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Attachment A

Figure 1
Figure 1. Number of Citations and Cumulative Percentages, By PSM Element

Figure 2
Figure 2. Number of Citations and Cumulative Percentages, By PSM Sub-Element

Figure 2 graphs the 33 PSM sub-elements that collectively have accounted for 80% of the citations proposed to date. The 18 top sub-elements, accounting for over 50% of all citations to date, are:

  Description   Description
j(5) Equipment deficiencies e(3)(v) PHA - facility siting
d(3)(ii) Equipment RAGAGEP f(1) Written operating procedures
e(5) PHAs not promptly addressed f(3) Procedure review & certification
l(1) Management of change procedures o(1) Compliance audit performance
d(3)(i)(B) P&IDs o(4) Compliance audit response
j(2) Written MI procedures d(3)(i)(D) Relief system design & design basis
f(1)(i)(D) Procedures - emergency shutdown f(1)(i)(E) Procedures - emergency operations
j(4)(i) Equipment inspection and testing f(4) Safe work practices
j(4)(iv) Inspection & test documentation g(1)(i) Initial training