ML20155G229
| ML20155G229 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 09/21/1988 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Randazza J Maine Yankee |
| References | |
| NUDOCS 8810140139 | |
| Download: ML20155G229 (14) | |
Text
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g UNITED STATES NUCLEAR REGULATORY COMMISSION j
j REGION l t
476 ALLENDALE ROAD k
.f KING OF PRUSSI A, PENNSYLVANIA 19406 September 21, 1988 Docket No. 50-309 Maine Yankee Atomic Power Company ATTN: Mr. J. B. Randazza President 83 Edison Drive Augusta, Maine 04336 Gentlemen:
Subject:
MAINTENANCE PROGRAM TEAM INSPECTION This letter is to inform you that the NRC intends to perform a team inspection of your maintenance program at the Maine Yankee Atomic Power site on October 31, 1988 through November 11, 1988, and one week near the end of the outage, and to request your assistance in accomplishing this task.
The inspection will focus on the performance of maintenance and whether all components, systems and structures of your plant are adequately maintained and properly repairod so that they are available to perform their intended safety function.
The inspection team will consist of five members providing expertise in different areas.
In order for us to prepare for the inspection and maximize the onsite time spent in observation of maintenance in progress, it will be necessary for the facility to furnish reference material listed in the enclosure to this letter.
The team leader will be contacting you shortly regarding the information that will be needed prior to the start of the inspection and to arrange a suitable date for a meeting to explain the inspection and assessment methodology.
A copy of draft NRC Temporary Instruction 2915/97 "Maintenance Inspection" is enclosed for your information and to aid in preparation for the inspection.
Thank you for your cooperation in this matter.
If you have any questions regarding this matter please contact Mr. Robert Gallo at 215/337-5291.
Sincerely, Oriainal sisnea Bra*
Thomas T. Martin, Director Division of Reactor Safety 1
Enclosures:
As stated 0FFICIAL RECORD COPY I
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GG10140139 83092g PDR ADOCK 05000309 O
Maine Yankee Atomic Power Company 2
cc:
C. D. Frizzle, Vice President, Operations John Garrity, Vice President, Quality Programs and Engineering Dr. E. T. Boulette, Plant Manager P. L. Anderson, Project Manager G. D. Whittier, Licensing Section Head J. A. Ritsher, Attorney (Ropes and Gray)
Philip Ahrens, Esquire Public Document Room (PDR) local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of Maine bec:
Region I Docket Room (with concurrences)
L. Tripp, DRP
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9/h /88 0FFICIAL RECOR9 COPY MAINE YANKEE TEAM INSPECTION -
0001.1.0 09/09/88
ENCLOSURE To aid us in preparation for the maintenance inspection please provide us with the following dncuments, procedures and information in accordance with the designated numbers.
If you do not have the requested document or information, it is not necessary to generate it to comply with this request. We recognize that many of the documents requested separately may be inclusive in a larger single document.
Please proviue five sets of the requested documents. A member of our staff will contact you regarding the best method of transmitting the documents to us.
Section 1-Description of General Plant Maintenance Activities 1-1 Maintenance administrative procedures which describe your corrective, preventive and predictive maintenance activities.
1-2 Organization charts including the maintenance organization and plant wide organizations.
1-3 Procedures, charts and other documents which describe your Planning Department ard its activities.
J 1-4 bocuments which describe maintenance planning and scheduling meetings and status of maintenance reports.
1-5 Documents which describe the Maintenance and Operations interface during planning, scheduling, work start, work closeout and post maintenance / functional testing.
1-6 Documents which describe your work control process:
how a work order is started, planned, executed, completed, closed out and equipment returned to service.
1 1-7 Documents which describe training and retraining of plant and contractor maintenance personnel.
(For maintenance activities only, i
do not include GET.)
1-8 Documents which describe interfaces and communications among the technical support, engineering support and the maintenance /I&C Departments, 1-9 Documents which describe maintenance work procedure establishment and control:
Criteria as to when a procedure is to be used; initial writeup; reviews and approval; revisions; human factors reviews; QA reviews; requirements for conduct of work; troubleshooting criteria; work closeout; post maintenance testing and restoration of systems.
1-20 Description of methods by which maintenance performance is measured.
Are performance indicators used? What are they? Who is informed of the results?
1 1
ENCLOSURE 2
1-11 Description of process for communications with vendors for technical services and latest technical infermation on equipment and systems ins +.alled at the plant, and interfaces with vendors or NSS$ for training, modifications and equipment replacement.
1-12 Occuments which describe the preventive maintenance and predictive maintenar.ce programs.
- Which equipment is included?
- How is maintenance frequency determinea?
- What is done with results of these maintenance actions.
1-13 Documents which describe management involvement in maintenance.
- Are there goals set for the maintenance and 1&C Departments.
- Are these goals used in the performance v aluation of managers and supervisors?
- Are these goals communicated to first line supervisors and chiefs?
Section 2-Status of Plant and Contractor Personnel Who Perform Maintenance.
2-1 The number of craft personnel for electrical, mechanical and I&C maintenance organizations.
Please include foremen and the foreman to craft ratio.
2-2 The average years of experience for each individual and the turnover rate.
2-3 Description of sh.ft work and work assignments.
How do foremen decide on which craf t is to perform what type of work?
Section 3-Status of Plant Equipment and Plant Maintuance 3-1 What equipment failures occurred during the last year of operations?
3-2 WFat equipment failures have been found during shutdown of plant?
3-3 Describe maintenance and testing for diesel generators and electrical equipment including switchgear that would be required in case of loss of offsite power.
3-4 What component failures present greatest risk from a probabilistic risk standpoint to the plant?
3-5 What have been the areas of high maintenance activity on safety related and non-safety related equipment and components?
0FFICIAL RECORD COPY MAINE YANKEE TEAM INSPECTION -
0007.0.0 09/12/88
ENCLOSURE 3
3-6 Provide the following status concerning Maintenance Work Orders (NWO).
-Current total listing and status of MW0s, number in planning, number in final sign-off, number on hold for lack of parts, number on hold for engineering assistance, number available to be worked on
-Projected number of corrective Md0s to be outstanding at start-up by priority
-Rate of completion of corrective MWO in terms of number completed / month and manhours expended (by craft)/ month for the past 12 months
-Current number of preventive maintenance work orders overdue
-Rate of completion of preventive Kd0 for the past 12 months.
-Estimated manhours required to complete current preventive maintenance Kd0s
-Number Kd0s requiring rework over past 6 months 3-7 Provide five corrective maintenance procedures for wt.*k that is scheduled for the upccming outage.
MOVs, PRVs, ECS Pumps, Batteries, Switchgear, etc.
3-8 Provide five preventive maintenance procedures that are scheduled for the upcoming outage.
3-9 Provide your overall outage schedule.
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0FFICIAL RECORD COPY MAINE YANKEE TEAM INSPECTION -
0008.0.0 09/12/88 j
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TEMPORARY INSTRUCTION 2515/97 MAINTENANCt! INSPECTION 2515/97-01 PURPOSE To provide guidance for conducting a performance-based inspection of an established and implemented maintenance process at an operating nucleer power station.
2515/97-02 OBJECTIVES The primary objective is to determine whether all components, systems, and structures of nuclear power plants are adequately maintained so that they L
are available to perform their intended functions.
Additionally, it should be determined whether the maintenance process provides for the prom,nt repair of plant components, systems, and structures, as appropriate to their 7
prescribed function.
2515/97-03 BACKGROUND The NRC has examined nuclear power plant maintenance programs and has found a wide variation in effectiveness. Inadequate maintenance has been a signif-i icant contributor to plant and system reliability problems and, thus, is a safety concern. Analysis of operational events has shown that nuclear power plant components are not being maintained at a level commensurate with their i
importance to safety.
This Temporary Instruction (TI) was developed for the inspection and assessment of the ef fectiveness of maintenance at selected nuclear power plant sites.
A Maintenance Inspection Tree (logic tree) will be utilized as a product of these inspections to collate and present inspection find-ings.
The tree will also provide a systematic approach to the inspections e
and is intended to ensure consistency.
2515/97-04 CONDUCTING TEAM INSPECTIONS The maintenance team inspections will be announced when the team leader prepares for the pre-inspection visit (05.01) to the site.
The full scope J
inspection cycle will generally be of a 6-week durt. tion with the team
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leader possibly taking an additional 2 weeks to initially coordinate the j
inspection, gather information and issue the final inspection report. Issue Date: 09/xx/88 I
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The 6 weeks of team effort should consist of 1 week preparation, I week in-office inspection, 2 weeks on site inspection and 2 weeks documentation.
The sequence of the inspection ef fort will be determined by the Regional Office.
For uample, the 2 weeks of on-site inspection may be consecutive or separated by 1 week of in-of fice inspection.
Generally, the inspection team will be composed of the following six members:
Team Leader (Regf on)
Two Reactor / Project Engineer (Region)
Radiation Specialist (Region)
Twe Engineers (HQ)
The team composition and/or the extent of effort for individual members may be adjusted by the Recicn.
For e< ample, the extent of radiation specialist involvement may be determined to be less than a full 6 weeks, as appropriate l
by the Regional Office.
In addition, the Regions tray include Resident Inspector involvement.
During the monthly maintenance observations, the Resident Inspector is able to observe the performance of maintenance more l
readily +han a Region-based team.
Consequently, for a specific inspection, the Resident may be used to complete portions of a tree based on a number of IP-62703 monthly examinations, thereby reducing the size of the team and/or the amount of team member participation.
The Resident should be provided training in the use of the logic tree by the appropriate team leader prior to his utilization for this purpose.
The Project Manager (pM) will be involved with each inspection to the following extent:
Be available to the team leader to facilitate contacts with the licensee Attend 1-2 days of the team preparation Attend final team meeting Atter:d exit meetings The team will determine what recent failures of significant equipmeat (PRA identified, safety-related, Balance of Plant that impacts on safety-related and special interest items) have acc.urred and inspect the licensee's main-tenance activities to schedulv, repair and prevent further failure of that equipment.
Other selective examinations of equipment failures attributed to maintenance will determine the adequacy of licensee corrective actions and root cause determinations.
The inspection should be performed using the Maintenance Inspection Tree (working tree) and inspectier guidance provided in Appendix A.
These provide the means of determining adequacy, implementation and an evaluation of maintenance activities, the tree is
)
used as a tool to provide uniformity in inspection structure and to docu-ment inspection results.
It is important to stress that the tree not drive the inspection, but that it is to be completed as a result of the inspec-tion.
The tree cons'sts of three rnajor section:;:
(1) Overall Plant Per-
- formance, (2) Management Support of Maintenance, and (3) Maintenance Implemnntation.
The inspection requirements for Maintenance In'plementa t ion that focus on the plant systels and components snd related activities receivo the
P majority (at hast 60*4, including direct observations of maintenance being performed) of the inspection ef fort.
It should be recognized that inspec-tion results from the Maintenance Implementation area will also provide input to the Management Support area.
Further, portions of the Management i
Support of Maintenance portion of the tree, especially the Management Co.a-mitment ar.d Managemo.t Organization Sections, may be conducted by a single team member in a relatively short time.
The amount of inspection effort devoted to the inriividual subsections of tae tree will be determined by the Regional Office, considering recent in-spection findings and future inspections for specific areas.
Th> purpose of the inspection is to dete-mine the effectiveness of power reactor licensees' total integrated maintenance process.
By the very nature of the goal, the team inspection may be directed into areas for which explicit regulaury requirements may not currently exist.
Thus, the insoec-tion is geared more towards analyzing the performance of maintenance activ-ities rather than towards the identification of violations.
A specific ex-ample of au area not subject to explicit requirements is the licensee's participation with INPO.
Review of licensee resolution of INPO activities 4
shall be conducted in accordance with established policy and, thus, ob-servationi in thfs area should be treated as indicators of strength or weaknesses.
Although the inspection may result in the identification of inadequacies that are nat covered by explicit regulatory requirements, there is no intent to "ratchet" licensees.
Individual findings that licensees are not following 3
published NRC guides and industry guidelines do not necessarily indicate that a program or area is inadequate.
The goal of tne inspection effort is to emphasize the use of plant experience, recent component failures, PRA in-l sights and items of interest in evalu2 ting the licensee's maintenance process in terms of capabilities and performance and to identify major strengths and weaknesses.
04.01 Team Leader Preparation.
A meeting should be planned and held with the licusee to describe the scope of the inspectien and to obtain prelimin-a ry review materials such as licensee's procedures for planning, conducting and assessing maintenance as well as organizational charts, work schedules, equipment lists, component failure data, completed work orders and related QC inspection procedures. The material obtained by the team leader from the licensee should be distributed to the team members for their review. Follow-ing completion of the in-of fice review of the licensee's maintenance process, the results of these reviews snould be discussed with the team members and l
factored into the plan for the on site inspection.
1 04.02 Ingection Preparatign.
In preparation for site inspections, the inspection team should review the elements of the Maintenance Inspection Tree 4
and Jetermine which areas may have received recent inspections, which areas may not be applicable, and which areas will be reviewed at the plant site.
The three major parts of maintenance (i.e.,
overall plant performance, management support of naintenance, maintenance implementation) should be inspected to the degree re,uired to provide an accurate conclusion regarding the licensee's maintenante program.
Du.-i n g the preparation phase, the team should select several components /
systems for detailed inspection either t$ rough consideration of PRA
insights, recent component failures in safety-related or BOP systems that affect safety, or selected topics of interest to the Commission such as check valves, motor-operated valves, air systems.
The PRA insights may be used to select components whose failures (or unreliability) would contrib-ute most to the risk at that plant. At least one PRA identified high risk system should be included to verify that all performance related maintenance ha t.
been accomplished including preventive maintenance.
Recent equipment f ailures provide a vehicle for review of various aspects of maintenance, including root cause analysis, equipment history, corrective actions, and past maintenance (preventative or corrective).
Inspection of failed equip-ment repairs or work packages will provide the opportunity to examine the adequacy of the interaction of all licensee functions supporting mainte-nance, including su.h things as engineering analyses and trending.
Review of performance indicator data, SALP reports, previous inspection findings, LERs, maintenance radiation exposure hi sto ry and other direct measures may identify ootential weak areas at that plant for more detailed inspaction through utilization of the Maintenance Inspection Tree.
The attached figure (Inspectior Flo,v Chart) depicts the initiators that may be selected to enter the tree.
During the preparation, program strengths and weaknesses in certain areas may be recorded on the Maintenance Inspection Tree (working tree).
If there are sufficient data to provide an evaluation rating during the preparation, the elements should be rated in accordance with the Maintenance Inspection Guidance. However, selected items and, in particular, identified weaknesses should be verified during the on-site inspection, even if an evaluation rating is assigned during the preparation.
04.03 On-Site Insp_ection.
An entrance meeting should be held with the licensee to cetail tne scope, and schedule of the inspection, introduce the team members and establish the licensee's contacts for the inspection.
The team should obtain from the licensee the status of ongoing work applicable to the inspection or which may affect the performance of the inspection or the inspection schedule. The exit meetings and interim meetings between the team leader and licensee management may also be established during the entrance meeting.
I Team members shall perform a detailed walkdo,<n of the plant on the first or second day on site to observe the overall plant and equipment material con-dition.
This walkdown should include but not be limited to (observe the condition of numerous valves, pumps, motors etc.)
Condition of ccmponents Tagged equipment Housekeeping and environment Labeling Comparisons with drawings / procedures Status of annunciators This walldown may provide areas for further investigation during the in-spection.
The on-site inspection should focus on the direct ob;.rvation of work in
- progress, including following of a
job in
- progress, e.g.,
- tagouts,
procedures work packages, engineering support, materials, communications, testing, approval s, quality control holdpoints, etc.; significance of the maintenance backlog; rework; licensee assessment of performance of mainte-nance; work control processes; control of interfaces; post-maintenance testing; plant material condition and maintenance facilities.
Based on the collected data, determine the apparent nature of the cause of any problems noted; t, hat is, is it related to the adequacy of procedures, work packages, qualification of personnel, management, engineering, etc.?
This analysis provides entry to elements of the tree which then provides a tool to explore the suspected cause and assess effectiveness of implementa-tion of an element.
All areas listed need not be utilized in forming conclusions for each element.
Further, other areas selected by the team may i
be used for inspection of tree elements.
04.04 Analysis.
Utiliing the inspection findings and results with the Maintenance Inspection Tree, determine whether each of the areas inspected has been adequately implemented and whether or not there is enough data to assign a rating.
Refer to Appendix A, the Maintenance Inspection Guidance and Criteria for assistance in using the Mairtenance Inspection Tree.
As-sign a rating to the applicable elements identified on the work sheets.
The team should assign the overall evaluation rating to each of the elements inspected. Wnen this analysis has been completed, an overall rating can be determined in accordance with the Maintenance Inspection Guidance and Criteria.
04.05 E_xit Meeting.
Prior to the final days of inspection, written issues ard findings should be used to highlight the oresentation version of the Maintenance Inspection Tree (unbulleted Maintenance Inspection Tree) and to complete the rating roll-up.
The exit meeting should include a brief dis-cussion of the preliminary inspection findings and a discussion using the Presentation Tree.
The Presentation Tree is used during the exit meeting to depict inspection resulti in a summary fashion; however, the licensee should be informed that the findings are preliminary until they are re-i viewed by regional management and that a completed chart will be forwarded to the licensee.
04.06 SeportPreparation.
Because of the extent of the inspection, documentation of inscection activities should commence early in the prccess.
This will minimize the time required to complete the final report.
The final report should document the assumptions used, elements inspected, ele-ments that were not applicable, licensee strengths and weaknesses and overall conclusions consistent with IMC-0610.
De report should address elements of the tree to at least the depth of the tier with eight crea s (e.g., Direct Measures, Management Commitment and Involvement, etc.).
04.07 Follow-up.
Any findings idet.ef fied during the inspection wi'l be appropriately tracked and resolved by the Regional Office.
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2515/97-05 INSPECTION REQUIREMENTS The inspection recuirements, guicance and criteria contained in Appendix A address the aspects of maintenance listed balow.
Inspection findings should
h be based on observation of maintenance activities in progress, review of li-censee implementation of their procedures and controls, results of review of selected documents, such as work packages and engineering evaluations, and interviews with personnel.
- Overall Plant Performance Related to Maintenance
- Direct Measures Management Support of Maintenance Management Commitment and Involvement Management Organization and Administration Technical Support Maintenance Implementation
- Work Control Plant Maintenance Organization Maintenance Facilities, Equipment, and Materials Control Personnel Control 05.01 Overall Plant Performance Related to Maintenance a.
Di_ rect Measures.
Overall plant performance with respect to plant operability, equipment availability and plant material condition can directly 1
be related to the effective implementation of a maintenance process.
l Inspection of plant performance should include plant (1) availability, (2) operability, and (3) reliability.
These items can be obtained from the plant's operating history. Other sources for obtaining the information are i
SALP Reports, Performance Indicator Data, AE00-Scram, ESF Actuations, and Safety System Unavailability Studies, Technical Specification Violations, Monthly Operating Report Data and Capacity Factors from NUREG-0020.
Data collection should be directed to those measures related to the maintenance process.
In addition, a detailed walkdown if the overall plant material condition will show the effectiveness of a licensee's maintenance process.
Perform the inspection in accordance with the criteria listed under direct l
measures for:
Historical Data i
- Plant Material Condition 05.02 Manaaement Support of Maintenance a.
Yanagement Commitment and Involvement.
Maintenance is influenced by the management philosophy toward maintenance activities.
The areas to be I
inspected are listed below. The inspection should be directed to determining the extent of corporate and plant management awareness and support of maintenance using the criteria listed under the following:
Y Application of Industry Initiatives l
Management Vinor and Example b.
Managerent Organization and_ Administration.
The inspection of manage-ment organization and administration controls should be directed to deter-mining how the organization supports maintenance activities, what mainte-nance activity plan has been established, how the maintenance activity plan has been implemented and controlled, and thu control of resources.
Perform the inspection in accordance with the criteria listed under the following:
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Identify Program Coverage for Maintenance Establish Policy, Goals, and Objectives for Maintenance Allocate Reso'irces Define Maintenance Requirements Conduct Performance Measurement Document Control System for Maintenance Maintenance Decision Process C.
Technical Support.
The topics that are to be used to inspect the technical support organizations with regard to maintenance are as follows:
Internal / Corporate Communication Channels Engineering Control PRA into Maintenance Process Quality Control Radiological Controls into Maintenance Process Safety Review Committees Regulatory Documents Some of the applicable departments or organizations are as follows:
Engineering (nuclear, I&C, mechanical, elect-ical, licensing, systems, etc.)
Quality Assurance (QA)
Quality Control (QC)
Health Physics (HP)
Safety Fire Protection Operations 05.03 Maintena_n_ce Implementation a.
Work Control.
The inspection of the work control process should be directed _ to v.o r k order documentation, equipment history, planning and scheduling, and document review.
Perform the inspection in accordance with the criteria listed under the following:
Review of Maintenance in Process
- Work Order Control
(
Maintain Equipment Records and History Conduct Job Planning Perform Work Prioriti:ation 1
i Maintenance Work Scheduling 4
Backlog Controls I
Provide Maintenance Procedures i
Conduct Post Maintenance Testing j
Review of Completed Work Control Documents b.
Plant Maintenance Organization.
The inspection of the plant maintenance I
organi:ation shoufd be directed to how the organization supports maintenance activities, how the maintenance activities are controlled and implemented, how personnel are controlled, how the organization estabiishes documentation.
and how open the lines of communication between plant management and craf t personnel are. Perform the inspection in accordance with the criteria listed under the following:
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Establish Control of Plant Maintenance Activities Establish Control of Contracted Maintenance Establish Deficiency Identification and Control System Perform Maintenance Trending Establish Support Interfaces c.
Maintenance Facilities, Equipment and Materials Control.
The following topics are to be used to inspect the f acilities, equipment, and material controls with regard to their support of the maintenance process.
Provide maintenance facilities and equipment
- Establish material controls Establish maintenance tool and equipment control Provide control and calibration of measurement and test equipment
- d. Perscnnel_ Control.
The following topics are to be used to inspect personnel control.
The inspection should include consideration for staffing, training, and qualification.
Establish staffing control Provide personnel training Establish test and qualification process Assess the current personnel control status 2515/97-06 REPORTING REQUIREMENTS l
1 The appropriate Regional Office will document the findings and actions taken in an inspection report and in addition to the normal distribution, will forward one copy to the Director, Division of DLPQ, Office of NRR and one copy to each of the other Rejional Offices.
(Director, Division of Reactor Safety).
i 2515/97-07 COMPLETION SCHEDULE Inspections should be scheduled such that cceplation is within 2 years from 4
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the issuance of this instruction.
L 2515/97-03 EXPIRATION i
This Temporary Instruction shall remain in effect for 24 months or until the l
inspections have been completed.
2515/97-09 NRR CONTACT j
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Anj questions regarding this Temporary Instruction should be addressed to A. T. Gody (FTS 492-1117).
2515/97-10 STATISTICAL DATA REPORTING 4
For 766 input, record the actual inspection effort against the review of module 25597.
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2515/97-11 ORIGINATING ORGANIZATION INFORMATION 11.01 Organization Responsibilities.
The Performance Evaluation Branch of NRR will provide support and overall guidance for these inspections.
11.02 Estimated Resources.
Each inspection is planned for 6 weeks for six persons, with expected additional effort by the team leader (38 staff weeks).
11.03 Parallel Inspection Procedures Inspection Procedures this TI may satisfy totally or in part are listed below.
Where credit is taken, the inspection report should note the module number per IMC-0610.
The Region should make final determinations based on the scope and docu:nentation of the inspection.
37701 56700 62704 37702 61700 62705 37828 CIP 61725 72701 38701 62700 83000 series 38702 62702 92700 41400 62703 CIP 92701 l
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