment to be used a Critical Step.

[Comment during onsite validation]

- Page 5 of 7

~ ~

27. Admin JPM Change so that it does not state that the simulator is Comment incorporated.

AD- SRO-1 needed for this JPM?

Page 4 of 10

28. Admin JPM Add procedure QCOA 4100-1 1 as a procedure that is Comment incorporated.

AD-SRO-1 available to the applicant during the administration of the JPM. [Comment during onsite validation]

- Page 4 of 10

29. Admin JPM In the Step column, add an asterisk to show that Comment incorporated.

AD-SRO-1 step D.2.c(4) is a Critical Step, and another asterisk to show that the step just after step D.2.c(4) is a Critical

- Page 7 of 10 Step.

Page 3 of 5

QUAD CITIES MAY 2005 INITIAL LICENSE EXAM OPERATING EXAM COMMENTS

  1. Source Comment Resolution
30. Admin JPM For Equipment Control, replace the JPM titled Review JPM replaced with a new AD-SRO-3 Temporary Change package to Determine if it can be one that satisfies the same Accepted for Operation, and replace with JPM titled WA (WA 2.2.1 1).

Review Abnormal Component Position Sheet.

Reason: The original JPM took too long during site validation (before the NRC on-site validation) to complete (could take as long as 90 minutes).

[NOTE: This comment makes Admin JPM AD-SRO-3 initially Unsatisfactory.]

31. Admin JPM To provide more flexibility for the applicant, change so Comment incorporated.

AD-SRO-3 that the Critical Step is to EITHER add the Control Switch OR the breaker and control power fuses to the Page 7 of 9 Abnormal Component Position Sheet.

[Comment during onsite validation]

32. Admin JPM In the OP-AA-108-101, Attachment 2, Abnormal Comment incorporated.

AD-SRO-3 Component Position Sheet, change so that valve 2-1099-96 is listed as Uncapped and open instead of valve 2-1099-100A (since only valve 2-1099-96 has a cap adjacent to it).

33. Admin JPM Is this JPM task (developing a Pre-Job briefing for On 4/6/05 verified with site AD-RO-4 NLOs and selecting NLOs to perform a radiation area that this JPM is part of the job for an RO.

- related task) part of the job of an RO?

34. Admin JPM Change the title of the JPM to Select Personnel for Comment incorporated.

AD-SRO-4 Radiation W o r k to better reflect the task of the JPM.

[Comment during onsite validation]

Admin JPM AD-RO-4

- Page 1 of 10

~ ~ ~~

35. Admin JPM Change the Initiating Cue so that the task is to Comment incorporated.

AD-SRO-4 calculate the expected dose for the job, determine who and who can not perform the job, and why a Admin JPM person can or can not perform the job. Add Critical AD-RO-4 Steps to determine the expected dose for the job, and the reasons why each applicable person can not Page 5 of 10 perform the radiation related work.

[Comment during onsite validation]

[NOTE: This comment makes Admin JPM AD-SRO-4

- and Admin JPM AD-RO-4 initially Unsatisfactory.]

36. Admin JPM Add procedure EP-MW-114-100 as a procedure that Comment incorporated.

AD-SRO-5 is available to the applicant during the administration of the JPM. [Comment during onsite validation]

- Page 4 of 11

37. Admin JPM Change to make it a Critical Step to identify the Comment incorporated.

AD-SRO-5 correct EAL number.

Page 8 of 11 Page4of 5

QUAD CITIES MAY 2005 INITIAL LICENSE EXAM OPERATING EXAM COMMENTS

  1. Source Comment Resolution

- ~~~ ~ ~

38. Admin JPM Change to make step D.5.f a Critical Step to make a Comment incorporated.

AD-RO-1 plant announcement to assemble the Fire Brigade.

- Page 8 of 11

39. Admin JPM In the C U E near the top of the page, change Comment incorporated.

AD-RO-1 SECURITY Modules to EMERGENCY Modules

[Comment during onsite validation]

- Page 8 of 1 1

40. Admin JPM Change so that the applicant can use EITHER the Comment incorporated.

AD-RO-1 plant radio or the APB-1 key to transmit the messages for steps D.5.f and D.5.f (1).

- Pacre 8 of 11 [Comment during onsite validation]

41. Admin JPM In Step H . l .a, have an offsite power line 0 0 s but Comment incorporated.

AD-RO-2 such that there are still 2 other offsite power lines available (e.g., have line 0403 00s).

- Page 6 of 12 I I

42. Admin JPM For Steps H . l .l.(l) and H . l .l.(3), change the CUE to Comment incorporated.

AD-RO-2 just say that this step is not met.

[Comment during onsite validation]

- Page 8 of 12

43. Admin JPM In Step H.3.b, have the NLO return Attachment D with Comment incorporated.

AD-RO-2 all steps signed off, but with a comment that would result in an Acceptance Criteria not being met. Make Page 9 of 12 this step a Critical Step.

- I I I

44. Admin JPM In Step H.3.b, change Attachment D to Attachment Comment incorporated.

AD-RO-2 D and E. [Comment during onsite validation]

- Page 9 of 12 ~

45. Admin JPM Change Step H.5 to a Critical Step, with the critical Comment incorporated.

AD- RO-2 being to identify that 1) Transformer 12 feed to Bus 14 is not available, and 2) to identify the deficiency Page 10 of 12 inserted into Attachment D performed by the local operator.

[NOTE: This comment makes Admin JPM AD-RO-2 initiallv Unsatisfactorv.1

- I

46. Admin JPM -

Add print M 43 to the list of prints available to the Comment incorporated.

AD-RO-3 applicant. [Comment during onsite validation]

- Page 4 of 9 I 1 Page 5 of 5