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