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  
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. Psychometric Flaws
4. Job Content Flaws
5. Other
6.
7.

Q#

LOK LOD (FIH) (1-5) Stem Cues T/F Cred. Partial Job-Minutia

  1. /

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)undamental or (H)igher cognitive level.

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).

Check the appropriate box if a psychometric flaw is identified:

7

3.

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

le.

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

Check the appropriate box 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 reference test mode (i.e., it is not required to 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 application compared to the job requirements.

2.

Check Questions that are samoled for conformance with the approved WA and those that are designated SRO-only (WA and license level mismatches are unacceptable).

Based on the reviewer's judgment, is the question as written (U)nsatisfactory (requiring repair or replacement), in need of (E)ditorial enhancement, or (S)atisfactory?

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

2 Form ES-401-9

,New. Change LOK from Fundamental to Higher Cognitive Level.

RESOLUTION: Comment incorporated.

1 New.

ES-401 QL IdC -

5 H

6+

F 7

H 8

H 9+

F 10 F

11 H

12 H

13+

F 14 H

15 F

1 Bank.

3 2 -

2 2 -

U ies May 2005 Exam

3. Psychometric Flaws
4. Job Content Flaws New. Questions associated with background knowledge of the SAMGs are not appropriate for an ILT exam.

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

ues Dist.

Link Kq-7 units -

lack- *

7.

Explanation New. 1

~~

E -

E -

S S

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.

I I S INew.

U New. Distractors A and B are not plausible that an increase in torus water temperature would 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.

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.

16+

7 17 18 19+

20 21 7

22 23+

E E

E S

3. Psychometric Flaws I 4. Job Content Flaws

~~

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.

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

NOTE: Question requires reference.

RESOLUTION: Comment incorporated.

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.

New.

Ainutia

5. Other
6.

UIEIS

7.

Explanation S

E 7

S E

New.

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

RESOLUTION: Comment incorporated.

New. The supporting material 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.

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 47 F

3 48 H

3 49+

F 2

t 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-phrased and distractors changed such that all are plausible.

S New.

S New.

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

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 900-8 G-12 page 1 states that the "4KV Bus 14-1 Voltage 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 "3700 VAC".

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 restored within 5 minutes,...".

NOTE: Question requires reference.

RESOLUTION: Comments incorporated.

E S

New.

S New.

I I

I S

New.

I

4. Job Content Flaws KqT units 7

Back-ward -

7 I 5. Other I 6

SRO UIWS f I

7.

Explanation 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 breathing air.

RESOLUTION: Comment incorporated. Distractor B was changed.

~~

Modified.

S New.

S New.

S New.

S New.

S New.

Tl Bank. In the question stem delete the second and third bulleted (-)

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

I I I I I E l RESOLUTION: Comment incorporated.

S New.

S New.

E S

~~

~~

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.

Bank.

62 63+

64 -

65 -

66+

67 68 69+

7

6.

UIE/S H

7.

Explanation F

E S

E H

H F

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.

Modified. In the question stem change the beginning of the first sentence from The plant was... "to "Unit 1 was...".

RESOLUTION: Comment incorporated.

3

~

3. Psychometric Flaws

~

4. Job Content Flaws
5. Other Job-Minutia Link I X

~~

s IBank. -

NOTE: Question requires reference.

E E

U S

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 reference something 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.

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.

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 considered correct since the procedure itself would have required a 50.59 screening.

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

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

RESOLUTION: Question is Satisfactory. The ROs have a specific Learning Objective to know the Safety Limits from memory.

~

~

~~

4. Job Content Flaws
5. Other
3. Psychometric Flaws 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+ -

74 -

75 2 -

2 -

3 -

2 New. In the question stern change "should" to "are required to" RESOLUTION: Comment incorporated.

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

RESOLUTION: Comment incorporated.

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

RESOLUTION: Comment incorporated.

New.

3 3

3 3 -

New.

Modified. 1) The explanation for distractor C being incorrect is not right.

It states that Pressure and 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.

New.

7.

Explanation New. To increase the 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 information would not assist answering any other question).

NOTE: Question requires reference.

RESOLUTION: Comment incorporated.

Bank.

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

RESOLUTION: Comment incorporated. Revised question so that no references are required.

Bank.

NOTE: Question requires reference.

~~~

~

I N

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 provided as 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.

c 0

m K

m Q

X W

c B

II W

X N

co OD i

??

??

0 C

a

.c m

3 U

c 0

m

.- E

??

c 2

0 W

z z 25 -

v)

-I-o) m N -

I W

X X

In the SRO action to verify recirc pumps and drywell coolers tripped, delete the requirement that this is a Critical Task, since this action is only a verification of an action that should have occurred automatically.

[Comment during onsite validation]

I I

QUAD CITIES MAY 2005 INITIAL LICENSE EXAM OPERATING EXAM COMMENTS Comment I

Resolution Source 1

Scenario No. 1 For Event 2, change the Event Type for the SRO from R to N,

since only the RO can get credit for an R.

Comment incorporated.

Scenario Outline Sheet

2.

Scenario No. 1 Event 5 Page 5 of 10 Add Tech Spec 3.5.1 Conditions F and H as applicable to this event.

[Comment during onsite validation]

Comment incorporated.

3.
4.

Scenario No. 1 Event 8 Page 8 of 10 Add steps required to start the SSMP from the hardcard. [Comment during onsite validation]

Comment incorporated.

Scenario No. 1 Event 8 Page 9 of 10 Comment incorporated.

5.
6.

Scenario No. 2 (Not Validated -

Extra Spare)

Scenario Outline Sheet For Event 6, change the Event Type for the SRO from R to N, since only the RO can get credit for an R.

Comment incorporated.

Scenario No. 2 (Not Validated -

Extra Spare)

Scenario Outline Sheet Need to add to the Turnover that APRM #1 is bypassed (per Summary on next page of scenario).

Comment incorporated.

I

7.
8.
9.

Scenario No. 3 For Event 5, change the Event Type for the SRO from R to IN, since only the RO can get credit for an Fi.

Comment incorporated.

Scenario Outline Sheet

~

~

Scenario No. 3

~

~~

In the Turnover, delete the statement that HPCl is OOS, since if HPCl was 00s it would cause a Tech Spec 3.0.3 entry during Event 1, which is not desirable. [Comment during onsite validation]

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

Comment incorporated.

Scenario Outline Sheet Move Event 2 ( A CRD pump trip) to after the current Event 4, in case the crew decides to scram the Reactor during this event.

[Comment during onsite validation]

Comment incorporated.

Scenario No. 4 (Validated Spare)

Scenario Outline Sheet

QUAD CITIES MAY 2005 INITIAL LICENSE EXAM OPERATING EXAM COMMENTS

10. -
11.
12.
13.
14. -
15. -
16.
17. -
18.
19.

Comment Source Resolution Scenario No. 4 (Validated Spare)

Scenario Outline Sheet For Event 5, change the Event Type as follows:

BOP gets a C RO gets an R SRO gets a C Comment incorporated.

~~~

~

Make the A TBCCW pump trip embedded in Event 5 a separate event (Event 6).

Comment incorporated.

Scenario No. 4 (Validated Spare)

Event 5 Page 6 of 11 Scenario No. 4 (Validated Spare)

Events 7, 8 Page 9 of 11, Page 10 of 11

~~

~~

~

Comment incorporated.

Delete mention of the Lead Examiner (LE) directing the simulator operator to perform certain actions. The examiners can not be involved in the scenario.

Change to have the applicant contact the simulator operator to perform certain actions.

For the SRO/RO actions to report RPV level, delete these as Critical Tasks.

[Comment during onsite validation]

Scenario No. 4 (Validated Spare)

Comment incorporated.

Event 8 Page 10 of 11 Generic Comment for All JPMs Need a Task Standard specified for each JPM per the Examiner Standards, Appendix C, page 3 of 10.

Comment incorporated.

For step D.2.a,b, add: Verifies closed M O 1-2301 -5.

~

~~

~~

~

Comment incorporated.

JPM SYS-c Page 8 of 15 JPM SYS-c Page 12 of 15 Add step F.7.f to verify the Emergency Oil Pump is off.

Comment incorporated.

~~

Comment incorporated.

JPM SYS-c Page 13 of 15 For step F.7.i, add to the Standard:

Pump discharge pressure 5 1250 psig JPM SYS-d Page 8 of 10 For step F.2.h, rewrite the Standard to reflect that the A RHR pump is started approximately 2 seconds after the discharge valve starts to open.

[Comment during onsite validation]

Delete step F.2.k from the JPM, since this step would be performed after the JPM is already complete per the Initiating Cue.

[Comment during onsite validation]

Comment incorporated.

Comment incorporated.

JPM SYS-d Page 8 of 10 Page2of 5

20. -
21. -
22.
23.
24.

7

25.
26. -
27.
28.
29.

QUAD CITIES MAY 2005 INITIAL LICENSE EXAM OPERATING EXAM COMMENTS Source JPM SYS-e Page 6 of 10 JPM SYS-e Paae 6 of 10 Comment Change Site Emergency to Site Area Emergency.

Add to the Initiating Cue that RPS and ESS are energized. [Comment during onsite validation]

Resolution Page 4 of 10 Admin JPM AD-SRO-1 Page 4 of 10 Admin JPM AD-SRO-1 Page 7 of 10 Comment incorporated.

Add procedure QCOA 4100-1 1 as a procedure that is available to the applicant during the administration of the JPM. [Comment during onsite validation]

In the Step column, add an asterisk to show that 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 Step.

Comment incorporated.

Comment incorporated.

Comment incorporated.

JPM SYSf Page 7 of 10 JPM SYS-g Page 7 of 9 JPM SYS-g Page 8 of 9 Can not have the Evaluator asking the simulator operator to request that the speed droop be set to 0.

Need to have the applicant call the simulator operator to have this action completed.

After step F.5, add a CUE that alarm 901 -3 C16 is in alarm, since the applicant would not be able to verify this alarm from the back panel while holding the TRIP CHECK pushbutton in.

[Comment during onsite validation]

This JPM is listed as an Alternate Path on this page.

However, this JPM is not an alternate Path, since 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.

Comment incorporated.

Comment incorporated.

Comment incorporated.

~~

JPM SYS-j Page 4 of 8 JPM SYS-k Page 5 of 7 Change the Initial Conditions as follows:

Add that all control rods are in.

Change Unit Supervisor to Shift Manager to agree with wording in procedure Add that the SBLC tank in not available.

QCOP 1 100-08.

lComments durina onsite validation1 Make the first step to obtain the procedure and equipment to be used a Critical Step.

[Comment during onsite validation]

Comments incorporated.

Comment incorporated.

~

~

Admin JPM AD-S RO-1 Change so that it does not state that the simulator is needed for this JPM?

Comment incorporated.

Page 3 of 5

30. -
31.
32.
33.
34.
35.
36.
37.

QUAD CITIES MAY 2005 INITIAL LICENSE EXAM OPERATING EXAM COMMENTS Source Admin JPM AD-SRO-3 Admin JPM AD-SRO-3 Page 7 of 9 Admin JPM AD-SRO-3 Admin JPM AD-RO-4 Admin JPM AD-SRO-4 Admin JPM AD-RO-4 Page 1 of 10 Admin JPM AD-SRO-4 Admin JPM AD-RO-4 Page 5 of 10 Admin JPM AD-SRO-5 Page 4 of 11 Admin JPM AD-SRO-5 Page 8 of 11 Comment For Equipment Control, replace the JPM titled Review Temporary Change package to Determine if it can be Accepted for Operation, and replace with JPM titled 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.]

To provide more flexibility for the applicant, change so that the Critical Step is to EITHER add the Control Switch OR the breaker and control power fuses to the Abnormal Component Position Sheet.

[Comment during onsite validation]

In the OP-AA-108-101, Attachment 2, Abnormal Component Position Sheet, change so that valve 2-1 099-96 is listed as Uncapped and open instead of valve 2-1 099-100A (since only valve 2-1099-96 has a cap adjacent to it).

Is this JPM task (developing a Pre-Job briefing for NLOs and selecting NLOs to perform a radiation area related task) part of the job of an RO?

Change the title of the JPM to Select Personnel for Radiation Work to better reflect the task of the JPM.

[Comment during onsite validation]

Change the Initiating Cue so that the task is to calculate the expected dose for the job, determine who and who can not perform the job, and why a person can or can not perform the job. Add Critical Steps to determine the expected dose for the job, and the reasons why each applicable person can not 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.]

Add procedure EP-MW-114-100 as a procedure that is available to the applicant during the administration of the JPM. [Comment during onsite validation]

Change to make it a Critical Step to identify the correct EAL number.

Resol ut ion JPM replaced with a new one that satisfies the same WA (WA 2.2.1 1).

Comment incorporated.

Comment incorporated.

On 4/6/05 verified with site that this JPM is part of the job for an RO.

Comment incorporated.

~

~

~~

Comment incorporated.

Comment incorporated.

Comment incorporated.

Page4of 5

38. -
39.
40.
41.
42.
43.
44.
45.
46.

Comment Resolution I

I I

I I

I Comment incorporated.

QUAD CITIES MAY 2005 INITIAL LICENSE EXAM OPERATING EXAM COMMENTS Source

~~~

Admin JPM AD-RO-1 Page 8 of 11

~

~

Change to make step D.5.f a Critical Step to make a plant announcement to assemble the Fire Brigade.

Comment incorporated.

Admin JPM AD-RO-1 Page 8 of 1 1 In the CUE near the top of the page, change SECURITY Modules to EMERGENCY Modules

[Comment during onsite validation]

Comment incorporated.

Admin JPM AD-RO-1 Pacre 8 of 11 Comment incorporated.

Change so that the applicant can use EITHER the plant radio or the APB-1 key to transmit the messages for steps D.5.f and D.5.f (1).

[Comment during onsite validation]

In Step H.l.a, have an offsite power line 00s but such that there are still 2 other offsite power lines available (e.g., have line 0403 00s).

Admin JPM AD-RO-2 Comment incorporated.

Page 6 of 12 Admin JPM AD-RO-2 For Steps H.l.l.(l) and H.l.l.(3), change the CUE to just say that this step is not met.

[Comment during onsite validation]

Comment incorporated.

Page 8 of 12 Admin JPM AD-RO-2 Page 9 of 12 In Step H.3.b, have the NLO return Attachment D with all steps signed off, but with a comment that would result in an Acceptance Criteria not being met. Make this step a Critical Step.

Comment incorporated.

Admin JPM AD-RO-2 Page 9 of 12 In Step H.3.b, change Attachment D to Attachment D and E. [Comment during onsite validation]

Comment incorporated.

~

Change Step H.5 to a Critical Step, with the critical being to identify that 1) Transformer 12 feed to Bus 14 is not available, and 2) to identify the deficiency inserted into Attachment D performed by the local operator.

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

Admin JPM AD-RO-2 Page 10 of 12 Admin JPM AD-RO-3 Add print M - 43 to the list of prints available to the applicant. [Comment during onsite validation]

I 1

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