ML15231A841

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2015 Davis-Besse Nuclear Power Station Initial License Examination ES-401-2&3 RO Written Outline
ML15231A841
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 03/06/2015
From:
NRC/RGN-III
To:
FirstEnergy Nuclear Operating Co
Reeser D
Shared Package
ML15217A099 List:
References
Download: ML15231A841 (9)


Text

ES-401 PWR Examination Outline Form ES-401-2 Facility: Davis-Besse RO Date of Exam 6/15 thru 6/26 2015 RO K/A Category Points SRO ONLY Points Tier Group K K K K K K A A A A G TOTAL A2 G* TOTAL 1 2 3 4 5 6 1 2 3 4

  • 1 3 3 3 3 3 3 18 1.

Emergency 2

& 2 2 1 2 1 1 9 Abnormal Plant Tier Totals 5 5 4 5 4 4 27 Evolutions 1

2.

2 2 3 3 3 2 2 3 2 3 3 28 Plant Systems 2 1 1 1 1 1 1 1 0 1 1 1 10 Tier Totals 3 3 4 4 4 3 3 3 3 4 4 38 1 2 3 4 1 2 3 4

3. Generic Knowledge and Abilities 10 Category 2 3 3 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.

NUREG-1021, Revision 9 Supplement 1 RO Page 1 of 9 FENOC Facsimile Rev. 1

ES-401 PWR Examination Outline Form ES-401-2 Davis-Besse 6/2015 Emergency and Abnormal Plant Evolutions - Tier 1/Group 1(RO)

E/APE # / Name / Safety Function K K K A A G K/A Topic(s) IR Points 1 2 3 1 2 000007 Reactor Trip 2.1.28 Knowledge of the purpose and function of 4.1 Question 1 X major system components and controls.

1 (CFR: 41.7) 000008 Pressurizer (PZR) Vapor Space AK2.02 Knowledge of the interrelations between 2.7*

Accident X the Pressurizer Vapor Space Accident and the 1 Question 2 following: Sensors and detectors (CFR 41.7 / 45.7) 000009 Small Break LOCA 2.2.39 Knowledge of less than or equal to one hour 3.9 Question 3 X Technical Specification action statements for 1

systems.

(CFR: 41.7 / 41.10 / 43.2 / 45.13) 000011 Large Break LOCA EK3.15 Knowledge of the reasons for the following 4.3 Question 4 X responses as the apply to the Large Break LOCA: 1 Criteria for shifting to recirculation mode (CFR 41.5 / 41.10 / 45.6 / 45.13) 000015/000017 Reactor Coolant Pump AK1.02 Knowledge of the operational implications 3.7 (RCP) Malfunctions X of the following concepts as they apply to Reactor 1 Question 5 Coolant Pump Malfunctions (Loss of RC Flow):

Consequences of an RCPS failure (CFR 41.8 / 41.10 / 45.3) 000026 Loss of Component Cooling Water AA1.02 Ability to operate and / or monitor the 3.2 (CCW) X following as they apply to the Loss of Component 1

Question 6 Cooling Water: Loads on the CCWS in the control room (CFR 41.7 / 45.5 / 45.6)

EK2.06 Knowledge of the interrelations between 000029 Anticipated Transient Without X the following and an ATWS: Breakers, relays, and 2.9* 1 Scram (ATWS)

Question 7 disconnects (CFR 41.7 / 45.7)

EK3.08 Knowledge of the reasons for the following 000038 Steam Generator Tube Rupture X responses as the apply to the SGTR: Criteria for 4.1 1 (SGTR)

Question 8 securing RCP (CFR 41.5 / 41.10 / 45.6 / 45.13) 000054 Loss of Main Feedwater (MFW) AA1.01 Ability to operate and / or monitor the 4.5 Question 9 X following as they apply to the Loss of Main 1 Feedwater (MFW): AFW controls, including the use of alternate AFW sources (CFR 41.7 / 45.5 / 45.6) 000055 Loss of Offsite and Onsite Power EK1.01 Knowledge of the operational implications 3.3 (Station Blackout) X of the following concepts as 1 Question 10 they apply to the Station Blackout : Effect of battery discharge rates on capacity (CFR 41.8 / 41.10 / 45.3) 000056 Loss of Offsite Power AA2.57 Ability to determine and interpret the 3.9 Question 11 X following as they apply to the Loss of Offsite Power: 1 RCS hot-leg and cold-leg temperatures (CFR: 43.5 / 45.13) 000057 Loss of Vital AC Electrical AA1.01 Ability to operate and / or monitor the 3.7*

Instrument Bus X following as they apply to the Loss of Vital AC 1 Question 12 Instrument Bus: Manual inverter swapping (CFR 41.7 / 45.5 / 45.6)

NUREG-1021, Revision 9 Supplement 1 RO Page 2 of 9 FENOC Facsimile Rev. 1

ES-401 PWR Examination Outline Form ES-401-2 Davis-Besse 6/2015 Emergency and Abnormal Plant Evolutions - Tier 1/Group 1(RO) Continued E/APE # / Name / Safety Function K K K A A G K/A Topic(s) IR Points 1 2 3 1 2 000058 Loss of DC Power AK1.01 Knowledge of the operational implications 2.8 Question 13 X of the following concepts as they apply to Loss of 1 DC Power: Battery charger equipment and instrumentation (CFR 41.8 / 41.10 / 45.3) 000062 Loss of Nuclear Service Water AA2.03 Ability to determine and interpret the 2.6 Question 14 X following as they apply to the Loss of Nuclear 1 Service Water: The valve lineups necessary to restart the SWS while bypassing the portion of the system causing the abnormal condition (CFR: 43.5 / 45.13) 000065 Loss of Instrument Air AA2.07 Ability to determine and interpret the 2.8*

Question 15 X following as they apply to the Loss of Instrument 1 Air: Whether backup nitrogen supply is controlling valve position (CFR: 43.5 / 45.13) 000077 Generator Voltage and Electric Grid AK2.07 Knowledge of the interrelations between 3.6 Disturbances X Generator Voltage and Electric Grid Disturbances 1 Question 16 and the following: Turbine / generator control (CFR: 41.4, 41.5, 41.7, 41.10 / 45.8)

BW/E04 Inadequate Heat Transfer - Loss 2.2.44 Ability to interpret control room indications to 4.2 Of Secondary Heat Sink X verify the status and operation of a system, and 1

Question 17 understand how operator actions and directives affect plant and system conditions.

(CFR: 41.5 / 43.5 / 45.12)

BW/E05 Steam Line Rupture - Excessive EK3.4 Knowledge of the reasons for the following 3.8 Heat Transfer X responses as they apply to the (Excessive Heat 1 Question 18 Transfer):

RO or SRO function within the control room team as appropriate to the assigned position, in such a way that procedures are adhered to and the limitations in the facilities license and amendments are not violated.

(CFR: 41.5 / 41.10, 45.6, 45.13)

K/A Category Point Totals: 3 3 3 3 3 3 Group Point Total: 18 NUREG-1021, Revision 9 Supplement 1 RO Page 3 of 9 FENOC Facsimile Rev. 1

ES-401 PWR Examination Outline Form ES-401-2 Davis-Besse 6/2015 Emergency and Abnormal Plant Evolutions - Tier 1/Group 2(RO)

E/APE # / Name / Safety Function K K K A A G K/A Topic(s) IR Points 1 2 3 1 2 000005 Inoperable/Stuck Control Rod AA1.04 Ability to operate and / or monitor the 3.9 X following as they apply to the Inoperable / Stuck 1 Question 19 Control Rod: Reactor and turbine power (CFR 41.7 / 45.5 / 45.6) 000028 Pressurizer (PZR) Level Control AK1.01 Knowledge of the operational implications 2.8*

Malfunction X of the following concepts as 1 they apply to Pressurizer Level Control Question 20 Malfunctions: PZR reference leak abnormalities (CFR 41.8 / 41.10 / 45.3) 000032 Loss of Source Range Nuclear AK2.01 Knowledge of the interrelations between 2.7*

Instrumentation X the Loss of Source Range Nuclear Instrumentation 1 and the following: Power supplies, including proper Question 21 switch positions (CFR 41.7 / 45.7) 000069 Loss of Containment Integrity AK1.01 Knowledge of the operational implications 2.6 X of the following concepts as they apply to Loss of 1 Question 22 Containment Integrity: Effect of pressure on leak rate (CFR 41.8 / 41.10 / 45.3) 000076 High Reactor Coolant Activity AA1.04 Ability to operate and / or monitor the 3.2 X following as they apply to the High Reactor Coolant 1 Question 23 Activity: Failed fuel-monitoring equipment (CFR 41.7 / 45.5 / 45.6)

BW/A01 Plant Runback AK2.1 Knowledge of the interrelations between the 3.7 X (Plant Runback) and the following: Components, 1 Question 24 and functions of control and safety systems, including instrumentation, signals, interlocks, failure modes, and automatic and manual features.

(CFR: 41.7 / 45.7)

BW/A07 Flooding AA2.1 Ability to determine and interpret the 3.0 X following as they apply to the (Flooding): Facility 1 Question 25 conditions and selection of appropriate procedures during abnormal and emergency operations (CFR: 43.5 / 45.13)

BW/E09 Natural Circulation Cooldown EK3.3 Knowledge of the reasons for the following 3.8 X responses as they apply to the (Natural Circulation 1 Question 26 Cooldown): Manipulation of controls required to obtain desired operating results during abnormal, and emergency situations (CFR: 41.5 / 41.10, 45.6, 45.13)

BW/E13 EOP Rules 2.4.45 Ability to prioritize and interpret the 4.1 X significance of each annunciator or alarm 1 Question 27 (CFR: 41.10 / 43.5 / 45.3 / 45.12)

K/A Category Point Totals: 2 2 1 2 1 1 Group Point Total: 9 NUREG-1021, Revision 9 Supplement 1 RO Page 4 of 9 FENOC Facsimile Rev. 1

ES-401 PWR Examination Outline Form ES-401-2 Davis-Besse 6/2015 Plant Systems - Tier 2/Group 1(RO)

System # / Name K K K K K K A A A A G K/A Topic(s) IR Points 1 2 3 4 5 6 1 2 3 4 003 Reactor Coolant Pump 2.1.7 Ability to evaluate plant performance 4.4 System (RCPS)

X and make operational judgments based on 1 operating characteristics, reactor behavior, Question 28 and instrument interpretation (CFR: 41.5 / 43.5 / 45.12 / 45.13) 003 Reactor Coolant Pump K3.01 Knowledge of the effect that a loss or 3.7 System (RCPS)

X malfunction of the RCPS will have on the 1

Question 29 following: RCS (CFR: 41.7 / 45.6) 004 Chemical and Volume K6.26 Knowledge of the effect of a loss or 3.8 Control System X malfunction on the following CVCS 1 components: Methods of pressure control of Question 30 solid plant (PZR relief and water inventory)

(CFR: 41.7 / 45.7) 005 Residual Heat Removal K4.08 Knowledge of RHRS design 3.1*

System (RHRS)

X feature(s) and/or interlock(s) which provide 1 or the following: Lineup for "piggy-back" Question 31 mode with high-pressure injection (CFR: 41.7) 006 Emergency Core Cooling K2.01 Knowledge of bus power supplies to 3.6 System (ECCS)

X the following: ECCS pumps 1 Question 32 (CFR: 41.7) 006 Emergency Core Cooling 2.4.1 Knowledge of EOP entry conditions 4.6 System (ECCS)

X and immediate action steps 1 Question 33 (CFR: 41.10 / 43.5 / 45.13) 007 Pressurizer Relief Tank A3.01 Ability to monitor automatic operation 2.7*

/Quench Tank System (PRTS)

X of the PRTS, including: Components which 1 discharge to the PRT Question 34 (CFR: 41.7 / 45.5) 008 Component Cooling Water A4.02 Ability to manually operate and/or 2.5*

System (CCWS)

X monitor in the control room: Filling and 1 draining operations of the CCWS including Question 35 the proper venting of the components (CFR: 41.7 / 45.5) 008 Component Cooling Water A2.05 Ability to (a) predict the impacts of the 3.3*

System (CCWS)

X following malfunctions or operations on the 1 CCWS, and (b) based on those predictions, Question 36 use procedures to correct, control, or mitigate the consequences of those malfunctions or operations: Effect of loss of instrument and control air on the position of the CCW valves that are air operated (CFR: 41.5 / 43.5 / 45.3 / 45.13) 010 Pressurizer Pressure K5.02 Knowledge of the operational 2.6 Control System (PZR PCS)

X implications of the following concepts as 1 the apply to the PZR PCS: Constant Question 37 enthalpy expansion through a valve (CFR: 41.5 / 45.7)

NUREG-1021, Revision 9 Supplement 1 RO Page 5 of 9 FENOC Facsimile Rev. 1

ES-401 PWR Examination Outline Form ES-401-2 Davis-Besse 6/2015 Plant Systems - Tier 2/Group 1(RO) Continued System # / Name K K K K K K A A A A G K/A Topic(s) IR Points 1 2 3 4 5 6 1 2 3 4 012 Reactor Protection System K3.03 Knowledge of the effect that a loss or 3.1*

(RPS)

X malfunction of the RPS 1 will have on the following: SDS Question 38 (CFR: 41.7 / 45.6) 012 Reactor Protection System K6.11 Knowledge of the effect of a loss or 2.9*

(RPS)

X malfunction of the following will have on the 1 RPS: Trip setpoint calculators Question 39 (CFR: 41.7 / 45/7) 013 Engineered Safety Features K5.01 Knowledge of the operational 2.8 Actuation System (ESFAS)

X implications of the following concepts as 1 they apply to the ESFAS: Definitions of Question 40 safety train and ESF channel (CFR: 41.5 / 45.7) 022 Containment Cooling K2.01 Knowledge of power supplies to the 3.0*

System (CCS)

X following: Containment cooling fans 1 Question 41 (CFR: 41.7) 026 Containment Spray System A1.01 Ability to predict and/or monitor 3.9 (CSS)

X changes in parameters (to prevent 1 exceeding design limits) associated with Question 42 operating the CSS controls including:

Containment pressure (CFR: 41.5 / 45.5) 039 Main and Reheat Steam K4.07 Knowledge of MRSS design 3.4 System (MRSS)

X feature(s) and/or interlock(s) 1 which provide for the following: Reactor Question 43 building isolation (CFR: 41.7)

K4.18 Knowledge of MFW design feature(s) 059 Main Feedwater (MFW) X and/or interlock(s) which provide for the 2.8* 1 System following: Automatic feedwater reduction on Question 44 plant trip (CFR: 41.7)

K5.05 Knowledge of the operational 061 Auxiliary / Emergency X implications of the following concepts 2.7 1 Feedwater (AFW) System as the apply to the AFW: Feed line voiding Question 45 and water hammer (CFR: 41.5 / 45.7) 2.4.35 Knowledge of local auxiliary operator 061 Auxiliary / Emergency X tasks during an emergency and the resultant 3.8 1 Feedwater (AFW) System operational effects Question 46 (CFR: 41.10 / 43.5 / 45.13)

A1.03 Ability to predict and/or monitor 062 AC Electrical Distribution X changes in parameters (to prevent 2.5 1 System exceeding design limits) associated with Question 47 operating the ac distribution system controls including: Effect on instrumentation and controls of switching power supplies (CFR: 41.5 / 45.5)

NUREG-1021, Revision 9 Supplement 1 RO Page 6 of 9 FENOC Facsimile Rev. 1

ES-401 PWR Examination Outline Form ES-401-2 Davis-Besse 6/2015 Plant Systems - Tier 2/Group 1(RO) Continued System # / Name K K K K K K A A A A G K/A Topic(s) IR Points 1 2 3 4 5 6 1 2 3 4 K1.03 Knowledge of the physical 063 DC Electrical Distribution X connections and/or cause-effect 2.9 1 System relationships between the DC electrical Question 48 system and the following systems: Battery charger and battery (CFR: 41.2 to 41.9 / 45.7 to 45.8)

K3.01 Knowledge of the effect that a loss or 064 Emergency Diesel X malfunction of the ED/G system will have on 3.8* 1 Generator (ED/G) System the following: Systems controlled by Question 49 automatic loader (CFR: 41.7 / 45.6)

K1.02 Knowledge of the physical 064 Emergency Diesel X connections and/or cause-effect 3.1 1 Generator (ED/G) System relationships between the ED/G system and Question 50 the following systems: D/G cooling water system (CFR: 41.2 to 41.9 / 45.7 to 45.8)

A4.01 Ability to manually operate and/or 073 Process Radiation X monitor in the control room: Effluent release 3.9 1 Monitoring (PRM) System Question 51 (CFR: 41.7 / 45.5 to 45.8)

A2.02 Ability to (a) predict the impacts of the 076 Service Water System X following malfunctions or operations on the 2.7 1 (SWS)

SWS; and (b) based on those predictions, Question 52 use procedures to correct, control, or mitigate the consequences of those malfunctions or operations: Service water header pressure (CFR: 41.5 / 43.5 / 45/3 / 45/13)

A4.01 Ability to manually operate and/or 078 Instrument Air System X monitor in the control room: Pressure 3.1 1 (IAS) gauges Question 53 (CFR: 41.7 / 45.5 to 45.8) 078 Instrument Air System A3.01 Ability to monitor automatic operation 3.1 (IAS)

X of the IAS, including: Air pressure 1 Question 54 (CFR: 41.7 / 45.5) 103 Containment System A2.03 Ability to (a) predict the impacts of the 3.5*

X following malfunctions or operations on the 1 Question 55 containment system and (b) based on those predictions, use procedures to correct, control, or mitigate the consequences of those malfunctions or operations: Phase A and B isolation (CFR: 41.5 / 43.5 / 45.3 / 45.13)

K/A Category Point Totals: 2 2 3 3 3 2 2 3 2 3 3 Group Point Total: 28 NUREG-1021, Revision 9 Supplement 1 RO Page 7 of 9 FENOC Facsimile Rev. 1

ES-401 PWR Examination Outline Form ES-401-2 Davis-Besse 6/2015 Plant Systems - Tier 2/Group 2(RO)

System # / Name K K K K K K A A A A G K/A Topic(s) 1 2 3 4 5 6 1 2 3 4 IR Points 001 Control Rod Drive K4.11 Knowledge of CRDS design 2.7 X feature(s) and/or interlock(s) which provide 1 Question 56 for the following: Resetting of CRDM circuit breakers (CFR: 41.7) 002 Reactor Coolant System A4.01 Ability to manually operate and/or 3.5*

(RCS)

X monitor in the control room: RCS leakage 1 calculation program using the computer Question 57 (CFR: 41.7 / 45.5 to 45.8) 011 Pressurizer Level Control K2.01 Knowledge of bus power supplies to 3.1 System X the following: Charging pumps 1 Question 58 (CFR: 41.7) 015 Nuclear Instrumentation K6.03 Knowledge of the effect of a loss or 2.6 System X malfunction on the following will have on the 1 NIS: Component interconnections Question 59 (CFR: 41.7 / 45.7) 016 Non-nuclear K5.01 Knowledge of the operational 2.7*

Instrumentation X implication of the following concepts as they 1 apply to the NNIS: Separation of control and Question 60 protection circuits (CFR: 41.5 / 45.7) 033 Spent Fuel Pool Cooling 2.4.11 Knowledge of abnormal condition 4.0 X procedures 1 Question 61 (CFR: 41.10 / 43.5 / 45.13)

A1.02 Ability to predict and/or monitor 035 Steam Generator X changes in parameters (to prevent 3.5 1 Question 62 exceeding design limits) associated with operating the S/GS controls including: S/G pressure (CFR: 41.5 / 45.5) 041 Steam Dump/Turbine K3.02 Knowledge of the effect that a loss or 3.8 Bypass Control X malfunction of the SDS will have on 1 the following: RCS Question 63 (CFR: 41.7 / 45.6) 045 Main Turbine Generator A3.11 Ability to monitor automatic operation 2.6*

X of the MT/G system, including: Generator 1 Question 64 trip (CFR: 41/7 / 45.5) 086 Fire Protection System K1.03 Knowledge of the physical 3.4*

(FPS)

X connections and/or cause-effect 1 relationships between the Fire Protection Question 65 System and the following systems: AFW system (CFR: 41.2 to 41.9 / 45.7 to 45.8)

K/A Category Point Totals: 1 1 1 1 1 1 1 0 1 1 1 Group Point Total: 10 NUREG-1021, Revision 9 Supplement 1 RO Page 8 of 9 FENOC Facsimile Rev. 1

ES 401 Generic Knowledge and Abilities Outline (Tier 3) Form ES-401-3 Facility: Davis-Besse RO Date of Exam 6/15 thru 6/26 2015 RO SRO Only Category K/A# Topic IR Points IR Points

1. 2.1.41 Knowledge of the Refueling process. (CFR: 41.2 / 41.10 / 43.6/ 45.13) 2.8 1 Conduct Question 66 of Operations 2.1.27 Knowledge of system purpose and/or function. (CFR: 41.7) 3.9 1 Question 67 Subtotal 2
2. 2.2.15 Ability to determine the expected plant configuration using design and 3.9 1 Equipment configuration control documentation, such as drawings, line-ups, tag-Control outs, etc. (CFR: 41.10 / 43.3 / 45.13)

Question 68 2.2.36 Ability to analyze the effect of maintenance activities, such as degraded 3.1 1 power sources, on the status of limiting conditions for operations. (CFR:

41.10 / 43.2 / 45.13)

Question 69 2.2.38 Knowledge of conditions and limitations in the facility license. (CFR: 41.7 3.6 1

/ 41.10 / 43.1 / 45.13)

Question 70 Subtotal 3

3. 2.3.4 Knowledge of radiation exposure limits under normal or emergency 3.2 1 Radiation conditions. (CFR: 41.12 / 43.4 / 45.10)

Control Question 71 2.3.5 Ability to use radiation monitoring systems, such as fixed radiation 2.9 1 monitors and alarms, portable survey instruments, personnel monitoring equipment, etc. (CFR: 41.11 / 41.12 / 43.4 / 45.9)

Question 72 2.3.12 Knowledge of radiological safety principles pertaining to licensed 3.2 1 operator duties, such as containment entry requirements, fuel handling responsibilities, access to locked high-radiation areas, aligning filters, etc. (CFR: 41.12 / 45.9 / 45.10)

Question 73 Subtotal 3

4. 2.4.30 Knowledge of events related to system operation/status that must be 2.7 1 Emergency reported to internal organizations or external agencies, such as the Procedures/ State, the NRC, or the transmission system operator. (CFR: 41.10 / 43.5 Plan / 45.11)

Question 74 2.4.34 Knowledge of RO tasks performed outside the main control room during 4.2 1 an emergency and the resultant operational effects. (CFR: 41.10 / 43.5 /

45.13)

Question 75 Subtotal 2 Tier 3 Point Total 10 NUREG-1021, Revision 9 Supplement 1 RO Page 9 of 9 FENOC Facsimile Rev. 1