Issue Date: 10/20/08 1 65001.19 

ATTACHMENT 65001.19 

INSPECTION OF INSTALLATION 

OF ITAAC-RELATED RADIATION MONITORING COMPONENTS AND SYSTEMS 

PROGRAM APPLICABILITY: 2503 

 

65001.19-01 INSPECTION OBJECTIVES 

01.01 To determine whether activities relative to radiation monitoring components and 

systems (RMCS) are being accomplished in accordance with NRC requirements, the final 

safety analysis report (FSAR), design specifications and drawings, industry standards, and 

licensee commitments and procedures. 

01.02 To evaluate the performance of ITAAC-related RMCS. 

01.03 To determine whether the general records for the installation and testing of RMCS 

are consistent with NRC requirements, the FSAR, and licensee commitments and 

procedures. 

01.04 To evaluate the adequacy of the implementation of the specific quality assurance 

(QA) program requirements for the installation and testing of RMCS, and to ensure 

problems are entered into the corrective action process. 

65001.19-02 INSPECTION REQUIREMENTS AND GUIDANCE 

This inspection procedure (IP) covers the inspection of the installation and testing of 

RMCS. This includes field sensors, transmitters, indication displays, instrumentation 

systems that process field information and actuate other components and protection 

systems, logic and control devices, and annunciation. It does not include cabling, except 

when the cabling is an integral part of the instrument component, for example, 

thermocouple cabling. 

For the RMCS listed in this IP, periodic inspections shall be performed on a frequency 

commensurate with construction progress, but in general, no less frequently than semi 

annually. 

Because RMCS are important, extensive inspection activities are to be conducted 

periodically. In-process construction and installation inspections should be scheduled to 

match appropriate installation activities. It is expected that the scope of periodic inspections 

will vary with construction progress, problems encountered, etc. Not all the steps of this IP 

are required to be performed each time it is implemented. It may be appropriate for a 

particular inspection to implement only certain steps in this IP. Additional inspections 

should be made when and where conditions warrant. Any installation activity that has 

been delayed or suspended for more than one year, or has been subject to significant 

procedural, design, or personnel change, should be re-evaluated immediately after 

resumption of the work or after the changes have been made. Inspectors should be aware 
Issue Date: 10/20/08 2 65001.19 

of how the inspection requirements and guidance in the following steps and the 

subsequent inspection results can provide the justification for concluding that the ITAAC, 

for RMCS, for a specific advanced reactor design are complete. 

02.01 Pre-Inspection Activities. 

a. Inspection Preparation. 

1. The inspector should develop a basic understanding of the RMCS of the 

particular plant design (e.g., AP 1000), and how they interrelate to one 

another and to the main control room (MCR) readouts. 

Guidance. The RMCS being referred to are those that process the signals from 

field detectors, and provide displays to the MCR and from there to other accessible 

data systems. The focus is on the purpose of each system and their sub-systems, 

the types of inputs and outputs to/from each system, and how these systems 

interrelate to other plant systems. However, since RMCS includes components, a 

working knowledge of the larger more distinct components would also be 

appropriate. A basic familiarity with non-safety related RMCS is also applicable. 

The goal is to become familiar with all RMCS including the actual hardware but to 

give more attention to those systems that have a large number of ITAAC 

associated with them. The inspector can use the FSAR, plant-specific design 

control documents (DCDs) or equivalent, and construction drawings and 

specifications for the requested inspection preparation. 

2. The inspector should understand the nature and types of the ITAAC residing 

in Afamilies@ along row (19) of the ITAAC matrix for Radiation Monitoring 

components and systems. 

Guidance. The attributes of the ITAAC for row 19 of the matrix are important 

because they will be the focus of the inspections for RMCS. The inspection results 

for the implementations of this IP will eventually be used to verify the licensee=s 

documentation that indicates completion of the ITAAC for RMCS. 

3. Review the FSAR and licensee/contractor QA programs to determine the 

documentation requirements for the fabrication, installation, and testing of 

RMCS. 

Guidance. The licensee should maintain clear, concise records during the 

fabrication, installation, and testing of RMCS. Where possible, the record reviews 

of this IP should be performed in conjunction with the inspection of work and test 

activities. Look for inadequacies that could lead to construction or testing 

deficiencies and indicate inadequate management control. Quality records should 

be selected for review based on their association with ITAAC, safety, and risk 

significance. Ascertain who is responsible for preparing, reviewing, and ensuring 

the accuracy of quality-related records. 

4. The inspector should verify with NRO that the RMCS, actually purchased, 

are in accordance with the plant=s design basis. 
Issue Date: 10/20/08 3 65001.19 

Guidance. The majority of the RMCS were not actually defined down to the 

hardware level in the plant-specific DCD or equivalent. In most cases, the related 

ITAAC and Design Acceptance Criteria (DAC) for the RMCS were defined based 

only on performance. The selection of the actual hardware for the RMCS may not 

actually occur until late in the application process for a Combined Operating 

License (COL) or even after construction begins. NRO Instrumentation, Controls, 

and Electrical Engineering Branch 1 or 2 (ICE1or ICE2) will assist the inspector by 

making the determination, if required, as to which RMCS is ready for inspection. 

The inspector should determine if required design reviews have been performed as 

part of any inspections of specific RMCS that are associated with Design 

Acceptance Criteria (DAC). 

b. Selection of RMCS. 

1. Select one or more components for each of the Radiation Monitoring 

systems listed in the DCD or in some cases an entire Radiation Monitoring 

system when appropriate for the inspections at the factory and for the 

installation and testing of RMCS at the specific nuclear plant. 

Guidance. The seismically qualified (SQ) and environmentally qualified (EQ) 

equipment should receive the highest priority in selection, but a cross section of 

the equipment systems should be assessed by the inspector or over time by the 

inspection process. The qualification description of various types of RMCS is listed 

in the DCD. The inspection should focus on RMCS that provides the information 

used by operators to address an accident or an event, and to prevent the potential 

release of radiation to the environment. The licensee should have procedures that 

indicate the manual actions taken by operators based on the available indications 

in the MCR. The following are some examples of RMCS that may be selected. 

(a) Containment Monitoring and Main Control Room Monitor. 

Guidance. Examples of RMCS used for technical specification action 

requirements and emergency action limits during events are Containment 

High Range and Containment Atmosphere Monitors. The Main Control 

Room Radiation Monitor is included in this group due to SQ requirements. 

Associated and interrelated equipment components include: signal 

processing components, microprocessors, data communication links and 

transmitters, resets, instrument housings, racks, panels, and associated 

supports. Examples of processes used in the engineered safety features like 

control room ventilation actuation include in addition to manual actuation: 

high area radiation and high radioactive particulate or gas. The FSAR 

should include the specific variables, as well as the logic and logic devices, 

used in the system. Actuation of the ESF actuation system (e.g., Control 

Room Habitability, Stand-by Gas Treatment) may be achieved through 

multiple means. 

(b) Process Radiation Monitoring. 

Guidance. Examples of Process Radiation Monitoring used to monitor the 

equipment engineered for safety to limit plant releases and assess systems 
Issue Date: 10/20/08 4 65001.19 

during operation include monitors for: blow down, component cooling and 

service water, main steam line, and primary system liquid and gas. The 

FSAR should include the specific variables, as well as the logic and logic 

devices, used in the systems. 

(c) Effluent Monitors. 

Guidance. These are RMCS that provide the information used by operators 

to assess release of radiation to the environment. The licensee should have 

procedures that indicate the manual actions taken by operators based on 

reliance on the available indication in the MCR. Examples of the effluent 

monitors are the ones for plant ventilation normal range particulate-iodinegas, mid-range gas, high range gas, turbine building vent, containment air 

exhaust, gaseous and liquid radwaste discharges, and wastewater 

discharge. 

(d) Airborne Monitors 

Guidance. The Airborne Monitors used for safety related and environmental 

control for example may be located in the fuel handling, Auxiliary, Annex, 

Chemistry Laboratory, RadWaste and Machine Shop exhaust systems. 

Portable monitors will be installed later, and if they are not part of the 

permanently attached equipment then they are not part of this inspection 

module. 

(e) Area Monitors 

Guidance. In addition to the monitors in the main control room HVAC 

system, area monitors are installed in the control room to assess 

occupational safety. Other examples of these monitors are found in the 

Technical Support Center and the Primary System Sampling Station area. 

Area Monitors may be installed in other locations in the plant. Consult the 

DCD for the particular plant being inspected. 

02.02 Inspection Activities. 

a. Design and Fabrication. 

1. Confirm for each of the selected RMCS equipment, that the original design 

(or approved deviations from the original design) that the licensee/contractor 

has maintained the SQ of those RMCS that must have SQ as indicated in 

the DCD or FSAR. 

Guidance. Direct observation of some performance based Category I SQ testing is 

preferred during the planning, testing, or conclusion stage(s) as available. In lieu of 

observations, review of licensee audits should be completed. The seismic 

Category I equipment should be able to withstand seismic design basis loads 

without loss of safety function. Review of test or analysis documentation is also 

possible. The documentation of Class 1E equipment should be clearly marked on 

the drawings, ANuclear Safety Related@. The documentation including all changes 
Issue Date: 10/20/08 5 65001.19 

to the original design should be reviewed to assure that the testing or analysis 

parameters and the relationship of the test(s) or analyses to the design basis event 

have equivalency. Verify that the safety related documents are complete. Any preassembly of Radiation Monitoring equipment prior to installation into the plant 

should be bounded by the test or analysis. 

2. Confirm that each selected RMCS matches the original design. Alternatively, 

after reviewing available contractor design changes or deviations from the 

original design, that the licensee/contractor has maintained the EQ of the 

selected RMCS requiring it as so indicated in the DCD or FSAR. 

Guidance. Direct observation of some EQ testing is preferred. In lieu of direct 

observation, records should be reviewed that report contractor inspection activities 

by the licensee. The licensee=s records should indicate that they performed audits 

at the contractor=s facility of EQ tests or analyses. All EQ equipment should be 

able to function for the worst-case environmental conditions for their locations in 

the plant. 

3. Digital systems and components like microprocessors have hardware and 

software QA and configuration management plans. 

Guidance. The selected RMCS should be assembled and handled in accordance 

with these plans. These plans should address the functional requirements, 

documentation and review, factory and installation tests, verification and validation, 

problem reporting and training for qualified equipment. These plans should state 

the controls put in place for the hardware and software for their entire life cycles 

from inception through factory testing and final shipment. The inspector is not 

doing a detailed design review, but a verification that these plans exist and address 

the appropriate requirements. The licensee=s records should indicate that they 

performed audits at the contractor=s facility and verified that the contractor followed 

a hardware and software QA plan, that factory testing was performed, and any 

failures of components were promptly resolved. The licensee=s records should 

indicate the results of those audits and any onsite reviews and whether the results 

were satisfactory. 

4. Assure that cleanliness requirements have been maintained or otherwise 

satisfied. 

Guidance. This is a manufacturing or assembly facility assessment. The 

cleanliness of a component should meet the construction specification or 

contractor=s manual and must be appropriate for its environment. This is especially 

true for digital instrumentation and any associated software and electronic 

components. The contractor installation records should indicate that the 

contractor=s requirements were met and if not the justification for not meeting them 

or how the licensee plans to meet those requirements. 

5. Verify that the contractor identified and controlled all nonconforming 

conditions. 

Guidance. All nonconforming conditions should result in the appropriate 
Issue Date: 10/20/08 6 65001.19 

documentation in accordance with licensee/contractor procedures and regulations 

in 10 CFR 21. All corrective actions must be reported and be in accordance with 

licensee/contractor procedures. 

b. In-Process Installation. 

1. The following licensee activities are controlled, inspected, and accomplished 

in accordance with the requirements of the procedures reviewed in 

accordance with IP 65001. 

2. Verify that the required identification is properly maintained or established for 

the selected RMCS. 

Guidance. The selected RMCS should be identified including panels, racks, and 

field mounted components. 

3. The latest approved revision of applicable construction specifications, 

drawings, and/or construction procedures are available and used by the 

installers. 

Guidance. Drawings, construction specifications, and procedures used in the field 

should be reviewed periodically to ensure that the most recent approved revisions 

are being used and that there are no missing or inappropriate approvals. The 

installation records should indicate that the latest approved revisions of the 

documents were used. 

4. Verify that the characteristics of the selected RMCS are as specified, such 

as type, range, EQ, SQ, and material. 

Guidance. The general information contained on the construction specification 

should be verified for each selected RMCS, and they should be qualified for the 

environment in which they are located during and following installation. Parts of 

this assessment can be verified by data in the construction specification or 

contractor manual. This applies to field-mounted and panel or rack-mounted 

components and to the panels and racks themselves. For EQ and SQ to be 

maintained, the installation should be bounded by the test reports or analyses. IN 

97-45 discussed how post-accident temperature transients inside containment 

could lead to thermal induced currents in safety-related cabling which could result 

in temporary, erratic readings from the containment radiation monitors. Assure that 

the equipment installed in the containment and other areas of the plant could 

respond as designed in the event of severe temperature transients. Even 

equipment designed for a non-harsh environment must be rated to function in that 

environment. In addition, instrumentation systems must have the appropriate 

ratings for their components, for example, surge withstand capability (SWC), 

electromagnetic interference (EMI), electrostatic discharge (ESD), and radio 

frequency interference (RFI). The FSAR should identify and describe all RMCS 

which must operate in a harsh environment defined by high radiation, temperature, 

pressure, vibration or humidity during or subsequent to an accident such as a loss 

of coolant accident (LOCA), or high energy-line break (HELB). Installation records 

should be used to indicate that the proper components were installed as indicated 
Issue Date: 10/20/08 7 65001.19 

on the design drawings and construction specifications. 

5. Verify that mounting hardware and supports are of the type and material 

specified and properly located in the plant. 

Guidance. The subject of anchorage and supports is pertinent to the equipment, 

racks, and panels for SQ and EQ equipment. For some of the supports and 

anchorages, the inspector should directly measure or otherwise independently 

verify that requirements pertaining to such items as location of equipment, location 

of supports, and bolt size are as specified. This activity is important to the as-built 

SQs for some instrumentation and should be clearly delineated in the installation 

documentation. The inspector may choose to not limit this inspection activity solely 

to the SQ and EQ equipment. For example, during installation of equipment, 

anchorage holes are sometimes drilled in concrete structures. Indiscriminate 

cutting of reinforcing steel should not be allowed. So although the inspector is 

reviewing RMCS, a broad review of the construction activities is always necessary. 

6. Verify that the selected RMCS are installed in the proper location and 

orientation by qualified craft personnel using suitable equipment and tools. 

Guidance. Use construction drawings and specifications, training records and 

visual verifications. The physical installation should have the necessary elements 

to facilitate monitoring of the plant specific effluents. Consideration should be 

clearly made for the physical characteristics of the sampling equipment for the 

effluent being sampled. For example, the contractor may specify limits on the 

number of 90 degree bends allowed in the sampling lines or require heat tracing to 

maintain the temperature of the sample in order to have proper sampling. 

7. Inspect selected RMCS after installation to ensure that they are adequately 

protected from damage by adjacent construction activities. 

Guidance. The damage could be inflicted by heat, water, power lines, falling 

equipment, etc. 

8. The corrective actions undertaken for problems identified during the 

installations of the selected RMCS should be effective. 

Guidance. The inspector should select 1 - 2 problems that are more significant 

than a missing screw or an improperly labeled component. The effectiveness of 

any corrective actions is determined by whether the problems are recurring or 

not. The licensee should determine the root causes of the problems, and the 

corrective actions should address the root causes not the problems themselves. 

 When the corrective actions are not effective, the inspector informs both the 

licensee and NRC management. The installation records should indicate what 

corrective actions were required for problems encountered during the 

installation of the RMCS. 

9. Review records to assure that nonconforming RMCS or conditions have 

been identified and controlled in accordance with approved procedures. 
Issue Date: 10/20/08 8 65001.19 

Guidance. The intent is to verify that nonconforming conditions are identified and 

result in the initiation of appropriate nonconformance documentation in accordance 

with 10 CFR 21. Where revisions are made, verify that they are in accordance with 

approved corrective action dispositions. The installation records should indicate 

any non conformances and how each was processed. 

10. The records of the in-process activities are in accordance with licensee 

procedures and NRC regulations. 

Guidance. The records should be all the installation records including those 

suggested in the guidance for the proceeding steps of the in-process work 

activities. 

c. Completed Work/As-Built

1. The following licensee activities are controlled, inspected, and accomplished 

in accordance with the requirements of the procedures reviewed in 

accordance with IP 65001. 

2. Review the as-built installations for the RMCS. 

Guidance. For as-built installations, including the Containment High Range 

monitoring equipment, Containment Atmosphere and Main Control Room 

monitoring equipment, and the remainder of the selected RMCS requiring SQ, as 

indicated by the DCD or FSAR, should still be seismically bounded by the tests or 

analyses of the licensee or contractor. The EQs of the selected RMCS as 

indicated in the DCD or FSAR should also still be bounded by their appropriate 

tests or analyses so that those qualifications are still maintained for their as-built 

installations. 

3. Verify that the selected RMCS and associated items maintain physical and 

electrical independence between redundant channels or systems. 

Guidance. IEEE Standard 279 requires channels that provide signals for the same 

protection function be independent and physically separated. This physical and 

electrical independence should be true for all redundant RMCS required for safety 

assessment and accident mitigation. This is for the components comprising the 

instrumentation channels within a Radiation Monitoring system. The inspector 

should determine how the contractor intended to meet this requirement and 

whether the as-built installation meets that requirement. This is not meant to be a 

validation of the design but whether the completed installation meets the design 

requirements. Electrical independence also includes being powered by the right 

power source. The installation records should indicate any deviation between the 

design basis and the as-built installation. 

4. Verify that displays on MCR panels and at other panels used by operators 

are mounted at the correct locations. 

Guidance. The displays should not only be mounted correctly but be functional in 

accordance with contractor specifications. ANSI N13.10 recommends alarms for 
Issue Date: 10/20/08 9 65001.19 

detection levels but also to alert operators of equipment inoperability. Additionally, 

the installation records of the licensee should indicate the results of this review. 

Depending on MCR designs and evolving digital technology, MCR readouts may 

not be dedicated components. 

5. Verify that the selected RMCS, in the completed installation, conform to 

elementary layouts of the systems. 

Guidance. This review is an expansion of the review for the selected components. 

This is a fundamental check that the system has the required types of inputs, 

outputs, displays, and controls. The installation records should indicate any 

deviations of the systems as installed from their elementary layouts. 

6. Verify that the correct RMCS have been used. Verify that they have been 

correctly and permanently identified. 

Guidance. Sometimes similar Radiation Monitoring components are put in identical 

cases. The inspector should determine that the RMCS inspected are as specified. 

 This can be done by observing the name plate for specific characteristics unique 

to that component and comparing them against the construction specification for 

that component. A component=s identification should be in agreement with 

construction drawings and specifications and be adequate for the location of the 

component. The installed instrument components should be uniquely identified on 

the component itself, the installation records, calibration records, and inspection 

records. For panel or rack-mounted components, the component may have its own 

identification but the panel or rack should also be identified. For a variety of 

reasons, the identification of components previously reviewed during the in-process 

installation inspections may have been disturbed. This is a final verification that the 

identification is still correct, and the installation records should indicate the 

components were identified per drawings and specifications. 

7. The records of the completed work and as-built activities are in accordance 

with licensee procedures and NRC regulations. 

Guidance. The records should be all the installation records including those 

suggested in the guidance for the proceeding steps of the completed work 

activities. 

d. Construction and Operational Testing. The inspector should observe construction 

and operational testing for some of the RMCS in the inspection sample by 

performing the following sub steps below: 

Guidance. This section combines construction and operational testing. The first is 

the preliminary testing to verify that components and systems are correctly installed 

and operational. Operational testing is a verification that components and systems 

operate in accordance with their design criteria. This section will not further 

segregate between the two, but the following steps will address both. 

1. The test activities, reviewed in the following sub-steps, should be controlled, 

inspected, and accomplished in accordance with the requirements of the 
Issue Date: 10/20/08 10 65001.19 

procedures reviewed in IP 65001. 

No specific guidance 

2. Test and calibration personnel adhere to any special handling or removal 

requirements. 

Guidance. Test and calibration personnel should be knowledgeable in the special 

care and handling that should be exercised when readying sensitive RMCS for 

testing. The inspector should be especially mindful of those injudicious actions that 

could cause the systems or components to operate in a manner uncharacteristic to 

their test specifications or design basis. 

3. The latest revisions of applicable procedures and/or specifications are 

available at the test location and used by personnel performing the testing 

and calibration. 

Guidance. The inspector should periodically check that the latest test procedure is 

being used during the test. The inspector should review the specified calibration 

requirements and procedures before observing these activities. If special 

requirements are specified, such as density compensation during liquid level 

instrument calibration, the inspector should determine whether those requirements 

are met. All testing should be in accordance with licensee commitments and 

manufacturer=s recommendations. 

4. Properly identified, traceable, and calibrated measuring and test equipment 

are used. 

Guidance. If calibration activities are in progress, determine whether the most 

recently approved calibration information is being used, and whether there is 

compliance with the required procedures. The values of instrument ranges and 

zero set points are sometimes changed after receipt of the instruments at the site. 

The inspector should assure himself (by selective sampling) that current data are 

used for checking and calibrating instruments, and that these changes are within 

the limits of the instrument components involved. 

5. RMCS are able to obtain the desired set point, degree of accuracy, and/or 

tolerance specified or otherwise noted. 

Guidance. As these inspection requirements cannot be done until testing and 

calibration activities are in progress, inspection in this area should be scheduled 

accordingly. For digital RMCS, the setpoints or tuning parameters embedded in 

the software should be treated like any other setpoint. A download of setpoints 

and coefficients by the licensee could be compared to RMCS requirements 

documentation. 

6. Required testing and calibration results are recorded during the activity, not 

after the work has been completed. 

Guidance. Final calibration and trip settings should be done during the final testing 
Issue Date: 10/20/08 11 65001.19 

of the system or component. 

7. The power, grounding, and shielding, if applicable, are in accordance with 

the design basis and NRC SER. 

Guidance. Test signals may be utilized to test if the systems and components are 

powered from the correct power division. Grounding and shielding of electronic 

and digital systems and components should be carefully addressed and be in 

accordance with the manufacturer=s recommendations. 

8. Automatic and manual actuations and responses of RMCS are per the 

design basis. 

Guidance. The following pertain to the responses of RMCS to either simulated or 

actual signals or inputs. Whether the signals are actual or simulated is not really 

pertinent to whether the RMCS perform in accordance with the design basis. The 

inspector can check for any of the following: 

(a) After the required input, RMCS actuate or inhibit process systems. 

(b) The manual actuation of process RMCS is performed from operator 

stations like the MCR or RS panels. 

(c) Safety-related displays provide the correct information. 

9. RMCS are adequately identified as having been tested or calibrated. 

Guidance. The licensee in some fashion should indicate what RMCS have been 

tested and whether there are outstanding concerns that could possibly invalidate 

the tests as conducted. 

10. Personnel performing the testing and calibration are properly qualified. 

Guidance. "Qualified test personnel" means those employees who have achieved 

suitable proficiency to do their assigned tasks by appropriate training and/or 

previous experience and who understand the test procedures, drawings, and 

specifications necessary for the testing to be conducted. 

65001.19-03 RESOURCE ESTIMATE 

This IP supports the review of RMCS for any reactor design. The resource estimate for this 

IP is approximately 240 hours of direct inspection effort each time this whole procedure is 

implemented. 

65001.19-04 REFERENCES 

ANSI N13.1-1969, Guide to sampling airborne radioactive materials in nuclear facilities 
Issue Date: 10/20/08 12 65001.19 

ANSI N13.10-1974, Specification and Performance of On-site Instrumentation for 

Continuously Monitoring Radioactivity in Effluents 

ANSI 41.28-1976, IEEE Standard Method for Identification of Documents Related to Class 

1E Equipment and Systems for Nuclear Power Generating Stations 

IEEE 279-1971 - Criteria for Protection Systems for Nuclear Power Generating Stations 

IEEE Standard 572-1985, Qualification of Class 1E Connection Assemblies for Nuclear 

Power Generating Stations 

IN 97-45, Environmental Qualification Deficiency For Cables and Containment Penetration 

Pigtails 

NSI/ANS 8.3-1997, Criticality Alarm 

NUREG-1211, Regulatory Analysis for Resolution of Unresolved Safety Issue A-46, 

Seismic Qualification of Equipment in Operating Plants 

Regulatory Guide 1.29, Seismic Design Classification, Revision 3 

Regulatory Guide 1.97, Criteria for accident monitoring instrumentation for nuclear power 

plants 

Regulatory Guide 1.156 Environmental Qualification of Connection Assemblies for Nuclear 

Power Plants 

END 

Attachment 1 – Revision History for IP 65001.19 
Issue Date: 10/20/08 Att1-1 

Attachment 1 

Revision History for 65001.19 

Commitment Tracking Number 

Issue Date Description of Change Training 

Needed 

Training Completion Date 

CoAc

N/A 10/20/08 

CN 08-029 

1. Initial issuance to support ITAAC related inspections under 10CFR52. 2. Researched commitments for 4 years and found none. 

None N/A N/A