**NRC INSPECTION MANUAL** 	IRIB

IMPLEMENTATION OF LICENSEE CONTINGENCY PLANS

DURING A STRIKE/LOCKOUT

PROGRAM APPLICABILITY:	IMC 2201B, IMC 2515C, IMC 2600B, IMC 2681E3

92711-01	INSPECTION OBJECTIVES

01.01 To evaluate the licensee’s implementation of the strike/lockout contingency plans.

01.02	To verify that operations are proceeding in a safe and orderly manner during the strike/lockout.

92711-02	INSPECTION REQUIREMENTS

02.01	Verify that facility staffing continues to be consistent with staffing requirements, the licensee's contingency plans, and the emergency plan.  Verify that the licensee’s transition to replacement licensed operators and other workers is conducted safely.

02.02	Determine if procedure changes are consistent with requirements in the regulations, the license, and technical specifications.

02.03	Evaluate the performance of one person from each of the following categories:

a. Plant management.

b. Senior reactor operators and reactor operators (at reactor sites), or plant operators (at fuel facilities).

c. Maintenance.

d. Health physics.

e. Security supervision and force.

f. Other personnel responsible for operational or safety functions, especially non-licensed operators in charge of plant equipment that could initiate transients or would be required to mitigate abnormal conditions, transients, or accidents.  This may involve monitoring materials controls and accounting personnel and criticality safety personnel for fuel facilities.

Issue Date:  05/16/19	5	92711

02.04	Determine if the licensee is experiencing problems in obtaining local police or medical  

		support, or supplies.

02.05	Determine if all plant safety review committees are functioning effectively and are complying with the requirements in the license and technical specifications.

02.06	Evaluate the licensee's response to any strike/lockout-related event(s) (i.e., those that are caused by strike/lockout-related activities and that fall within NRC jurisdiction).

02.07	Evaluate the licensee’s implementation of the security plan during the strike/lockout.

02.08	Evaluate the licensee’s implementation of 10 CFR 26.205, “Work Hours,” and verify that work hours, exemptions, and self-declarations conform to regulatory requirements.

02.09	Meet with the site employee concerns program (ECP) coordinator or ombudsman to determine if the strike/lockout has had any adverse impact on the safety conscious work environment at the site.

92711-03	INSPECTION GUIDANCE

General Guidance.  After completing IP 92709, "Contingency Plans for Licensee Strikes or Lockouts," the resident inspection staff and/or responding regional inspectors shall perform this inspection procedure for the duration of the strike/lockout.  Inspection requirements shall be met weekly with the exception of the review of the licensee retraining plan, which shall be performed prior to normal staff return to duty.

Specific Guidance

03.01	Nuclear power plant licensed operator control room staffing is discussed in 10 CFR 50.54(m).  It is recommended during the licensee’s transition from licensed operators to replacement licensed operators that 24-hour site coverage be used (i.e., continuous control room observation).  When the transition has been completed, an augmented site coverage schedule should then be established to monitor control room activities, plant operations, and shift turnovers.  The Senior Resident Inspector should be assigned to oversee the onsite activities and continue with baseline inspections.  These actions, however, are left to the discretion of regional management.  If the licensee demonstrates the emergency plan implementation prior to, or during the strike/lockout, the inspectors shall observe activities in all emergency response facilities.  This may require additional regional resources to complete.  No specific guidance is provided for fuel facilities other than that contained in the approved license application.

03.02	The inspector should review a sample of procedure changes made during the strike/lockout for procedures used in selected baseline samples of maintenance, surveillance, and operations activities.  The inspector should determine the effect of changes on plant safety.  The inspector should verify that licensee management reviewed and approved the changes.

03.03	The inspector should evaluate the ability of plant personnel to continue to function effectively under existing working conditions.  The inspector should look for indications of fatigue that might affect the continued safe operation of the plant.  Recognizing that this area is very subjective, the inspector should find clear evidence of an effect on safety before raising this as an issue with plant management.

a. 	No guidance for  02.03a

	b.	The inspector should observe just-in-time crew training and operations involving significant plant evolutions, such as startup, shutdown, planned power changes greater than 20% or other evolutions deemed to be risk-significant.  The inspector should also monitor the licensed operator requalification training program by observing a minimum of one simulator scenario or classroom instruction per crew or a sample of either scenarios or classroom instruction for newly formed crews.  

	c.	The inspector should monitor the performance of major maintenance activities or surveillance tests.  During augmented site coverage, inspectors should increase this activity as necessary.  The inspector should examine the qualifications of plant personnel involved, determine whether the activity is being conducted using an approved procedure, and whether all related operational requirements are being satisfied (limiting conditions for operations, etc.).  The inspector should refer to the licensee's administrative controls, maintenance procedures, and technical specifications, if applicable, for guidance in determining operational requirements for controlling maintenance activities.

	d.	While monitoring the selected maintenance or surveillance activity, the inspector should ensure that appropriate health physics controls are followed in accordance with established licensee procedures or regulatory requirements.  Also, the inspector should monitor all condition reports involving failure of radiation protection controls and inform regional management of any significant performance issues.

	e.	The inspector should continue to monitor plant operations as directed in the Reactor Oversight Process baseline inspection program.  If the strike/lockout involves security personnel, physical security inspectors should observe weapon requalification training and response drills to ensure guard proficiency has been maintained.  In addition, the physical security inspectors should attend shift briefings and conduct walkdowns of the security posts, placing emphasis on any post at which a replacement officer may be working.  The purpose is to ensure that replacement officers understand their responsibilities.

	f.	For fuel facilities, monitor the performance of items relied on for safety testing. Examine the qualifications of personnel responsible for the nuclear criticality safety program and that related controls are being maintained.

03.04 	No inspection guidance for 02.04.

03.05	The inspector should review the administrative controls section of the technical specifications, license conditions, or other commitments that establish the composition and frequency of meetings, and the responsibilities of the nuclear safety review committees.  The inspector should evaluate the effectiveness of nuclear safety review committees by attending meetings or reviewing the meeting minutes.

03.06	The inspector should review licensee event reports, plant non-conformance reports, and safeguards incident reports, and evaluate the effectiveness of the licensee's corrective actions.

03.07	The inspector should evaluate the licensee’s implementation of the security plan through verification of day-to-day security activities.  If the strike/lockout involves security staff at a power reactor site, the resident inspector staff should monitor the need for compensatory measures daily and report adverse conditions to regional management and security specialists for assessment.  Physical security inspectors should lead the review of strike contingency plans involving security staffing.  Resident inspector staff will monitor changes to these plans, inform regional management of any changes, and assist the security inspectors in assessing the impact of these changes.

03.08	When evaluating whether site staffing work hours are in accordance with 10 CFR 26.205, “Work Hours,” the inspectors should consider the amount of overtime needed to maintain site coverage in the covered positions.  The inspectors should reference IP 93002 for additional guidance associated with work hour requirements and how to assess work hours, work hour extensions, and self-declarations.

03.09	The inspectors should refer to IP 71152, “Problem Identification and Resolution,” for guidance on reviewing the safety conscious work environment at a site.

92711-04	RESOURCE ESTIMATE

This inspection procedure requires approximately 70 hours per week to complete.  If required, an additional inspector should assist the resident inspector staff with baseline inspection activities.  Regional physical security inspectors should lead for strikes/lockouts involving security staff or and regional specialists should assist as needed in the review of contingency plans whenever licensed staff or emergency response organization members are involved to ensure that sufficient staff are available to meet license requirements.  If it is anticipated that the strike/lockout will be extended, support resources should be identified and, if possible, a site coverage schedule developed.

92711-05 	REFERENCES

10 CFR 26.205

10 CFR 40.31

10 CFR 50.34

10 CFR 50.47

10 CFR 50.54

10 CFR 50, Appendix E

10 CFR 55.31

10 CFR 55.53

10 CFR 60.160

10 CFR 70.22

10 CFR 73, Appendix C

Technical Specifications

IP 71152, “Problem Identification and Resolution”

IP 93002, “Managing Fatigue”

RG 5.73, “Fatigue Management for Nuclear Power Plant Personnel”

NEI 06-11, “Managing Personnel Fatigue at Nuclear Power Sites”

92711-06	PROCEDURE COMPLETION

Meeting the inspection objectives defined in section 92711-01 of this inspection procedure will constitute completion of this procedure.

END

Attachment 1:  Revision History page

Attachment 1 - Revision History for IP 92711

Issue Date:  05/16/19	Att1-1	92711