Prompt Evaluation of the IRRS Mission to the Czech …gnssn.iaea.org/NSNI/Shared Documents/OPEN Shared Files... · Web viewThe team members are requested to offer their opinions on

LUX, Ivan

IAEA

12/20/2013

2013Prompt Evaluation of the IRRS Mission to the Czech Republic

Prompt Evaluation of the IRRS mission to the Czech Republic Page | 1

Table of Contents1. Introduction...............................................................................................................................2

2. Basic Mission Data.....................................................................................................................2

3. Feedback from the Team Members on the Advance Reference Material of the IRRS Mission..2

Characteristic additional comments..............................................................................................3

Further specific remarks................................................................................................................3

General conclusions.......................................................................................................................3

4. Feedback from the Team Members on the Effectiveness of the Mission..................................3

Characteristic additional comments..............................................................................................4

Further specific remarks................................................................................................................4


5. Feedback from the Host Country on the Effectiveness of the Mission......................................5


6. Overall Evaluation of the Effectiveness and Efficiency of the Mission.......................................6

Discussion and conclusions............................................................................................................8

7. Summary....................................................................................................................................8

Appendix 1: Module-wise Coverage in the Mission Report...............................................................9

Appendix 2: Module-wise Coverage of the Action Plan...................................................................12


1. Introduction

The Contribution Agreement ENER/11/NUCL/SI2.588650 between the European Atomic Energy Community (represented by the European Commission) and the IAEA among others foresees as an expected result a performance monitoring based on the evaluation of some key performance indicators of the IRRS missions.

The Nuclear Safety Action Plan of the IAEA has as one of its main objectives the requirement to “Strengthen IAEA peer reviews in order to maximize the benefits to Member States” and in specific, it calls the IAEA Secretariat to review the effectiveness of the IRRS peer reviews.

In reply to these requirements a system of performance indicators have been elaborated in order to measure the efficiency and effectiveness of the IRRS missions. Some of the performance indicators are based on direct feedbacks from the IRRS team members and from the representatives of the country hosting the IRRS mission.

Results of and conclusions from the feedbacks and efficiency and effectiveness evaluations are given in the present Prompt Evaluation Report.

2. Basic Mission Data

Host country: Czech RepublicHost organization: State Office for Nuclear SafetyMission date: 18 to 29 November 2013Team Leader: Derek Lacey (UK)Deputy Team: Peter Johnston (AUS) Team Coordinator: Adriana Nicic (IAEA-NSNI)Deputy Team Coordinator: Ibrahim Shadad (IAEA-NSRW)Number of external experts: 19Number of IAEA staff: 6Number of observers: 1Mission type: full scopeScope of the mission:

Core modules (No. 1 through 10) Facilities and activities: NPP, research reactors, fuel cycle facilities, radioactive waste

facilities, radioactive sources facilities, decommissioning activities, transport activities Additional areas (Module 11): control of medical exposures; occupational radiation

protection; control of discharges, materials for clearance and chronic exposures, environmental monitoring for public radiation protection

Fukushima module Policy issues: (1) Governance issues related to the establishment of a Commission, (2)

Transparency

3. Feedback from the Team Members on the Advance Reference Material of the IRRS Mission

The Advance Reference Material (ARM) normally includes the results of the self-assessment of the host country (usually performed with the aid of the Self-Assessment Tool – SARIS); the Action Plan for improvement in issues found in the self-assessment, a module-wise summary of the status and activity of the regulatory body reviewed and a number of other documents needed for an objective and well informed peer review.

The team members are requested to offer their opinions on the quality of the ARM by rating from 1 to 5 (5 reflecting the highest satisfaction) three questions and also expanding in free text their


comments on the questions. The questions and the average values of the team members’ ratings are given below:

No. Question Average markQr1 How complete do you consider the ARM? 3.7

Qr2 How realistic picture could you obtain on the area you will be reviewing from the ARM?

3.7

Qr3 What is your overall evaluation on the quality of the ARM? 3.6

Total average 3.7

Characteristic additional comments

Qr1: The stated compliance with requirements were not always supported by evidence The regulatory guide and the management system related topics were missing from the

English textQr2:

Some parts of the ARM were available too late The document often described what the host country wished to reach not what the situation

was Certain areas were described quite realistically, in other cases the general picture was not

supported by specific examplesQr3:

The ARM was burdened by translation errors The general quality was good, however, certain questions were answered in very generic

manner The number of Q/A’s were very different in different modules

Further specific remarks

The IRRS module structure is not always followed in the SARIS Questionnaires The draft of the new Atomic Act would have been useful to see The ARM was changing for too long and it is not user friendly Notification of the team members on the change in the ARM would be necessary The ARM and the mission report template should be consistent with each other The ARM should contain specific examples of compliance

General conclusions

1) The ARM contained the necessary generic information, yet specific examples supporting stated compliance with requirements were missing

2) Structure and management of the ARM need revision to turn it more user friendly3) The SARIS Questionnaires and the Report Template need to be revised for consistency

4. Feedback from the Team Members on the Effectiveness of the Mission

The team members are requested to offer their opinions on the effectiveness of the mission by rating from 1 to 5 (5 reflecting the highest satisfaction) five questions and also expanding in free text their comments on the questions. The questions and the average values of the team members’ ratings are given below:

No. Question Average markQt1 How effective do you consider the activity of the expert team during the

mission?4.2

Qt2 How effective do you consider the activity of the IAEA staff in the team 4.2


during the missionQt3 How effective do you consider the activity of the Team Leader? 4.6

Qt4 How effective do you consider the activity of the Deputy Team Leader? 4.5

Qt5 How satisfied are you with the preparations of the mission (enough time for preparing yourself, information provided by the IAEA, etc.)?

4.1

Total average 4.3

Characteristic additional comments

Qt1:

The team was very effective, had good spirit and possessed ample experience More time should have been available for interviews at the beginning of the mission.

Qt2:

The IAEA staff was very helpful, committed and provided practical guidance and assistance The administrative support was highly appreciated

Qt3:

The team leader was effective, and has shown strong leadership He was clear in his expectations, focused on relevant topics, good time management,

excellent coordination The team was guided too fast through the findings, more discussion would have been

necessary

Qt4:

He did his job well, demonstrated excellent individual expertise He was supportive, active and constructive The role of the DTL is not fully clear. He should have spent more time on the general

consistency of the report

Qt5:

The mission was prepared very well, all information provided by IAEA was timely, yet some parts of the ARM was updated late

There was not enough guidance for a first time participant Information and preparations from IAEA were perfect, the Nucleus based access was a good

idea The team administrator provided good support


Cross-reading should be extended More time would be needed for interviews and discussions with the counterparts and also

for group-discussions Use of examples is recommended Working in groups is very effective, this should also be followed when discussing with

counterparts

General conclusions

1) All members and leaders of the team were rather effective and did a great job2) Support from IAEA staff was appreciated3) The mission schedule needs refinement to provide more time for interviews, group

discussions and for good balance in discussing findings and the report


5. Feedback from the Host Country on the Effectiveness of the Mission

The Liaison Officer of the host country is requested to offer the opinion of the host on the effectiveness of the mission by rating from 1 to 5 (5 reflecting the highest satisfaction) seven questions and also expanding in free text their comments on the questions. The questions, the host country’s ratings and the associated comments are given below:

No. Question MarkQh1 How effective do you consider the mission in assisting the continuous

improvement of nuclear safety in your country?Comment: The IRRS mission can be a significant stimulus to further improvement of national nuclear safety policy. Exchange of views and knowledge always helps to improve because the view from the outside brings a slightly different perspective on each issue.

4.0

Qh2 How objective was the peer review?Comment: The peer review was very objective, yet some members of the team IRRS tried to apply their experience from their own country as the good way.

4.4

Qh3 How has the mission helped the exchange of information, experience and good practice with other countries?Comment: The IRRS mission is useful for the international exchange of information. On the other hand reviewers should avoid favouring their national approach.

4.0

Qh4 How consistent was the use of the IAEA safety requirements and guides in the mission?Comment: Using the IAEA safety requirements was not very consistent.

3.9

Qh5 How justified are the findings of the peer review?Comment: The findings are fully justified. Conclusions time differences correspond to the period covered by the legislation of the Czech Republic and the current recommendations of the IAEA.

4.2

Qh6 How relevant are the findings of the peer review for the future development of your regulatory body?Comment: The findings are clearly defined and relevant. Findings will be used in the creation of new implementing regulations for the new Atomic Act.

4.4

Qh7 How competent were the reviewers in their review and findings?Comment: The IRRS team was generally competent but some reviewers should come better prepared.

4.5

Average 4.1


The IAEA self-assessment tool (SARIS) should be modified. The current version does not reflect a graded approach. E.g., there are hundreds of questions in the modules for research reactors, transport, radwaste and much less focus is given to the modules on NPPs. The Module 10 questionnaire is very robust, very detailed, many items are repeated.

Interpretation of IAEA Safety Requirements and guidance on their possible implementation in the relevant Czech legislation would have been welcome.

Certain findings were somewhat formal and will not add improvements to the otherwise working system.

Discussion of the mission findings on a plenary session was missed, although there has not always been full consensus between the reviewers and their counterparts.


General conclusions

1) The purpose of the mission was acknowledged by the hosts2) The review was considered sufficiently objective, the findings were accepted as realistic, the

reviewers were judged generally competent3) Reviewers should not take their national practice as basis for comparison in peer review4) Plenary discussion of the final report is necessary5) SARIS questionnaires need further revision

6. Overall Evaluation of the Effectiveness and Efficiency of the MissionThe Performance Indicators developed for the measurement of the effectiveness and efficiency of an IRRS mission were evaluated in the extent as it was made possible by the data available at the time of the present evaluation.

In the next figure the values of the performance indicators as they follow from the evaluation of the mission data1, as well as the overall effectiveness of the mission are presented. The rightmost columns (EFF. INDICATION) present the ranges where the particular PIs fall (green – optimum, yellow – acceptable, red – needing attention), whereas the frame in the right lower part summarizes the overall effectiveness of the mission (green – optimum, white – effective, yellow – acceptable, red – to analyse).

The bar diagram in the figure shows the number ratio of issues covered by the mission report to those foreseen by the Standard Mission Report Template. Details on this coverage are given in Appendix 1.

The coverage of the Action Plan items (defined by the host country) by Recommendations and Suggestions by the reviewers of the various Modules is shown in the figure in Appendix 2.

1 On the Efficiency and Effectiveness of IRRS Missions, Draft v6, Working Material, IAEA, Vienna, 2013

Efficiency and Effectiveness of an IRRS Mission initial

INPUT QUANTITIES valueA priory mission data No(id) Unit Value min.(>) max.(≤) min.(>) max.(≤) col PI

Type of mission (1 - initial or 2 - follow-up) 1 optimum 0.0 C1(T) - 25 24 29 21 32 0.00 Team sizeHost country Czech Rep. effective 0.1 C2(P) - 132 126 154 112 168 0.00 Report lengthStating time of the mission (yyyy-mm-dd) 2013-11-18 acceptable 0.2 C3(tARM) day 61 45 - 30 45 0.00 ARM review timeEnding time of the mission (yyyy-mm-dd) 2013-11-29 needs attention C4(NAWC) - 16 14 - 11 14 0.00 Advance commentsNumber of modules (nT) 12 C5(fbARM) - 3.70 4.00 5.00 3.00 4.00 0.07 Feedback on ARMNumber of supplementary modules (in follow-up) (nM+) T 0-first -0.96 C6(Exp) - 0.63 0.50 0.66 0.33 1.00 0.00 Team experienceNumber of facility and activity types (nx) 6 λ T-first 1.48 C7(fbHost) - 4.14 4.00 5.00 3.00 4.00 0.00 Host feedbackNumber of additional technical areas (nT) 3 T 0-fu 3.09 C8(fbTeam) - 4.31 4.00 5.00 3.00 4.00 0.00 Team feedbackNumber of policy discussion issues (nP) 2 λ T-fu 0.71 C9(β0) - 1.05 1.00 - 0.80 1.00 0.00 Action Plan ExtentNumber of NPP units in the host country (ν) 6 C10(β1) - 1.03 1.00 - 0.80 1.00 0.00 Action Plan coverage

Pre-mission data P 0-first 17.60 C11(β2) - 1.09 1.00 - 0.80 1.00 0.00 Beyond AP coverageNumber of Team Members (including IAEA) (T) 25 λM-first 5.83 C12(ρ1) - 1.18 0.75 1.25 0.50 1.50 0.00 Balance of findingsNumber of Experts in the Team (without IAEA) (Te) 19 λ F-first 0.63 C13(ρ2) - 1.15 0.75 1.25 0.50 1.50 0.00 Balance of R & SNumber of Experts with IRRS experience (Tx) 12 P 0-fu 54.20 C14(RCont) - 0.96 0.90 1.00 0.80 0.90 0.00 Report concisenessARM distribution date (yyy-mm-dd) 2013-09-17 λM-fu 1.55 C15(RTime) day 61 0 90 90 120 0.00 Report completionNumber of issues in the Action Plan (NAP) 29 λ F-fu 0.64 C16(OpenI) - - 0.00 0.20 0.20 0.40 - - Open issues leftNumber of advanced ARM comments from TM's (NAWC) 16 μ 0.90 G1 (InitEff) - - 4.00 5.00 3.00 4.00 - - Init. miss. effectivenessNumber of findings (R+S) in the initial mission (for follow-up)

Mission data (R+S) av 39Number of Recommendations (R) 20 R av 15.1Number of Suggestions (S) 17 G av 12.3Number of Good Practices (G) 11 (R*G) av 157.4Number of findings also in the Action Plan (N=) 15 (R/S) av 0.89Number of issues remained open (in follow-up)Number of Report Pages (P) 132 Size of nucl.pr. 1Conciseness of the Mission Report (ρ) 0.96 Mission size 18.5

Feedback data (average marks) Opt.team size 26.4By the Team on ARM quality 3.70 Opt.rep.length 140

By the Host on mission effectiveness 4.14 EFF.& EFF. OF THE MISSION TOBy the Team on mission effectiveness 4.31 Mission type:By the Host on initial mission effectiveness (for follow-up) - Missions duration:

Post-mission data Average Measure of Deviation (Δ):Date of isuance of mission report (yyyy-mm-dd) 2014-01-31 fields to input!

2013-11-18

effectiveOverall Effectiveness:November 2013 0.005

2013-11-29initial

CALCULATED DATA

IAEA, Version 5

EFF. INDICATIONRel.Dist from Opt.

Optimum rangePERFORMANCE INDICATORS Acceptable range

Czech Rep.

Czech Rep.

LIMITS & PARAMETERSFor average deviation

For team size

For report length

For findings

0.000.100.200.300.400.500.600.700.800.901.00

I II III IV V VI VII VIII IX X XI XII

Module-wise report conciseness

Discussion and conclusions

The values of the effectiveness and efficiency Performance Indicators (upper right table in the figure headed by EFF. INDICATION) suggest the following conclusions:

1) Almost all Performance Indicators of the mission are in the optimum range2) Feedback of the team on the ARM suggests slight non-conformances as discussed in section

3.3) Conciseness of the mission report is rather good, partly due to the fact that coverage of the

required topics by the report was checked already during the mission. Details of the coverage are given in Appendix 1.

4) Details on the coverage of the Action Plan by findings (which is also in the optimum range) are given in Appendix 2.

5) The overall effectiveness of the mission is in the lower region of white (effective) range and its value (0.005) is one of the best in recent missions, indicating a rather efficient mission.

7. Summary

The data of and feedback from the full scope initial IRRS mission to the Czech Republic have been analysed. The following conclusions are drawn:

The ARM contained the necessary generic information, yet specific examples supporting stated compliance with requirements were missing

Structure and management of the ARM need revision to turn it more user friendly The SARIS Questionnaires and the Report Template need to be revised for consistency All members and leaders of the team were rather effective and did a great job Support from IAEA staff was appreciated The mission schedule needs refinement to provide more time for interviews, group

discussions and for good balance in discussing findings and the report The purpose of the mission was acknowledged by the hosts The review was considered by the host sufficiently objective, the findings were accepted as

realistic, the reviewers were judged generally competent The host noted that reviewers should not take their national practice as basis for comparison

in peer review Plenary discussion of the final report is necessary SARIS questionnaires need further revision Almost all components of the mission that are measured by Performance Indicators were

rated optimum The mission was rated highly effective (nearly absolute optimum) by the evaluated

Performance Indicators


Appendix 1: Module-wise Coverage in the Mission Report Conciseness of the Mission Report

conciseness ratio: 0.96208 199

M No. Report section in scope in report M Module-wise

I 1.1 National policy and strategy 1 11.2 Establishment of a framework for safety - legal background covering all activities and facilities 1 1

- clearly allocated responsibilities 1 1 - legal and financial provisions for waste and spent fuel management 1 1

1.3 Establishment of a regulatory body - legal authority 1 1 - necessary resources 1 1 - effective independence of the Regulatory Body 1 1 - free from conflicting responsibilities 1 1

1.4 Compliance with regulations and responsibility for safety - prime responsibility for safety 1 1 - authority of regulatory body to require demonstration of compliance with requirements1 1

- responsibility through all stages of lifetime 1 11.5 Coordination of different authorities with responsibilities for safety within the regulatory framework - 1 1

- appropriate and documented liaison among authorities 1 11.6 System for protective actions to reduce existing or unregulated radiation risks - protection against risk not 1 1

- role of RB 1 11.7 Provision for decommissioning of facilities and the mngmnt of rad. waste and spent fuel - gov. 1 1

- provisions for financial resources, funds 1 1 - existence of respective legal requirements 1 1 - provisions for appropriate R&D programmes 1 1

1.8 Competence for safety - required for all parties with responsibilities for safety 1 1 - definition of necessary competence levels 1 1 - arrangements for training 1 1 - requirements for provisions of sufficient number of qualified and 1 1

1.9 Provision of technical services 1 1 I 1.00

II 2.1 International obligations and arrangements for international cooperation - international conventions 1 1 - use of and participation in the developmen tof IAEA SSs 1 1 - international peer reviews 1 1 - bilateral and multilateral cooperations 1 1

2.2 Sharing of operating experience and regulatory experience - reporting operating and regulatory experience 1 1 - receiving information from other states and parties 1 1

- dissemination of lessons learned, feedback on responsemeasures

1 1 II 1.00

III 3.1 Organizational structure of the regulatory body and allocation of resources - organization 1 1 - sufficient resources 1 1 - decision making process 1 1

3.2 Effective independence in the performance of regulatory activities - independent decision making 1 1 - prevention or resolution of conflicts of interest 1 1 - separation from influence, integrity of staff 1 0

3.3 Staffing and competence of the regulatory body - sufficiency and competence of staff 1 1 - long term human resource planning 1 1 - training and knowledge management 1 1

3.4 Liaison with advisory bodies and support organizations - advisory bodies 1 1 - dedicated TSOs / intelligent customer status 1 1 - handling of conflicts of interets related to technical support 1 1

3.5 Liaison between the regulatory body and authorized parties - meeting types and schedules 1 1 - nature of relationship 1 1 - resident inspectors 1 1

3.6 Stability and consistency of regulatory control - predictability 1 1 - transparency in change of requirements 1 1

3.7 Safety related records - scope of records to be kept 1 1 - management of records 1 1

3.8 Communication and consultation with interested parties - interfaces with the media and the public 1 1 - meetings and reports 1 1 - regulator's website 1 1 III 0.95

IV 4.1 Implementation and documentation of the MS - existence, defined, integrated 1 1 - documentation 1 1 - all activities defined by documented processes 1 1 - promotion of safety culture 1 1 - promotion of continuous improvement 1 1 - application of graded approach 1 1

4.2 Management responsibility - demonstration of commitment 1 1 - address expectations of interested parties 1 1 - organizational policies 1 1 - establishment of goals, strategies, plans, objectives 1 1

4.3 Resource management - determination of needs and requirements 1 1 - development of staffing plan 1 1 - training 1 1

4.4 Process implementation - identification, documentation of processes, process owners 1 1 - control of working documents and records 1 1 - management of organizational changes 1 1

4.5 Measurement, assessment, improvement - self-assessment 1 1 - audits 1 1 - MS review and improvement 1 1 - management of non-conformances 1 1 IV 1.00

fields to input!Czech Rep.

initial


V 5.1 Generic issues - roles and responsibilities in authorization 1 1 - types of authorization 1 1 - licensing steps, license amendment, renewal, revocation 1 1 - requirements on the submittal 1 1 - decision making process, traceability 1 1 - appeal 1 1 - assessment by the regulatory body 1 1 - independent verification of the safety assessment included in the 1 1

5.2 Authorization of nuclear power plants - application for authorization 1 1 - documentation of the licensing basis, modification of licensing documentation1 1 - licensing of plant personnel 1 1 - ageing management 1 1 - severe accident management 1 1

5.3 Authorization of research reactors - safety committees, communication with the reactor manager 1 0 - licensing of personnel 1 0 - ageing management 1 1 - experimental devices, influence of experiments on DBA 1 1

5.4 Authorization of fuel cycle facilities - specific authorization requirements for facilities 1 15.5 Authorization of radioactive waste management facilities - specific authorizations requirements 1 1

- authorization of closure of disposal facilities 1 05.6 Authorization of radiation sources facilities - specific authorization requirements 1 1

- hazards associated with industrial and health applications 1 1 - reuse or recycling 1 0 - authorization of export and import of sealed sources 1 1

5.7 Authorization of decommissioning activities - preserving key staff 1 0 - responsibilites of financial provisions 1 1 - demonstration of compliance with the decommissioning plan 1 1 - controls if cannot be released for unrestricted use 1 1

5.8 Authorization of transport activities - specific authorization requirements 1 10 - V 0.83

VI 6.1 Generic issues - graded approach for the various facilities 1 1 - responsibility for the R&A 1 1 - safety assessment has to address all radiation risks 1 1

6.2.1 Management of R&A (NPP) - types and number of documents subject to review 1 1 - availablity of internal guidance for R&A 1 1 - availability of R&A plan 1 1 - interface among interested authorities (if applicable) 0 - - documentation, monitoring, tracking, QA of the R&A process 1 1 - graded approach 1 1

6.2.2 Organization and technical resources for R&A (NPP) - internal manpower and organizational arrangements 1 1 - staff competence and training for R&A 1 1 - external resources, advisory bodies 1 1 - specific regulatory R&A tools (codes, experiements) and 1 1

6.2.3 Bases for R&A (NPP) - availability of relevant regulations and guides for the licensee 1 1 - guidance on the scope of probabilistic/deterministic safety analysis 1 1 - alignment with IAEA SSs 1 1

6.2.4 Performance of the R&A (NPP) - methods for verification of comprehensiveness and quality 1 1 - Periodic Safety Review 1 1 - Feedback of Operating Experience 1 1 - independent regulatory control calculations 1 1

6.3 R&A for research reactors - specific R&A methods 1 1 - Periodic Safety Review 1 1

6.4 R&A for fuel cycle facilities - specific R&A methods 1 1 - Periodic Safety Review 1 1

6.5 R&A for waste management facilities - specific R&A methods 1 16.6 R&A for radiation source facilities - specific R&A methods 1 16.7 R&A for decommissioning activities - specific R&A methods 1 16.8 R&A for transport activities - specific R&A methods (e.g. shipment, special arrangements, packaging) 1 1 VI 1.00

VII 7.1.1 Inspection approaches, methods and plans - inspection areas and aspects related to facilities and activities 1 1 - graded approach 1 1 - types and methods of inspections 1 1 - inspection plans 1 1 - use of third parties and joint inspections 1 1

7.1.2 Inspection processess and practices - procedures, guides, check lists 1 1 - observation, recording, reporting 1 1 - follow-up and use of inspection results 1 1 - reactive inspections 1 1

7.1.3 Inspectors - manpower, qualification, training 1 1 - resident inspectors, presence of inspectors on-site 1 1 - authority of inspectors (unlimited access, enforcement tools) 1 1

7.2 Inspection of nuclear power plants - specific issues from 7.1 1 17.3 Inspection of research reactors - specific issues from 7.1 1 17.4 Inspection of fuel cycle facilities - specific issues from 7.1 1 17.5 Inspection of waste management facilities - specific issues from 7.1 1 17.6 Inspection of radiation source facilities - specific issues from 7.1 1 17.7 Inspection of decommissioning activities - specific issues from 7.1 1 17.8 Inspection of transport activities - specific issues from 7.1 1 1 VII 1.00


Appendix 2: Module-wise Coverage of the Action Plan

0.000.100.200.300.400.500.600.700.800.901.00

I II III IV V VI VII VIII IX X XI

Modules

AP coverage by Modules

As seen from the figure, the coverage of the Action Plan (AP) items by findings is rather good (the optimum range is above 0.5) in most Modules. Poor coverage is reached in Module 1 (responsibilities and functions of the government) where the AP included a single item and it was not covered; in Module 5 (authorization), where a multiple AP item related to radioactive sources has not been covered and in Module 7 (inspection), where three AP items related to inspection programme, inspectors’ responsibilities and witnessing activities in transport have not been observed by the team.