IP 71114, Reactor Safety Emergency Preparedness
Reactor Safety Emergency Preparedness
[table of findings in Region 1]
Text
Issue Date: 05/29/12 1 71114
NRC INSPECTION MANUAL NSIR/DPR
INSPECTION PROCEDURE 71114
REACTOR SAFETY—EMERGENCY PREPAREDNESS
PROGRAM APPLICABILITY: 2515
71114-01 INSPECTION OBJECTIVES
01.01 The objective of this procedure is to gather information to determine, in conjunction with
the performance indicators, whether a licensee is meeting the Cornerstone Objective and
Performance Expectation.
a. The Cornerstone Objective is ―To ensure that the licensee is capable of implementing
adequate measures to protect the public health and safety in the event of a radiological
emergency.‖
b. The Cornerstone Performance Expectation is ―Demonstration that reasonable
assurance exists that the licensee can effectively implement its emergency plan to
adequately protect the public health and safety in the event of a radiological
emergency.‖
71114-02 INSPECTION REQUIREMENTS
02.01 Baseline inspection requirements are identified in each of the attached inspectable
areas:
a. Exercise Evaluation (Attachment 01)
b. Alert and Notification System Evaluation (Attachment 02)
c. Emergency Response Organization Staffing and Augmentation System (Attachment 03)
d. Emergency Action Level and Emergency Plan Changes (Attachment 04)
e. Maintenance of Emergency Preparedness (Attachment 05)
f. Drill Evaluation (Attachment 06)
g. Exercise Evaluation – Hostile Action (HA) Event (Attachment 07)
Issue Date: 05/29/12 2 71114
h. Exercise Evaluation – Scenario Review (Attachment 08)
02.02 The requirements found in the attached inspectable areas represent the minimum
inspection activity to be conducted at each reactor site. The expected frequency of inspection is
given in each inspectable area.
02.03 The accuracy of licensee reported performance indicator (PI) data will be inspected
annually using Inspection Procedure (IP) 71151, ―Performance Indicator Verification.‖
02.04 The licensee program for problem identification and resolution will be inspected
annually using IP 71152, ―Identification and Resolution of Problems.‖
02.05 10 CFR 50, Appendix E, Section IV.F.2 (challenging drills and exercises) requires each
licensee to conduct a hostile action exercise no later than December 31, 2015. The first eightyear exercise cycle will begin in the calendar year of the first hostile action exercise. For a site
licensed under Part 52, the first eight-year exercise cycle begins in the calendar year of the
initial exercise required by Section IV.F.2.a. All the new exercise cycle requirements described
in Section IV.F.2 must be completed/ implemented no later than the end of the first eight-year
exercise cycle.
71114-03 INSPECTION GUIDANCE
General Guidance
03.01 Performance Indicators.
a. The ―Drill/Exercise Performance‖ PI (DEP PI) monitors licensee performance of event
classification, offsite authority notification and protective action recommendation (PAR)
development.
b. The ―Emergency Response Organization Drill Participation‖ PI (ERO PI) monitors
licensee efforts to develop and maintain key skills within the ERO through participation
in proficiency enhancing evolutions, such as drills.
c. The ―Alert and Notification System Reliability‖ PI (ANS PI) monitors reliability of the alert
and notification system. This system has been identified as the most risk-significant
equipment system maintained by nuclear plant emergency preparedness programs.
d. DEP and ERO PIs are linked in that ERO drill participation is only credited when
performance is assessed for contribution to DEP. The details and exceptions to this
linkage are contained in Nuclear Energy Institute (NEI) 99-02, ―Regulatory Assessment
Performance Indicator Guideline.‖
03.02 Disposition Of Findings.
a. The need for inspection beyond the Baseline Inspection Program (BIP) is determined
through the significance and number of inspection findings and the status of PIs.
Issue Date: 05/29/12 3 71114
b. A Significance Determination Process (SDP) has been developed for assessing the
significance of inspection findings. The details of the Emergency Preparedness (EP)
SDP are contained in Manual Chapter 0609, Appendix B.
c. The BIP is designed for programs operating in the ―licensee response band,‖ that is, a
program with green PIs and only green findings. The resources allocated in the BIP are
not intended to be sufficient for the characterization of potential white, yellow, or red
findings. Should it be necessary to characterize such findings, and the time involved
exceeds a few hours, the time should be allocated to the SDP rather than the BIP.
03.03 Failure to Implement Corrective Actions.
a. Licensee failures to implement corrective actions necessary to maintain the
effectiveness of the EP program, to resolve weaknesses observed in a drill or exercise,
to restore compliance with regulatory requirements, or to address an inspection finding
should be summarized and provided to the team leader for the annual problem
identification and resolution inspection.
b. Weaknesses (see Attachment 1 ―Evaluating Exercise Player Prompting‖ and 2 ―ERO
Weaknesses‖ to this procedure) in ERO performance appropriately critiqued by the
licensee in evaluated exercises, drills, and training are not considered to be findings.
However, the inspector must ensure that such items are entered into the licensee
corrective action system in a manner that will allow review during the subsequent offyear exercise and next biennial exercise. If the licensee fails to identify the weakness,
the failure should be documented as a failure to comply with a regulatory requirement
and its significance assessed using the EP SDP.
c. Section IV.F.2.g of Appendix E to 10 CFR 50 requires that all weaknesses or
deficiencies that are identified in a critique of exercises, drills, or training be corrected.
Inspectors should review the correction of licensee and NRC-identified weaknesses.
However, a repeat ERO performance weakness may not in itself, represent a failure to
correct a weakness. The inspector must review licensee efforts to correct the
weakness and the reasons for the repeat problem. If the problem is localized it would
not be appropriate to determine that it represents a failure to correct. Guidance on
determining the adequacy of licensee efforts to resolve weaknesses is contained in
Manual Chapter 0612, in the EP SDP, and Inspection Procedure 71152.
03.04 Risk-Significant Areas.
Implementation of the emergency plan (E-Plan) is dependent on the performance of the ERO in
their EP assignments. There are many areas important to E-Plan implementation, but the most
risk-significant areas of performance are:
a. Timely and accurate classification of events. This includes the recognition of events as
potentially exceeding emergency action levels. [10 CFR 50.47(b)(4) and Section IV.C.2
of Appendix E to 10 CFR Part 50]
Issue Date: 05/29/12 4 71114
b. Timely and accurate notification of offsite governmental authorities. This includes
adequate performance of notifications to state and local authorities as specified in the
E-Plan. [10 CFR 50.47(b)(5) and Appendix E to 10 CFR Part 50 sections IV.D.1 and
IV.D.2 ]
c. Timely and accurate development of PARs for offsite authorities. This includes
providing PARs to governmental authorities, and the decision-making process to
develop the PARs. [10 CFR 50.47(b)(10)]
d. Assessment of offsite consequences. This includes the ability to assess and monitor
the magnitude and dose consequences of potential or actual radioactive releases. [10
CFR 50.47(b)(9) and Appendix E to 10 CFR Part 50 sections IV.G and IV.E.2 ]
In general, NRC oversight in EP is focused on adherence to the E-Plan with an emphasis on
these most risk-significant areas, and inspection resources should be deployed in a manner to
cover these areas. However, within the constraint of resources, a broad range of response
areas should be inspected.
03.05 Inspection Resource Planning.
The inspector should use corrective action system data to identify response areas of concern
and deploy inspection resources accordingly. Areas, (e.g., OSC, field monitor teams) that have
had few critique findings or more than average (as compared to the TSC or EOF) findings
should be selected for observation. Inspection resources usually deployed in the TSC, EOF, or
Control Room may be used to observe other areas should the inspector identify a need.
If the licensee‘s performance in previous baseline inspections in these risk-significant
areas in conjunction with its performance under the DEP PI indicates reliable acceptable
performance, within the licensee response band, inspectors should reduce the
inspection sampling of these areas and instead use a portion of available inspection
resources to sample a selection of less risk significant areas from Attachment 3
―Prioritization of Additional Areas for Inspection,‖ regardless of the results of the review
of critique findings.
In order to facilitate review of critique related corrective actions, the inspector should
request a corrective action system listing sorted for drill and exercise critique findings of
the last 2-3 years. If possible, the findings should be sorted by response center.
The inspector should remain alert to the impact that the licensee‘s performance in less
risk-significant areas (e.g., staffing, training, etc.) may have on the licensee‘s
performance in the risk-significant areas.
03.06 Prioritization of Additional Areas for Inspection.
Guidance for deployment of inspection resources beyond the most risk-significant areas is
provided below. These areas may generally be considered in order of importance. Selection
for deployment of inspection resources should be based on knowledge of the program, previous
problems and logistics.
Issue Date: 05/29/12 5 71114
a. Adequacy of worker protection including accountability, evacuation, exposure
authorization and thyroid protection, including actions during a hostile action [10 CFR
50.47(b)(10) & (11) and Appendix E to 10 CFR Part 50 sections IV.E and IV.I].
b. Adequacy of interface with offsite authorities (e.g., in the area of PAR communication
and technical support). [10 CFR 50.47(b)(6) and Appendix E to 10 CFR Part 50
sections IV.A.7, IV.E.9, and IV.D].
c. Adequacy of arrangements for offsite resources responding to an emergency, including
hostile actions, at the licensee‘s site [10 CFR 50.47(b)(6) and Appendix E to 10 CFR Part 50 section IV.A.7.]
d. Readiness and adequacy of EP equipment and facilities, including alternate and backup
facilities [10 CFR 50.47(b)(8) and Appendix E to 10 CFR Part 50 section IV.E].
e. Timely activation of facilities [10 CFR 50.47(b)(2) and Appendix E to 10 CFR Part 50
sections IV.C and IV.E].
f. Ability to prioritize mitigation and assessment efforts to protect the public health and
safety.
g. Command and control [10 CFR 50.47(b)(1)].
h. Ability to diagnose plant accident conditions, other than offsite consequences
addressed in the risk-significant area discussion.
i. Ability to formulate mitigating actions.
j. Ability to implement mitigating actions (e.g., damage control teams) under accident and
hostile action event conditions.
k. Adequacy of communications between licensee facilities [10 CFR 50.47(b)(6) and
Appendix E to 10 CFR Part 50 section IV.E.9].
l. Accuracy and completeness of licensee-approved press releases [10 CFR 50.47(b)(7)].
03.07 Scheduling
Attachment 1 should be scheduled for evaluation of the biennial exercise, except those
exercises involving hostile action based scenarios, which are evaluated under Attachment 7.
An exercise is to be evaluated biennially at each licensee site, including one biennial exercise
for each licensee at a co-located site. IP71151 is to be performed annually and should be
performed in conjunction with Attachment 1. Attachment 2, ―Alert and Notification System
Evaluation,‖ Attachment 3, ―Emergency Response Organization Staffing and Augmentation
System,‖ and Attachment 5, ―Maintenance of Emergency Preparedness,‖ may be conducted
during a single inspection in the off biennial exercise year. Attachment 6, ―Drill Evaluation,‖ is
conducted annually by the resident inspector and may be done whenever convenient to the
Issue Date: 05/29/12 6 71114
licensee and inspector schedule. Attachment 7, ―Exercise Evaluation – Hostile Action Event,‖
should be conducted once every eight year planning cycle in lieu of Attachment 1. Attachment
8 is to be scheduled prior to any evaluated biennial exercise.
71114-04 RESOURCE ESTIMATE
Estimates of inspection resources are identified within each inspectable area attachment.
71114-05 REFERENCES
NEI 99-02, ―Regulatory Assessment Performance Indicator Guideline,‖ and revisions.
NSIR/DPR-ISG-01, ―Interim Staff Guidance Emergency Planning for Nuclear Power Plants‖
Regulatory Guide 1.101, ―Emergency Planning and Preparedness For Nuclear Power
Reactors,‖ all revisions.
Regulatory Guide 1.219, ―Guidance on Making Changes to Emergency Plans for Nuclear Power
Reactors‖
Regulatory Issue Summary (RIS) 2003-18, ―Use of NEI 99-01, ‗Methodology for Development of
Emergency Action Levels‘,‖ and Supplements.
RIS 2005-02, ―Clarifying the Process for Making Emergency Plan Changes.‖
Inspection Procedure 71152, ―Identification and Resolution of Problems.‖
Inspection Procedure 71151, ―Performance Indicator Verification.‖
FEMA-REP-10, ―Guide For the Evaluation of Alert And Notification Systems For Nuclear Power
Plants.‖
Bulletin 2005-02, ―Emergency Preparedness and Response Actions For Security-Based
Events.‖
END
Attachments:
.01 Exercise Evaluation
.02 Alert and Notification System Evaluation
.03 Emergency Response Organization Staffing and Augmentation System
Issue Date: 05/29/12 7 71114
.04 Emergency Action Level and Emergency Plan Changes
.05 Correction of Emergency Preparedness Weaknesses
.06 Drill Evaluation
.07 Exercise Evaluation - Hostile Action (HA) Event
.08 Exercise Evaluation – Scenario Review
Issue Date: 05/29/12 Att1-1 71114
ATTACHMENT 1
EVALUATING EXERCISE PLAYER PROMPTING
Introduction
This attachment provides guidance for inspectors in the identification of player prompting during
drills and exercises conducted to meet the requirements of 10 CFR 50.47(b)(14) and Section
IV.F.2 of Appendix E to 10 CFR Part 50.
Not all of the information that may be provided by controllers to players is coaching. Some
information, namely ―injects‖ are generally appropriate.
Inject
An inject is a verbal or written communication between a controller and a player
that provides information regarding simulated conditions, analysis results,
instrument readings, etc., all of which would reasonably be expected to be known
or discoverable during an actual event. An inject may also be used to change
the course of exercise play if that play threatens successful completion of the
exercise.
The first part of this definition is the primary objective of an inject. An inject provides information
that the player(s) would otherwise had readily available, but doesn‘t because of the artificiality of
a drill or exercise situation. For example, it is acceptable for a controller to tell a field team
member that his survey instrument is reading X.X, if the field team member performed the
survey activity and then asked for the reading. It is similarly acceptable for a controller to hand
a auxiliary operator passing through a plant area a card identifying that a simulated fire is
burning in that area. However, a controller providing information that the player(s) have not
earned will likely constitute prompting. The player ―earns‖ the information by performing the
procedures that would govern his or her actions during an actual emergency to the extent
allowed by plant and personnel safety
The second part of the definition addresses a verbal or written communication intended to
prevent or correct an unanticipated situation that would result in an inability to evaluate exercise
objectives (e.g., a delayed general emergency declaration could prevent evaluation of offsite
agency objectives). These situations could be due to an ERO performance deficiency or a
deficiency in the exercise scenario either of which is an exercise weakness that needs to be
critiqued and corrected. However, the exercise need not be terminated.
Prompting
Prompting is an inject or other action by a controller or evaluator that prevents a true
evaluation of a player‘s performance in an evaluated drill or exercise by masking
performance weaknesses that would have otherwise become apparent if the
prompting had not occurred.
Controller actions that could fall within the above definition include the following examples to
the extent that the controller actions prevent a true evaluation of a player‘s performance or
Issue Date: 05/29/12 Att1-2 71114
mask player or program weaknesses:
1. A controller who directs a player to perform an activity that the player would not have
performed absent the prompt.
2. A controller who provides information that would not have yet been discoverable by
any player.
3. A controller who by direct statements or facial expressions or other body language
indicates to a player that the just-completed action is incorrect, such that the player
re-performs the action and reaches a different endpoint than he would have absent
the prompting.
4. A controller who provides a player with information that was not ―earned‖ via
simulation of an activity, if in doing so the player is alerted to his failure to perform the
simulated activity. Specifically:
a. It is prompting for a controller to provide a field team with sample readings
when the field team did not simulate taking or analyzing that reading or
sample.
b. It is prompting for a controller to ask a field team what their dosimeter reads
when the field team hasn‘t read their dosimeters since they left the plant.
c. It is not prompting for a controller to provide information to a player if, during
an actual event, the information would have been readily obvious, for
example, a controller telling a player doing a plant tour that an explosion had
just occurred in that plant area or an adjacent area. Note, however, that a
controller telling the ED in the TSC of an explosion in a HPSI quadrant is
prompting because the ED had no reason to know the information, even in an
actual event.
5. Controller statements to a player such as:
a. ―Are you sure that‘s correct?‖
b. ―Is that what the procedure calls for?‖
c. ―That‘s not correct. Try this approach.‖
d. ―Did you see this change in the display?‖
e. ―Are you aware the ED just declared an Alert?‖
f. ―Have you made the notification yet?‖
Prompting of exercise participants is not a finding under the ROP because it has no risk
significance in itself. However, prompting could prevent the identification and correction of
ERO performance weaknesses as required by § IV.F.2.g of Appendix E to 10 CFR Part 50
and 10 CFR 50.47(b)(14). Accordingly, the failure of the licensee to identify the
weaknesses, which would have been identified if not for the prompting, may be a
performance deficiency that should be evaluated as a failure to comply and assessed for
significance. Prompting may also be a basis for failing a DEP PI opportunity.
Issue Date: 05/29/12 Att1-3 71114
Relationship of Injects and / or Prompting to Scoring a Performance Opportunity
An inspector identifying an inject or prompting situation needs to consider the reason
(causal factors) for the inject in assessing whether a particular player‘s performance needs
to be considered as an opportunity failure or success.
1. Prompting that affects the outcome of a performance indicator opportunity should
generally be categorized as a failed opportunity. This is consistent with the guidance
in NEI 99-02.
2. In an inject situation, a player who successfully completes a performance opportunity
prior to the inject should generally be credited with an opportunity success.
3. If the timing of the inject is such that a player‘s performance is a failure to this point,
but changes to a success because of the inject, the player should be credited with an
opportunity failure as without the inject, the endpoint would have been a failure.
4. A player who successfully completes a performance opportunity prior to the inject
and successfully completes the re-performance should be credited with a single
opportunity success since the second opportunity was the result of the inject and
was not envisioned in the scenario.
5. In these inject situations, it is important to note that the ERO weaknesses or scenario
deficiency that made the inject necessary must be critiqued and corrective actions
taken.
6. Even if identified in the critique, prompting during a DEP PI opportunity should be
considered as a failure. (See ROP FAQ No. 405 dated July 21, 2005.)
7. It is also possible that prompting throughout an exercise could be so extensive as to
bring into question whether the exercise was a satisfactory test of the E-Plan. This
determination, which would involve Regional management, would be made based on
the extent of the coaching and the risk-significance of the associated weaknesses.
Consider a case:
1. A player properly classifies an emergency based on displayed indications (which,
because of performance weaknesses in the control room, are in error).
2. Before the player could confirm the indicated value with the control room, as required
by his procedure, and before declaration, the controller injects, stating that the
displayed value is in error and provides the correct value.
3. The player now properly classifies the emergency based on the indication as revised
by the controller (and as expected by the scenario.) The revised emergency
classification level is declared and notifications made.
4. The player has performed two correct classifications, one based on erroneous data
from the control room, and one based on the inject information. In such a case, the
Issue Date: 05/29/12 Att1-4 71114
classification opportunity should be considered a success.
5. There is, however, a performance weakness in the control room handling of data and
relaying data to the TSC that needs to be critiqued and corrective action taken.
Issue Date: 05/29/12 Att2-1 71114
ATTACHMENT 2
ERO WEAKNESSES
Introduction
A weakness is defined as a level of ERO performance demonstrated during an exercise, drill, or
training (that provide performance opportunities to develop, maintain, or demonstrate key skills)
that would preclude effective implementation of the E-Plan (i.e., loss of a planning standard
function) if the weakness were to occur during an actual emergency. Further:
1. A weakness identified by the licensee in its critique is not a performance deficiency and
is, therefore, neither a failure to comply nor a failure to implement.
2. A deficient program element uncovered by the exercise and identified by the licensee in
its critique is a licensee-identified performance deficiency and should be evaluated as a
failure to comply. If identified by the inspector, the deficient program element is an NRCidentified performance deficiency and is evaluated as a failure to comply with the related
planning standard.
3. A licensee‘s failure to identify a weakness in a critique or failure to take timely corrective
actions, is a performance deficiency and is evaluated as a failure to comply with
planning standard 10 CFR 50.47(b)(14).
Clarification
1. A mistake or a miss-step by ERO members that only detracts from the overall ERO
performance should generally not be treated as a weakness. Mistakes are likely to
happen in the course of an exercise and many are corrected by the ERO (e.g., peer
checking), which should be viewed as an organizational strength. Failure to identify
these mistakes as weaknesses in the critique is generally not an issue of concern.
2. Classifications, PARs, and notifications could be accurate and timely (i.e., DEP PI
opportunity successes) and there still be a weakness (e.g., a correct classification based
on misinformation, a correct PAR based on an incorrect dose assessment). Such
weaknesses need to be identified and corrected since, under different circumstances,
they could affect functions necessary for protecting the health and safety of the public.
Issue Date: 05/29/12 Att3-1 71114
ATTACHMENT 3
PRIORITIZATION OF ADDITIONAL AREAS FOR INSPECTION
General
In general, NRC oversight in EP is focused on adherence to the E-Plan with an emphasis on
these most risk-significant areas, and inspection resources should be deployed in a manner to
cover these areas. However, within the constraint of resources, a broad range of response
areas should be inspected.
The inspector should use corrective action system data to identify response areas of concern
and deploy inspection resources accordingly. Areas, (e.g., OSC, field monitor teams) that have
had few critique findings or more than average (as compared to the TSC or EOF) findings
should be selected for observation. Inspection resources usually deployed in the TSC, EOF, or
Control Room may be used to observe other areas should the inspector identify a need.
If the licensee‘s performance in previous baseline inspections in these risk-significant
areas in conjunction with its performance under the DEP PI indicates reliable acceptable
performance within the licensee response band, inspectors should reduce the inspection
sampling in those areas and instead use a portion of available inspection resources to
sample a selection of less risk significant areas from Attachment 1 ―Prioritization of
Additional Areas for Inspection,‖ regardless of the results of the review of critique
findings.
In order to facilitate review of critique related corrective actions, the inspector should
request a corrective action system listing sorted for drill and exercise critique findings of
the last 2-3 years. If possible, the findings should be sorted by response center.
The inspector should remain alert to the impact that the licensee‘s performance in less
risk-significant areas (e.g., staffing, training, etc.) may have on the licensee‘s
performance of the risk-significant areas.
Prioritization of Additional Areas for Inspection
Guidance for deployment of inspection resources beyond the most risk-significant areas is
provided below. These areas may generally be considered in order of importance. Selection
for deployment of inspection resources should be based on knowledge of the program, previous
problems, and logistics.
a. Adequacy of worker protection including accountability, evacuation, exposure
authorization and thyroid protection, including actions during a hostile action [10 CFR
50.47(b)(10) & (11) and Sections IV.E and IV.I of Appendix E to 10 CFR Part 50].
b. Adequacy of interface with offsite authorities (e.g., in the area of PAR communication
and technical support). [10 CFR 50.47(b)(6) and Sections IV.A.7, IV.E.9, and IV.D of
Appendix E to 10 CFR Part 50].
Issue Date: 05/29/12 Att3-2 71114
c. Adequacy of arrangements for offsite resources responding to an emergency, including
hostile actions, at the licensee‘s site [10 CFR 50.47(b)(6) and Section IV.A.7 of
Appendix E to 10 CFR Part 50.]
d. Ability to prioritize mitigation and assessment efforts to protect the public health and
safety.
e. Command and control [10 CFR 50.47(b)(1)].
f. Ability to diagnose plant accident conditions, other than offsite consequences
addressed in the risk-significant area discussion.
g. Ability to formulate mitigating actions.
h. Ability to implement mitigating actions (e.g., damage control teams) under accident
conditions.
i. Adequacy of communications between licensee facilities [10 CFR 50.47(b)(6) and
Section IV.E.9 of Appendix E to 10 CFR Part 50].
j. Accuracy and completeness of licensee-approved press releases [10 CFR 50.47(b)(7)].
Issue Date: 05/29/12 Att4-1 71114
ATTACHMENT 4
Revision History for IP 71114
Commitment
Tracking
Number
Accession
Number
Issue Date
Change Notice
Description of Change Description of
Training Required
and Completion
Date
Comment and Feedback
Resolution Accession
Number
N/A 06/29/06 Completed four-year historical CN search.
Revised to reflect changes to the procedure
attachments, add new procedure
Attachment 07, simplify using acronyms,
and add new references.
None ML061580314
ML12100A241
05/29/12
CN 12-008
Revised to reflect some aspects of the final
EP rulemaking, add new procedure in
Attachment 08, Increase priority ranking for
evaluation of EP facilities and equipment,
and clarify language regarding weaknesses.
Added Inspection Requirement 02.05 to
address 10 CFR 50, Appendix E, Section
IV.F.2 (challenging drills and exercises)
requirement for each licensee to conduct a
hostile action exercise no later than
December 31, 2015 and that the first eightyear exercise cycle will begin in the calendar
year of the first hostile action exercise
Added new section title of ―Inspection
Resource Planning‖ to Inspection Guidance
section.
Added Attachments 1and 2.
Provided at EP
Face to Face
counterpart meeting
09/09/11