ML14274A260
ML14274A260 | |
Person / Time | |
---|---|
Site: | Cook |
Issue date: | 08/01/2014 |
From: | Mcneil D NRC/RGN-III/DRS/OLB |
To: | Indiana Michigan Power Co |
Shared Package | |
ML14218A305 | List: |
References | |
Download: ML14274A260 (11) | |
Text
ES-401 PWR Examination Outline Form ES-401-2 Facility: D.C. Cook U1/U2 Date of Exam: July 21 - August 1, 2014 RO K/A Category Points SRO-Only Points Tier Group K K K K K K A A A A G A2 G* Total 1 2 3 4 5 6 1 2 3 4
- Total
- 1. 1 3 3 4 2 3 3 18 3 3 6 Emergency &
Abnormal 2 2 2 1 N/A 1 1 N/A 2 9 2 2 4 Plant Evolutions Tier Totals 5 5 5 3 4 5 27 5 5 10 1 3 2 3 3 1 1 3 3 3 4 2 28 2 3 5 2.
Plant 2 1 1 1 1 1 1 1 0 1 1 1 10 2 1 3 Systems Tier Totals 4 3 4 4 2 2 4 3 4 5 3 38 4 4 8
- 3. Generic Knowledge and Abilities 1 2 3 4 1 2 3 4 Categories 10 7 2 3 3 2 2 2 1 2 Note: 1. Ensure that at least two topics from every applicable K/A category are sampled within each tier of the RO and SRO-only outlines (i.e., except for one category in Tier 3 of the SRO-only outline, the Tier Totals in each K/A category shall not be less than two).
- 2. The point total for each group and tier in the proposed outline must match that specified in the table.
The final point total for each group and tier may deviate by +/-1 from that specified in the table based on NRC revisions.
The final RO exam must total 75 points and the SRO-only exam must total 25 points.
- 3. Systems/evolutions within each group are identified on the associated outline; systems or evolutions that do not apply at the facility should be deleted and justified; operationally important, site-specific systems/evolutions that are not included on the outline should be added. Refer to Section D.1.b of ES-401 for guidance regarding the elimination of inappropriate K/A statements.
- 4. Select topics from as many systems and evolutions as possible; sample every system or evolution in the group before selecting a second topic for any system or evolution.
- 5. Absent a plant-specific priority, only those K/As having an importance rating (IR) of 2.5 or higher shall be selected.
Use the RO and SRO ratings for the RO and SRO-only portions, respectively.
- 6. Select SRO topics for Tiers 1 and 2 from the shaded systems and K/A categories.
7.* The generic (G) K/As in Tiers 1 and 2 shall be selected from Section 2 of the K/A Catalog, but the topics must be relevant to the applicable evolution or system. Refer to Section D.1.b of ES-401 for the applicable K/As.
- 8. On the following pages, enter the K/A numbers, a brief description of each topic, the topics importance ratings (IRs) for the applicable license level, and the point totals (#) for each system and category. Enter the group and tier totals for each category in the table above; if fuel handling equipment is sampled in other than Category A2 or G* on the SRO-only exam, enter it on the left side of Column A2 for Tier 2, Group 2 (Note #1 does not apply). Use duplicate pages for RO and SRO-only exams.
- 9. For Tier 3, select topics from Section 2 of the K/A catalog, and enter the K/A numbers, descriptions, IRs, and point totals (#) on Form ES-401-3. Limit SRO selections to K/As that are linked to 10 CFR 55.43.
ES-401 PWR Examination Outline Form ES-401-2 Emergency and Abnormal Plant Evolutions - Tier 1/Group 1 (RO / SRO)
E/APE # / Name / Safety Function K K K A A K/A Topic(s) IR #
G 1 2 3 1 2 RO - Knowledge of the interrelations between a 000007 (BW/E02&E10; CE/E02) Reactor 0 reactor trip and the following: Breakers, relays and 2.6 1 Trip - Stabilization - Recovery / 1 2 disconnects.
RO - Knowledge of the reasons for the following 000008 Pressurizer Vapor Space 0 responses as they apply to the Pressurizer Vapor 4.1 2 Accident / 3 3 Space Accident: Actions contained in EOP for PZR vapor space accident / LOCA SRO - A2.10: Ability to determine or interpret the 000009 Small Break LOCA / 3 S following as they apply to a small break LOCA: 3.7 76 Airborne activity RO - Ability to determine or interpret the following as 0
000011 Large Break LOCA / 3 they apply to a Large Break LOCA: Significance of 3.3 3 5
charging pump operation RO - 2.1.23 Ability to perform specific system and 000015/17 RCP Malfunctions / 4 R integrated plant procedures during all modes of 3.8 4 plant operation.
SRO - 2.1.7 Ability to evaluate plant performance and make operational judgments based on 000022 Loss of Rx Coolant Makeup / 2 S operating characteristics, reactor behavior, and 4.7 77 instrument interpretation.
RO - Knowledge of the operational implications of 0 the following concepts as they apply to Loss of 000025 Loss of RHR System / 4 Residual Heat Removal System: LPI or Decay Heat 3.2 5 2
Removal/RHR pumps RO - Knowledge of the reasons for the following 000026 Loss of Component Cooling 0 responses as they apply to the Loss of Component Cooling Water: Guidance actions contained in EOP 4.0 6 Water / 8 3 for Loss of CCW RO - Ability to operate and / or monitor the following as they apply to the Pressurizer Pressure Control Malfunctions: Pressure recovery, using emergency-only heaters 3.9 7 000027 Pressurizer Pressure Control 0 S
System Malfunction / 3 1 SRO - A2.04 Ability to determine and interpret the following as they apply to the Pressurizer Pressure 3.7 78 Control Malfunctions: Tech-Spec limits for RCS pressure RO - Ability to determine or interpret the following as 0
000029 ATWS / 1 they apply to a ATWS: System component valve 3.4 8 5
position indications RO - 2.2.38: Knowledge of conditions and 000038 Steam Gen. Tube Rupture / 3 R 3.6 9 limitations in the facility license..
000040 (BW/E05; CE/E05; W/E12) 0 SRO - Steam line rupture excessive heat transfer:
Steam Line Rupture - Excessive Heat 4.2 79 4 Actions contained in EOPs for steam line rupture.
Transfer / 4 RO - Knowledge of the operational implications of the following concepts as they apply to Loss of 000054 (CE/E06) Loss of Main 0 Main Feedwater (MFW): MFW line break 4.1 10 Feedwater / 4 1 depressurizes the S/G (similar to a steam line break)
RO - Knowledge of the operational implications of 0 the following concepts as they apply to the Station 000055 Station Blackout / 6 4.1 11 2 Blackout: Natural circulation cooling RO - Knowledge of the reasons for the following 0 responses as they apply to the Loss of Offsite 000056 Loss of Off-site Power / 6 Power: Actions contained in EOP for loss of offsite 4.4 12 2
power
ES-401 PWR Examination Outline Form ES-401-2 Emergency and Abnormal Plant Evolutions - Tier 1/Group 1 (RO / SRO)
E/APE # / Name / Safety Function K K K A A K/A Topic(s) IR #
G 1 2 3 1 2 SRO - 2.2.40 Loss of Vital AC Instrument Bus:
000057 Loss of Vital AC Inst. Bus / 6 S Ability to apply Technical Specifications for a system 3.6 80 RO - Ability to operate and / or monitor the following 0 as they apply to the Loss of DC Power: Vital and 000058 Loss of DC Power / 6 3.1 13 3 battery bus components RO - Ability to determine and interpret the following 0 as they apply to the Loss of Nuclear Service Water:
000062 Loss of Nuclear Svc Water / 4 The normal values and upper limits for the 2.5 14 4
temperatures of the components cooled by SWS RO - 2.4.31: Knowledge of annunciator alarms, 000065 Loss of Instrument Air / 8 R indications, or response procedures. 4.2 15 SRO - 2.1.30 Ability to locate and operate W/E04 LOCA Outside Containment / 3 S 4.0 81 components, including local controls.
W/E11 Loss of Emergency Coolant RO - Components, capacity, and function of 1 3.7 16 Recirc. / 4 emergency systems.
RO - Knowledge of the interrelations between the (Loss of Secondary Heat Sink) and the following:
Facilitys heat removal systems, including primary BW/E04; W/E05 Inadequate Heat 2 coolant, emergency coolant, the decay heat removal 3.9 17 Transfer - Loss of Secondary Heat Sink / 4 systems, and relations between the proper operation of these systems to the operation of the facility.
RO - Knowledge of the reasons for the following 000077 Generator Voltage and Electric responses as they apply to Generator Voltage and 1 Electric Grid Disturbances: Reactor and turbine trip 3.9 18 Grid Disturbances / 6 criteria K/A Category Totals: Group Point Total: 18 3 3 3 3 4 2 / / /
2 4 6
ES-401 PWR Examination Outline Form ES-401-2 Emergency and Abnormal Plant Evolutions - Tier 1/Group 2 (RO / SRO)
E/APE # / Name / Safety Function K K K A A K/A Topic(s) IR #
G 1 2 3 1 2 SRO - A2.12 Ability to (a) predict the impacts of the following malfunction or operations on the CRDS- and (b) based on 000001 Continuous Rod Withdrawal / 1 S those predictions, use procedures to correct, 3.6 82 control, or mitigate the consequences of those malfunctions or operations:
Erroneous ECP calculation RO - 2.1.27 Knowledge of system purpose 000003 Dropped Control Rod / 1 R 3.9 19 and/or function.
000005 Inoperable/Stuck Control Rod / 1 RO - Knowledge of the operational 0 implications of the following concepts as 000024 Emergency Boration / 1 they apply to Emergency Boration: Low 2.8 20 4
temperature limits for boron concentration 000028 Pressurizer Level Malfunction / 2 RO - Knowledge of the interrelations 0 between the Loss of Source Range Nuclear 000032 Loss of Source Range NI / 7 Instrumentation and the following: Power 2.7 21 1
supplies, including proper switch positions 000033 Loss of Intermediate Range NI / 7 SRO - 2.2.25 Fuel Handling Accident:
Knowledge of the bases in Technical 000036 (BW/A08) Fuel Handling Accident / 8 S 3.6 83 Specification for limiting conditions for operators and safety limits 000037 Steam Generator Tube Leak / 3 RO - Knowledge of the reasons for the following responses as they apply to the 0 Loss of Condenser Vacuum: Loss of steam 000051 Loss of Condenser Vacuum / 4 2.8 22 1 dump capability upon loss of condenser vacuum 000059 Accidental Liquid RadWaste Rel. / 9 RO - Ability to operate and / or monitor the 0 following as they apply to the Accidental 000060 Accidental Gaseous Radwaste Rel. / 9 2.9 23 2 Gaseous Radwaste: Ventilation system 000061 ARM System Alarms / 7 RO - Ability to determine and interpret the 1 following as they apply to the Plant Fire on 000067 Plant Fire On-site / 8 Site: Equipment that will be affected by fire 3.2 24 4
suppression activities in each zone 000068 (BW/A06) Control Room Evac. / 8 SRO - A2.02 Ability to determine and interpret the following as they apply to the 000069 (W/E14) Loss of CTMT Integrity / 5 S Loss of Containment Integrity: Verification 84 of automatic and manual means of restoring integrity 000074 (W/E06&E07) Inad. Core Cooling / 4 RO - 2.2.7 Knowledge of the process for 000076 High Reactor Coolant Activity / 9 R 2.9 25 conducting special or infrequent tests.
W/E01 & E02 Rediagnosis & SI Termination / 3 RO - Knowledge of the operational implications of the following concepts as W/E13 Steam Generator Over-pressure / 4 1 they apply to the (Steam Generator 3.2 26 Overpressure): Components, capacity, and function of emergency systems.
W/E15 Containment Flooding / 5
ES-401 PWR Examination Outline Form ES-401-2 Emergency and Abnormal Plant Evolutions - Tier 1/Group 2 (RO / SRO)
E/APE # / Name / Safety Function K K K A A K/A Topic(s) IR #
G 1 2 3 1 2 RO - Knowledge of the interrelations between the (High Containment Radiation) and the following: Components, and W/E16 High Containment Radiation / 9 1 functions of control and safety systems, 3.0 27 including instrumentation, signals, interlocks, failure modes, and automatic and manual features.
BW/A01 Plant Runback / 1 BW/A02&A03 Loss of NNI-X/Y / 7 BW/A04 Turbine Trip / 4 BW/A05 Emergency Diesel Actuation / 6 BW/A07 Flooding / 8 BW/E03 Inadequate Subcooling Margin / 4 BW/E08; W/E03 LOCA Cooldown - Depress. / 4 BW/E09; CE/A13; W/E09&E10 Natural Circ. / 4 BW/E13&E14 EOP Rules and Enclosures SRO -2.2.38: RCS Overcooling - PTS:
CE/A11; W/E08 RCS Overcooling - PTS / 4 S Knowledge of conditions and limitations in 4.4 85 the facility license CE/A16 Excess RCS Leakage / 2 CE/E09 Functional Recovery K/A Category Point Totals: 1 2 Group Point Total: 9/4 2 2 1 1 / /
2 2
ES-401 PWR Examination Outline Form ES-401-2 Plant Systems - Tier 2/Group 1 (RO / SRO)
System # / Name K K K K K K A A A A G K/A Topic(s) IR #
1 2 3 4 5 6 1 2 3 4 RO - Knowledge of the operational implications of the following concepts as they apply to the RCPS: The relationship between the RCPS flow rate 0 and the nuclear reactor core operating 003 Reactor Coolant Pump 3.3 28 1 parameters (quadrant power tilt, imbalance, DNB rate, local power density, difference in loop T-hot pressure)
RO - Knowledge of the effect of a loss or malfunction on the following CVCS 4.4 29 components: Flow paths for emergency boration 004 Chemical and Volume 1 SRO - A2.12 - Ability to (a) predict the S impacts of the following malfunctions or Control 7 4.3 86 operations on the CVCS; and (b) based on those predictions, use procedures to correct, control, or mitigate the consequences of those malfunctions or operations: CIAS, SIAS RO - Ability to predict and/or monitor changes in parameters (to prevent 3.5 30 exceeding design limits) associated with operating the RHRS controls including:
Heatup/cooldown rates 0 0 RO - Ability to (a) predict the impacts of 005 Residual Heat Removal the following malfunctions or operations 1 3 on the RHRS, and (b) based on those predictions, use procedures to correct, 3.5 31 control, or mitigate the consequences of those malfunctions or operations:
Pressure transient protection during cold shutdown RO - Ability to monitor automatic 4.2 32 operation of the ECCS, including:
Automatic transfer of ECCS flowpaths 0
006 Emergency Core Cooling S SRO - 2.1.32 - Emergency Core 4.2 87 8
Cooling: Ability to explain and apply system limits and precautions.
RO - Ability to manually operate and/or 007 Pressurizer Relief/Quench 1 monitorin the control room: Recognition 3.6 33 Tank 0 of leaking PORV/code safety RO - Knowledge of the physical 2.9 34 connections and/or cause-effect relationships between the CCWS and the following systems: Loads cooled by 0 CCWS 008 Component Cooling Water R 2 RO - 2.4.4 Ability to recognize abnormal indications for system operating parameters that are entry-level 4.5 35 conditions for emergency and abnormal operating procedures.
0 RO - Knowledge of bus power supplies 010 Pressurizer Pressure Control 3.0 36 1 to the following: PZR heaters
ES-401 PWR Examination Outline Form ES-401-2 Plant Systems - Tier 2/Group 1 (RO / SRO)
System # / Name K K K K K K A A A A G K/A Topic(s) IR #
1 2 3 4 5 6 1 2 3 4 RO - Knowledge of the effect that a loss or 0 malfunction of the RPS will have on the 012 Reactor Protection 3.2 37 2 following: T/G RO - Knowledge of ESFAS design feature(s) and/or inter-lock(s) which provide for the following: Auxiliary feed 4.3 38 013 Engineered Safety Features 0 actuation signal S
Actuation 4 SRO - 2.1.32 Ability to explain and 4.0 88 apply system limits and precautions.
RO - Ability to predict and/or monitor changes in parameters (to prevent exceeding design limits) associated with 3.1 39 operating the CCS controls including:
0 0 Cooling Water flow 022 Containment Cooling 4 5 RO - Ability to manually operate and/or monitor in the control room:
Containment readings of temperature, 3.8 40 pressure, and humidity system RO - Ability to (a) predict the impacts of the following malfunctions or operations 0 on the ice condenser system; correct, 025 Ice Condenser control, or mitigate the consequences of 3.0 41 4
those malfunctions or operations:
Containment isolation RO - Ability to monitor automatic 0 operation of the CSS, including:
026 Containment Spray Verification that cooling water is supplied 3.9 42 2
to the containment spray heat exchanger RO -Ability to manually operate and/or 0 monitor in the control room: Emergency 039 Main and Reheat Steam 3.8 43 4 feedwater pump turbines RO - Knowledge of the physical connections and/or cause-effect 3.4 44 relationships between the MFW and the following systems: AFW system 0
059 Main Feedwater R 2
RO - 2.4.20 Knowledge of the 3.8 45 operational implications of EOP warnings, cautions, and notes..
061 Auxiliary/Emergency 0 RO - Knowledge of bus power supplies 3.2 46 Feedwater 1 to the following: AFW System MOVs RO - Knowledge of the effect that a loss 0 or malfunction of the ac distribution 062 AC Electrical Distribution 4.1 47 2 system will have on the following: ED/G RO - Knowledge of DC electrical system design feature(s) and/or interlock(s) 2.9 48 which provide for the following: Breaker interlocks, permissives, bypasses and cross-ties SRO - A2.02 Ability to (a) predict the 3.1 89 0
063 DC Electrical Distribution S impacts of the following malfunctions or 2
operations on the DC electrical systems; and (b) based on those predictions, use procedures to correct, control, or mitigate the consequences of those malfunctions or operations: Loss of ventilation during battery charging
ES-401 PWR Examination Outline Form ES-401-2 Plant Systems - Tier 2/Group 1 (RO / SRO)
System # / Name K K K K K K A A A A G K/A Topic(s) IR #
1 2 3 4 5 6 1 2 3 4 RO - Knowledge of ED/G system design feature(s) and/or inter-lock(s) which 3.5 49 provide for the following: Automatic load sequencer: safeguards 1 0 RO - Ability to predict and/or monitor 064 Emergency Diesel Generator 1 3 changes in parameters (to prevent 3.2 50 exceeding design limits) associated with operating the ED/G system controls including: Operating voltages, currents, and temperatures RO - Ability to manually operate and/or 073 Process Radiation 0 monitor in the control room: Effluent 3.9 51 Monitoring 1 release RO - Ability to (a) predict the impacts of the following mal-functions or operations on the SWS; and (b) based on those 0 predictions, use procedures to correct, 076 Service Water 3.5 52 1 control, or mitigate the consequences of those malfunctions or operations: Loss of SWS RO - Ability to monitor automatic 0
078 Instrument Air operation of the IAS, including: Air 3.1 53 1
Pressure RO - Knowledge of the physical connections and/or cause-effect relationships between the containment 54 system and the following systems: 3.9 Containment isolation/containment integrity 0 0 RO - Knowledge of the effect that a loss 103 Containment S 2 2 or malfunction of the containment 55 system will have on the following: Loss 3.8 of containment integrity under normal operations SRO - 2.2.22 - Containment: 4.7 Knowledge of limiting conditions for 90 operations and safety limits K/A Category Point Totals: 3 2 3 3 1 1 3 3 3 4 2 Group Point Total: 28/
/ / 5 2 3
ES-401 PWR Examination Outline Form ES-401-2 Plant Systems - Tier 2/Group 2 (RO / SRO)
System # / Name K K K K K K A A A A G K/A Topic(s) IR #
1 2 3 4 5 6 1 2 3 4 RO: Knowledge of CRDS design feature(s) 2 and/or interlock(s) which provide for the 001 Control Rod Drive 3.4 56 3 following: Rod motion inhibit 002 Reactor Coolant 0 RO - Knowledge of bus power supplies to 011 Pressurizer Level Control the following: Charging pumps 3.1 57 1
SRO A2.05 - Ability to (a) predict the impacts of the following malfunctions or operations on the RPIS; and (b) based on 014 Rod Position Indication S those on those predictions, use procedures 4.1 91 to correct, control, or mitigate the consequences of those malfunctions or operations: Reactor Trip RO - Knowledge of the effect of a loss or 0 malfunction on the following will have on 015 Nuclear Instrumentation 3.1 58 4 the NIS: Bistables and logic circuits 016 Non-nuclear Instrumentation RO - Ability to predict and/or monitor changes in parameters (to prevent 0 exceeding design limits) associated with 017 In-core Temperature Monitor 3.7 59 1 operating the ITM system controls including: Core exit temperature 027 Containment Iodine Removal 028 Hydrogen Recombiner and Purge Control RO - Ability to monitor automatic operation 0 of the Containment Purge System 029 Containment Purge 3.8 60 1 including: CPS isolation SRO - 2.4.41: Knowledge of the 033 Spent Fuel Pool Cooling S emergency action level thresholds and 4.6 92 classifications.
034 Fuel Handling Equipment RO - Ability to manually operate and/or 0 monitor in the control room: S/G isolation 035 Steam Generator 4.5 61 6 on steam leak or tube rupture/leak 041 Steam Dump/Turbine Bypass Control RO - 2.1.7 Ability to evaluate plant performance and make operational 045 Main Turbine Generator R judgments based on operating 4.4 62 characteristics, reactor behavior, and instrument interpretation.
055 Condenser Air Removal 056 Condensate SRO - A2.04 Ability to (a) predict the impacts of the following malfunctions or operations on the Liquid Radwaste System; 068 Liquid Radwaste S and (b) based on those predictions, use 3.3 93 procedures to correct, control, or mitigate the consequences of those malfunctions or operations: Failure of automatic isolation 071 Waste Gas Disposal
ES-401 PWR Examination Outline Form ES-401-2 Plant Systems - Tier 2/Group 2 (RO / SRO)
System # / Name K K K K K K A A A A G K/A Topic(s) IR #
1 2 3 4 5 6 1 2 3 4 RO - Knowledge of the effect that a loss or 0 malfunction of the ARM system will have 072 Area Radiation Monitoring on the following: Containment ventilation 3.2 63 1
isolation 075 Circulating Water RO - Knowledge of the physical 079 Station Air connections and/or cause-effect 0
relationships between the SAS and the 3.0 64 1
following systems: IAS RO - Knowledge of the operational 086 Fire Protection implication of the following concepts as 0 theyapply to the Fire Protection System: 3.1 65 3 Effect of water spray on electrical components K/A Category Point Totals: 0 1 Group Point Total: 10/
1 1 1 1 1 1 1 / 1 1 / 3 2 1
ES-401 Generic Knowledge and Abilities Outline (Tier 3) Form ES-401-3 Facility: DC Cook U1/U2 Date of Exam: 08/01/2014 Category K/A # Topic RO SRO-Only IR # IR #
2.1.1 Knowledge of conduct of operations requirements. 3.8 66 2.1.4 Knowledge of individual licensed operator responsibilities related 3.8 94
- 1. to shift staffing, such as medical requirements, no-solo Conduct operation, maintenance of active license status, 10CFR55, etc.
of Operations Ability to use procedures related to shift staffing, such as 2.1.5 minimum crew complement, overtime limitations, etc. 3.9 95 Ability to use plant computers to evaluate system or component 2.1.19 status. 3.9 67 Subtotal 2 2 2.2.2 Ability to manipulate the console controls as required to operate 4.6 68 the facility between shutdown and designated power levels.
2.2.12 Knowledge of surveillance procedures. 3.7 69 2.
Equipment 2.2.22 Knowledge of limiting conditions for operations and safety limits. 4.0 70 Control 2.2.36 Ability to analyze the effect of maintenance activities, such as 4.2 96 degraded power sources, on the status of limiting conditions for operations.
2.2.40 Ability to apply Technical Specifications for a system. 4.7 97 Subtotal 3 2 2.3.4 Knowledge of radiation exposure limits under normal or 3.2 71 emergency conditions.
Ability to use radiation monitoring systems, such as fixed 2.3.5 radiation monitors and alarms, portable survey instruments, 2.9 72 3 3.
personnel monitoring equipment, etc.
Radiation Control 2.3.6 Ability to approve release permits. 3.8 98 Knowledge of radiological safety principles pertaining to licensed 2.3.12 operator duties, such as containment entry requirements, fuel 3.2 73 handling responsibilities, access to locked high-radiation areas, aligning filters, etc.
Subtotal 3 1 2.4.1 Knowledge of EOP entry conditions and immediate action steps. 4.6 74 2.4.6 Knowledge of EOP mitigation strategies. 4.7 99 4.
Emergency 2.4.38 Ability to take actions called for in the facility emergency plan, 4.4 100 Procedures / including supporting or acting as emergency coordinator if Plan required.
2.4.49 Ability to perform without reference to procedures those actions 4.6 75 that require immediate operation of system components and controls.
Subtotal 2 2 Tier 3 Point Total 10 7