**NRC INSPECTION MANUAL**		NMSS/FCSS

INSPECTION PROCEDURE 88025

MAINTENANCE AND SURVEILLANCE OF SAFETY CONTROLS

Issue Date:  XX/XX/XX	1	88025

PROGRAM APPLICABILITY:  2600

88025-01 	INSPECTION OBJECTIVE. 

The objectives of this procedure are to determine whether:

01.01		Maintenance and surveillance activities for items relied on for safety (IROFS) and other safety controls are adequate to assure that IROFS and controls are 

available and reliable to perform their safety function when needed, and for Part 70 licensees, to comply with the performance requirements of Title 10 of the *Code of Fedral Regulations* (10 CFR) 70.61;

01.02		Effective corrective actions are taken when a safety control (and IROFS for Part 70 licensees) fails or has degraded; and

01.03		Maintenance and surveillance activities are in accordance with license or 

certificate requirements.

88025-02	 	INSPECTION REQUIREMENTS AND INSPECTION GUIDANCE.

NOTE:  The inspection requirements of this procedure are those tasks that must be performed to complete the inspection.  Inspection planning is a key element of 

performing a thorough and meaningful inspection.  Inspection plans must be developed and approved prior to the start of the inspection and must consider the safety 

significance of the items to be inspected.  Deviation from the approved inspection plan must be discussed with the inspection supervisor as soon as practicable.  Guidance on inspection planning can be found in Manual Chapter 2600, Fuel Cycle Facility 

Operational Safety and Safeguards Inspection Program.

NOTE FOR SELECTION OF MAINTENANCE ACTIVITIES:  In preparation for the inspection, the inspector should discuss with the project inspector, resident inspector, and project manager any safety equipment  availability or reliability problems (such as recurring failures or failures resulting in reportable events) the licensee or certificate holder has been experiencing.  In addition, the inspector should discuss facility 

operations to ensure a sampling of risk significant maintenance tasks and operations are evaluated, even if reliability has not been a concern.  Select from this list the 

controls for the more risk-significant operations to review during the inspection.  In addition, once on site, the inspector should initially determine what maintenance and surveillance activities of safety controls or IROFS are scheduled to be performed by the licensee or certificate holder during the period of the inspection.  From this, the 

inspector should select a sample of maintenance and surveillance activities for

risk-significant operations to observe during the inspection.  The inspector should use the integrated safety analyses (ISAs) Summary or other safety analysis to determine the risk-significant operations.  In addition, the inspector should consider inspecting a small sample of non-IROFS related maintenance to verify that the maintenance 

Issue Date:  01/23/14	1	88025

program is adequately implemented throughout the facility and is not only effective for IROFS-specific maintenance.  

Inform a licensee representative that you would like to be kept informed of any change in the schedule of these maintenance or surveillance activities to assure that an inspector observes them.

02.01	Maintenance Implementation.  

a.	Inspection Requirement.  For selected maintenance activities, review the selected action, including observation of ongoing activities where possible.

1. Work control procedures.  Determine whether work control procedures were adequately implemented to assure adequate review and approval of proposed work, including a maintenance work order.

2. Pre-job planning.  Determine the adequacy of pre-job planning where required by the license or certificate.

3. Work package.  Determine the adequacy of work packages (work request, maintenance procedure, tag-out, etc.) prepared for maintenance activities and whether licensee or certificate holder procedures were followed.

4. Maintenance observations.  Determine whether maintenance work activities on selected systems and processes are conducted according with the licensee or certificate holder’s requirements and procedures.

5. Post-maintenance testing.  Determine whether appropriate post-maintenance testing and calibrations, as specified by license or certificate requirements 

ISAs, licensee or certificate holder procedures, etc.), are performed prior to 

returning the component or system to operational status.

6. Completed work package.  Determine whether requirements for reviewing the completed maintenance activities by maintenance, engineering, or operations supervision are being adequately met prior to returning equipment to service.

b.	Inspection Guidance.  

1. Work control procedures.  Work control procedures usually require the use of a “work order” or similar document.  Administrative control procedures should 

define the review and approval sequence for this document and require that maintenance activities on safety controls or IROFS, or in the proximity of critical or vital equipment, be performed under the work order system.  Work orders might include the following elements:

(a) Identification of work activity,

(b) Work group(s) involved,

Issue Date:  01/23/14	2	88025

(c) Foreman in charge,

(d) Ignition source controls,

(e) Fire watch requirements,

(f) Special work controls,

(g) Maintenance supervision approval signature,

(h) Operating staff review signature, and

(i) Operations supervision approval signature,	

Troubleshooting.  Licensee or certificate holders might be required to have 

procedures for controlling troubleshooting activities such as removing and 

returning equipment to service, use of lifted leads and jumpers, and post activity testing.  Although a licensee or certificate holder could have a procedure that 

addresses the general plan of the troubleshooting activity, it is not always 

necessary that all of the steps performed as part of a troubleshooting activity be defined in a step-by-step procedure.  However, documentation of troubleshooting activities for safety controls or IROFS should provide evidence that the activity was performed properly.

Also ensure that the licensee or certificate holder is not using troubleshooting to circumvent the requirements of the standing maintenance procedures and 

policies, nor is troubleshooting being used as means to implement a work-around for a problem instead of repairing it.

2. Pre-job planning.  For complex corrective maintenance activities, recurring 

failures, or failures resulting in reportable events, evaluate the adequacy of 

pre-job planning by reviewing available records or questioning responsible 

licensee personnel to determine if the licensee performed the following pre-job planning activities: 

(a) Reviewed plant machinery history or industry operating data for similar equipment failures.

(b) Reviewed vendor technical manuals and incorporate appropriate vendor recommendations into maintenance procedures.

(c) Obtained engineering support, when needed, to address complex 

maintenance issues.

(d) Prepared written procedures, where necessary, to perform complex maintenance activities.

Issue Date:  01/23/14	3	88025

(e) Reviewed post-maintenance and/or post-modification system test 

alignments and control for exiting those alignments.

(f) Used formal root-cause analysis methods, as necessary, to identify the causes of maintenance failures.

(g) Identified special skills or qualifications, special tools and equipment, or spare parts needed to perform the maintenance activity.

(h) Assessed the IROFS out of service to determine the overall effect on 

safety of performing the planned maintenance activity, as applicable.

(i) Inspectors should check that newly installed parts are replaced as a 

like-for-like or that appropriate design change evaluations are available. 

3. Work package.  Determine if the work package (work request, maintenance procedure, tag-out, etc.) prepared for the maintenance activity addressed the 

elements listed below that are required by licensee or certificate holders 

procedure.  (Note that all the below elements might not be required in each 

licensee or certificate holders program.)

(a) The procedure conforms to the licensee or certificate holder’s 

administra-tive requirements for format, approval, and control. 

(b) The procedure conforms to the licensee or certificate holder’s 

administrative requirements for format, approval, and control.

(c) The procedure addresses the interface activities associated with the maintenance/repair/replacement of a component such as lockout/tagout, removing a component from service, process line breaks, radiation work permits, release from operations, equipment status control, return to 

service, and post-maintenance testing.

(d) Inspection hold points, independent verification points, or appropriate peer reviews are identified in the procedure or in a documented plan and are appropriate for the activity.

(e) Supplementary reference materials, such as drawings and technical 

manuals, are adequate, controlled, and up to date.

(f) The work activities are described in a level of detail that is commensurate with the complexity of the maintenance activity.  Skills normally possessed by qualified maintenance personnel may not require detailed stepbystep procedures for simple tasks.

Issue Date:  01/23/14	4	88025

(g) Consideration is given to cleanliness requirements and personnel hazards such as chemical, radiological, temperature, pressure, and electrical 

hazards.

(h) Provisions for fire protection and security are included.  Work involving welding, open flame, or other ignition sources, should require:  (1) special authorization; (2) a special survey or evaluation of the proposed work area to identify nearby flammable material, vital cable runs, critical process equipment, etc.; and (3) a fire watch.  If the maintenance activity is to be performed in the proximity of flammable material, vital cable runs, etc., the fire watch should have the capability of communicating with the 

appropriate organization (process control area, fire brigade).  The 

individual performing the fire watch should know what actions to take in the event of a problem.

(i) Instructions and quality control checks are included to verify that 

environmentally qualified (EQ) equipment is properly protected against moisture intrusion when reassembled and that proper EQ material, 

especially elastomers, have been installed.

(j) Provisions for control of equipment, including lifted leads, jumpers, 

bypasses, and mechanical blocks are included.

(k) Interfacing activities with the operations/production and safety/health 

physics personnel are verified.  Where applicable, safe work procedures, job hazard analysis, and/or radiological, nuclear criticality safety (NCS), or chemical hazards should be referenced. 

(l) Provisions for obtaining formal approval from operations are included, as well as methods for notifying operations when affected systems are 

removed from service, ready to be restored to normal service, or if 

problems are encountered.

(m) Provisions for material, parts, and tool accountability to ensure loose items are not inadvertently left inside equipment after the work is complete.

(n) Provisions for procedure or standard task prerequisites, such as scaffold engineering evaluations and requests, breach of fire/air/radiation barriers, and radiation protection requirements, are included.

(o) Replacement parts for a given job will be properly controlled and identified for its end-use.

4. Maintenance Observations.  For the maintenance activities selected, determine whether: 

Issue Date:  01/23/14	5	88025

(a) Maintenance personnel assigned understand the scope of the task and are familiar with the procedures.

(b) Up-to-date written procedures are being implemented in the field and that steps in the procedures are carried out sequentially, unless otherwise specified.

(c) Applicable parts of the work package are satisfied for the work in progress.

(d) The maintenance personnel are qualified for their respective tasks.

(e) Supervisory oversight of the work is adequate.

(f) Quality Control (QC) personnel assigned are knowledgeable of the task.

(g) Apparent cause of failure appears to be addressed by appropriate 

corrective action, including measures to prevent recurrence.

(h) Appropriate health physics support is available.

5. Post-maintenance testing (PMT).  Procedure contents should normally include testing provisions following maintenance.  Written procedures should be 

available for performing maintenance, calibration, and surveillance requirements for safety controls, including where applicable, NCS control systems and IROFS identified in the ISAs.  There should be records to confirm that the work was performed.  For each testing activity selected, identify the affected systems and/or components and review the following:

(a) The applicable licensing-basis and/or design-basis documents to identify the safety functions of the affected systems and/or components.

(b) The associated maintenance activity to identify the safety functions that may have been affected by that activity.

(c) The licensee’s or certificate holder’s test procedure to determine whether the procedure adequately tests the safety functions affected by the maintenance activity.  Determine whether the acceptance criteria in the procedure is consistent with information in the applicable licensing-basis and/or design-basis documents.  Determine whether the procedure has been properly reviewed and approved.

(d) Either witness the test and/or review the test data, to determine whether:

(1) The performance of the affected systems and/or components satisfy the procedure’s acceptance criteria.

(2) The effects of testing on the plant have been adequately addressed.

Issue Date:  01/23/14	6	88025

(3) The measuring and test equipment (M&TE) is calibrated and is 

within its current calibration cycle.

(4) The M&TE is within its required range and accuracy.

(5) The applicable prerequisites described in the test procedure are 

satisfied.

(6) The affected systems or components are removed from service in accordance with approved procedures.

(7) The test is performed in accordance with the test procedure and other applicable procedures.

(8) Any lifted leads or jumpers, both electrical and pneumatic, are 

controlled and restored.

(9) The test data/results are accurate, complete, and valid.

(10) The test equipment is removed after testing.

(11) After completion of testing, equipment is returned to the 

positions/status required to maintain the system operable in 

accordance with the current operating mode using approved 

procedures.

(12) Any problems noted during testing are appropriately documented.

Note:  Licensee or certificate holder PMT is often conducted by 

performing a related, existing surveillance procedure for operability 

determination.  Inspectors should assure that the testing performed not 

only provides a snapshot of the safety controls’ or IROFS’ operability, but actually evaluates the adequacy of the maintenance or repairs to the 

controls being tested.

Note:  As a minimum, perform a review of the completed test procedure and the recorded data.  However, where possible, the inspector should 

also attend the pre-job briefing, witness the test when it is performed, and attend any post-test critiques, as applicable.

6. Completed work package.  Determine whether the maintenance activities are reviewed by maintenance, engineering, or operations supervision upon 

	completion prior to returning equipment to service PMT.

Issue Date:  01/23/14	7	88025

02.02	Surveillance and Calibration Testing Implementation.  

a.	Inspection Requirement.  For the surveillance testing activities selected in Section 02.01 above, review the selected test and/or calibrations, including observation of ongoing activities where possible.

1. Surveillance.  Determine whether surveillance tests are conducted according to the procedures and at the required frequency.

2. Calibrations.  Determine whether calibrations are conducted according to the frequency, requirements, and procedures.

3. Criticality Alarm Monitoring Systems.  Determine whether the criticality safety monitoring system is tested and calibrated as required by license or certificate requirements.

b.	Inspection Guidance.  

1. Surveillance.  The license or certificate, licensee or certificate holder procedures, or the ISA will specify which safety controls require periodic surveillance tests.  The risk-significance of particular IROFS and NCS controls is specified in the ISA.  For Part 70 licensees, these surveillance tests and calibrations are to verify that IROFS are available and reliable to perform their function when needed.

Procedures should be developed, reviewed, and approved under the licensee’s or certificate holder's procedural control system.  The procedures should specify:

(a) Prerequisites and preparation for the test.

(b) Functional tests of instruments in conducting the surveillance test.

(c) Acceptance criteria.

(d) Operational checks to be made before returning equipment to service.

(e) Deficiency reports documented for failures.

Examine those procedures related to the tests selected for observation.  

Determine whether surveillance tests required by the license or certificate are conducted using properly approved procedures.

Examine the technical content of procedures for the selected surveillances to 

determine that satisfactory tests will be conducted.  The objective is to determine whether the procedure will satisfy the applicable license or certificate requirement or will demonstrate that IROFS are available and reliable.  The surveillance

requirement and the bases of the license or certificate requirements, or 

description in the safety analysis report or the application, should be used to aid in this determination.  Examine the procedure and checkoff sheets to determine 

Issue Date:  01/23/14	8	88025

if valve lineup, or other similar requirements, are correct for the test activity and the return of the component or system to service.

Determine whether, for tests selected above, that test results conform with 

license or certificate requirements, and that test results have been reviewed and approved by appropriate supervision.  The test results should be reviewed and approved by someone other than the person performing the test or the person 

directing the test.

Other significant surveillance test attributes for consideration include the 

following:

(a) Preconditioning does not occur.

(b) Effect of testing on the plant has been adequately addressed by control room and/or engineering personnel.

(c) Acceptance criteria is clear and demonstrates operational readiness and is consistent with the supporting design calculations and other licensing 

documents.

(d) M&TE range and accuracy are consistent with the application and has 

current calibration.  Verify the plant equipment calibration is correct, 

accurate, properly documented, and the calibration frequency is in 

accordance with licensee or certificate holder procedures and 

commitments.

(e) Test is performed in sequence and in accordance with written procedure.

(f) Jumpers installed or leads lifted during testing are properly controlled.

(g) Test data is complete, verified, and meets procedure requirements.

(h) Test frequency was adequate to demonstrate operability (meets license or procedure requirements), and reliability.

(i) Test equipment is removed after testing.

(j) After completion of testing, equipment is returned to the positions/status required for the performance of its safety function.

(k) For test results that do not meet the acceptance criteria, results of an 

adequate operability determination are acceptable.

(l) For selected safety related instrumentation and control surveillance test verify that reference setting data has been accurately incorporated to the test procedure.

Issue Date:  01/23/14	9	88025

2. Calibrations.  

Determine whether calibrations are performed at the required frequency for 

safety controls and IROFS.  During the review of calibration procedures and 

calibration records determine whether provisions are included to acknowledge that applicable license or certificate requirements for limiting conditions for 

operation are in effect.  Determine whether the service status of the system was in conformance with the applicable limiting conditions of operation specified in 

license or certificate requirements.  Examine the technical content of procedures for the selected calibrations to determine that satisfactory calibration of 

monitoring components will result.  In the review of procedures, look at a sample of stepwise instructions to determine if the following considerations have been included:

(a) Appropriate signal compensations are included,

(b) Point of signal insertion is specified,

(c) Calibrations are appropriate to the range and use of equipment.

Determine whether procedures used to calibrate the monitoring component 

selected contain:

(a) Review and approval requirements of license/certificate conditions,

(b) Acceptance values for trip settings that conform to license/certificate 

requirements, 

(c) Detailed stepwise instructions, and

(d) Deficiency reports documented for out-of-tolerances.

The objective is to determine whether the procedure will satisfy applicable 

license or certificate requirements.  The surveillance requirements and the bases of the license or certificate requirements, or description in the safety analysis 

report or the application, should be used to aid in this determination.  Examine the procedure and checkoff sheets to determine if valve lineup, or other similar requirements, appear correct for the calibration activity and the return of the component to service.

During the review of raw data calibration records, determine whether "asfoundsettings" are also recorded.  Determine whether trip points of 

components selected conform to applicable license/certificate requirements.

Review the qualifications of individuals having responsibility for performing 

calibrations against the licensee or certificate holder requirements and the 

company policy regarding personnel qualification requirements.  

Issue Date:  01/23/14	10	88025

For gauges, instruments, or other measuring/testing devices used as primary standards in the calibration of plant equipment, determine whether:

(a) Accuracy is traceable to the National Bureau of Standards or other 

independent testing organization.

(b) Storage and control of the selected devices is proper.

(c) Information tagged on the testing equipment conforms to that in calibration records.

(d) The M&TE was in calibration at the time of use.

(e) The M&TE is calibrated against standards that have an accuracy that is better than or equal to the instrument being calibrated.

3. Criticality Alarm Monitoring Systems.  By observation, discussion, and document review, determine whether the system is designed to permit component and 

system operability testing periodically and after maintenance.  Determine 

whether maintenance and testing of the entire alarm system are done and that such tests are announced.

The criticality accident alarm system is expected to be designed to permit 

component and system operability testing periodically and after maintenance.  The licensee or certificate holder is expected to have procedures in place to 

require tests and checks equivalent to the initial installation tests following 

significant modification or repair to the system.

Determine by observation, discussion, and document review that the audibility of the criticality alarm signal was above background noise level, as specified in 

applicable American National Standards Institute (ANSI) standards or other 

regulatory requirements, throughout all areas to be evacuated or that other 

signals, such as lights or beacons, provide operator warning.

All tests and corrective actions should be recorded.  Maintenance, surveillance, and test records for the alarm system are expected to be maintained.

02.03	Audits.

a. Inspection Requirements.  Verify that the licensee or certificate holder has conducted audits or self assessments in the area of maintenance and surveillance and is in 

compliance with license requirements, if applicable.

b.	Inspection Guidance.  Determine if licensee/certificate holder is required to conduct audits or self assessments.  Select internal or contracted audits performed since the previous inspection, and examine the records documenting selected audits to 

Issue Date:  01/23/14	11	88025

determine whether there was a written plan for the audit, the audit adequately reviewed the audited area, appropriate corrective actions were taken whenever deficiencies were found, and whether there was a check of the effectiveness of the corrective action.

Determine by interviewing the licensee or certificate holder representatives, how the licensee or certificate holder assures the effectiveness of audits, such as by use of contractor audits, use of a secondary (or follow-up) audit system on a periodic basis, conducted by a member of management or a senior technician not directly responsible for the system audited.

Determine if safety-significant audit findings are being tracked through completion by the corrective action program, if required. 

02.04	Training.

a. Inspection Requirements.  Review training in the area of maintenance and surveillance and evaluate if training is in compliance with license or certificate requirements.

b. Inspection Guidance.  Review area specific training to ensure that the following topics are included, as appropriate:

1. IROFS, process safety information elements (such as safety and health hazards, relevant material safety data sheets, personal protective equipment, etc.)

2. Safe work practices (such as confined space entry, lockout/tagout procedures, opening process equipment, hot work, control of entry into hazardous areas, etc.)

3. Process technology (as required).

4. Operating procedures for all phases of operation.

5. Emergency procedures (such as Hazard Waste Operations and Emergency Response).

6. Reporting unusual events or non-routine operations.

NOTE:  On-the-job training should, as a minimum, include: equipment 

familiarization, completing log sheets, equipment startup/shutdown activities,

limiting operating conditions, control of process variables, and applying operating procedures in the field.

02.05	Organizational Structure. 

a. Inspection Requirements.  Evaluate if a change occurred in the maintenance and surveillance program organization that is applicable to the position-specific 

requirements of the license or certificate.  If applicable, verify that the new manager or staff member meets the criteria of the license or certificate requirements.

Issue Date:  01/23/14	12	88025

Verify that any changes to the organizational structure in the area of maintenance and surveillance are in compliance with license requirements, if applicable.

b. Inspection Guidance.  By discussions with licensee or certificate holder staff and management, and review of documentation, determine whether the licensee or 

certificate holder's organizational structure is in accordance with the license or 

certificate.  By discussions with selected licensee or certificate holder managers who are new to their positions since the last inspection, and where appropriate, review of 

documentation, determine whether these managers meet the training and experience requirements for their positions as specified in the license or certificate.

Focus on whether the qualifications of involved plant staff meet the requirements of the license or certificate, including years of relevant experience, educational background, and training required for the newly assigned responsibilities.

Examine changes in organization and organizational structure  regarding changes in personnel, qualifications of personnel, functions, responsibilities, and/ or authorities.

If no significant changes have occurred in the organization since the previous 

inspection, then limit time spent on this section. 

02.06		Maintenance Problem Identification and Resolution.  

a.	Inspection Requirement.  

	Determine whether the licensee or certificate holder is identifying safety control or IROFS maintenance or surveillance problems at an appropriate threshold and entering them into the corrective action program.  Determine, for selected licensee or certificate holder identified items, whether effective corrective actions have been taken.

	Some fuel facilities conduct annual maintenance outages or otherwise schedule planned outages on a periodic basis.  Inspection activities should be scheduled to coordinate with licensee planned outages whenever possible.  This maximizes opportunities to observe maintenance work activities performed in the field and the subsequent surveillance activities for safety controls or IROFS as they are returned to service after maintenance.  Under these circumstances the licensee should be contacted several weeks ahead of the scheduled outage to ensure proper understanding of the outage scope.  It is 

important to understand the nature of the outage in order to determine the scope of maintenance activities and IROFS work that may be available for inspection during the outage period.

b.	Inspection Guidance.  

As it relates to maintenance and surveillance, select a sample of problems documented by the licensee or certificate holder and determine whether the corrective actions were timely and appropriate.  Also, determine whether the licensee or certificate holder has an information tracking and trending system for the availability and reliability of safety 

Issue Date:  01/23/14	13	88025

controls and IROFS.  Determine whether the licensee utilizes such a system to perform preventative maintenance for risk significant safety equipment.  Review the records of safety controls or IROFS that have degraded or declined in performance over time.  Review the licensee or certificate holder’s identification of the causes of the problems and the maintenance and/or surveillance actions taken for corrective action.

Part 70 licensees are required to maintain records of IROFS or management measures that have failed to perform their function upon demand or have degraded such that the performance requirements are not satisfied.  These records should be readily retrievable and inspected.  These records should identify the IROFS or management measure that has failed and the safety function affected, the date of discovery, date (or estimated date) of the failure, duration (or estimated duration) of the time that the item was unable to perform its function, any other affected IROFS or management measures and their safety function, affected processes, cause of the failure, whether the failure was in the context of the performance requirements or upon demand or both, and any corrective or compensatory action that was taken.  A failure should be recorded at the time of 

discovery and the record of that failure updated promptly upon the conclusion of each failure investigation of an IROFS or management measure.  (10 CFR Part 70.62(a)(3)).

88025-03 	RESOURCE ESTIMATE

The resource estimate to perform this inspection procedure is estimated to be 30 hours. 

88025-04 	REFERENCES

Inspection Manual Chapter 2600, “Fuel Cycle Facility Operational Safety and Safeguards Inspection Program.”

Center for Chemical Process Safety, “Guidelines for the Technical Management of Chemical Process Safety, American Institute of Chemical Engineers,” New York, 1989, Chapter 8, Process and Equipment Integrity, pp. 85 - 97

Center for Chemical Process Safety, “Plant Guidelines for Technical Management of Chemical Process Safety, American Institute of Chemical Engineers,” New York, 1992, Chapter 8, Process and Equipment Integrity, pp. 149 - 198 

U.S. *Code of Federal Regulations*, “Domestic Licensing of Special Nuclear Material,” 10 CFR Part 70, Section 61, “Performance Requirements”

Occupational Safety and Health Administration (OSHA,) “Process Safety Management of Highly Hazardous Chemicals,” 29 CFR 1910.119 (j), "Mechanical Integrity"

Issue Date:  01/23/14	14	88025

88025-05	 	PROCEDURE COMPLETION

Implementation of each applicable inspection requirement will constitute completion of this procedure.  Individual inspection samples and breadth of review will be determined by the inspector based on requirement compliance, risk- significance of activity, and extent of the activity or records available.

END

Attachment:

  Revision History for IP 88025

Issue Date:  01/23/14	15	88025

REVISION HISTORY FOR IP 88025

Issue Date:  01/23/14                                                      Att1-1						88025