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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 |