ML071340162

Post Strike Monitoring Activities - Updated 8/21/03

ML071340162
Person / Time
Site:	Oyster Creek
Issue date:	08/21/2003
From:	NRC Region 1
To:
References
FOIA/PA-2007-0175
Download: ML071340162 (19)

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OYSTER CREEK POST STRIKE MONITORING ACTIVITIES - UPDATED 8/21/03 Overview The Oyster Creek strike ended on August 7 and lasted 77 days. Reintegration of the bargaining unit staff commenced on August 11. The resident inspectors developed a post-strike inspection plan in accordance with the guidance contained in IMC 92712 that was approved by DRP management on August 12. The licensee's reintegration plan calls for several weeks of training for all returning staff prior to resumption of normal duties. While some staff in the radiation protection and chemistry areas may begin on-site duties the last week of August, most plant operators and maintenance technicians will not return to work until after the Labor Day holiday.

Until required training elements are completed, all control room operator positions are being staffed with current SROs, using a three crew, 12-hour/shift schedule. The operators remain on a "4 on/ 2 off" shift rotation. Other departments (maint., I&C, Rad Pro) have gone to a "5 - 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> day" schedule with weekends off. EP and Fire Brigade staffing are still being maintained at proper levels on back shifts and weekends.

All modified requal training for the SROs has been completed. A training schedule has been developed for returning licensed and non-licensed operators including completion of the requal training already completed by the SROs, proficiency watchstanding (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> for each license operator), and completion of the licensed operator requalification training in accordance with commitments made in support of the extension granted in June. On September 2, subsequent to the proficiency training, returning licensed and non-licensed operators will join the SROs in forming 5 operating crews that will work a new schedule having 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts. One week out of five will-be a training week that consists of 8-hour shifts.

Currently the resident inspectors are working a normal, first-forty schedule with weekend and backshift coverage for significant plant evolutions or emergent work, as well as significant training evolutions such as proficiency watchstanding. DRS has provided support in observing the modified licensed operator requalification training, as well as the commencement of requal training for the returning licensed operators. Region I senior management continue to discuss site performance observations on a weekly basis and have had frequent site visits (about every two weeks). The last senior manager visit occurred on August 13 - 14, and focused on the reintegration plan implementation. Please see the attached inspection plan for additional detail.

Current Overall Assessment The inspectors have noted no issues indicating fatigue or lack of knowledge while the returning staff have been away.

On August 14, the Oyster Creek plant scrammed from full power as a result of the grid collapse event that affected the Northeaster United States and parts of Canada. While the local grid for Oyster Creek did not lose power, resulting in the plant having sources of offsite power throughout the event, voltage fluctuations initially caused the generator protection logic to automatically trip the main generator and turbine, and a reactor scram resulted. Initial operator action to place the mode switch in shutdown was delayed because the switch stuck in run. This caused an automatic MSIV actuation about 30 seconds later when reactor pressure decreased to less than 850 psig. Subsequent troubleshooting of the mode switch didn't reveal any

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significant problem, however, the locking tumbler and key may have been slightly offset causing the switch lock to be engaged. Operators may not have been sensitive to the exacting requirement of the key position in the switch. Subsequently, all SROs have been informed of the difficulty in use of the mode switch and the complication that can cause during a plant transient (loss of PCS or normal heat sink).

A DRS inspector observed operator recovery actions in the control room. The SRI observed just-in-time training developed for the oncoming shift in order for them to practice a very infrequent evolution of going to cold shutdown with use of the Iso Condensers and the Shut Down Cooling systems. The training elements were appropriate for the SROs. The SRI then observed the same crew conduct the plant cooldown to a cold shutdown condition without any error.

The initial steps of reintegration have been relatively free of event. The licensee has added several security staff to their normal shift complement to observe activities in the plant parking lots and within the plant itself to increase the number of facility tours and awareness of the security personnel to plant conditions in an effort to be better postured to respond to potential acts of vandalism.

No PMs or required STs have been missed. In addition, the station backlogs were initially reduced during the strike. Backlog workoff flattened in July and held relatively constant since then, at or below station goals. While management focus has now shifted to reintegration of the returning staff, work schedule adherence and safe operation and risk management are clearly evident. Company management is well aware that some activities have been delayed or deferred and they conducted an evaluation to ensure that the decision to delay certain activities was appropriate.

DRS Operational Safety Branch has been observing the conduct of LORT training. Please see the attached discussion.

ATTACHMENTS:

1. LORT Training Observation Discussion

2. Post-Strike Inspection Plan

ATTACHMENT 1 Oyster Creek Training Overview Updated 8/20/03

SUMMARY

During session 1 overviews we have noted some weaknesses in the area of communications and command / control during more complex scenarios. During this session, one crew was observed to miss a critical task that would have resulted in crew failure, if the scenario was being used to test the crew. The crew was coached and returned to shift. During the first week of session 2 two individual failures occurred, remediation plans were establish and completed before the individuals returned to shift. During the second week of session 2 there were no failures. Overall, the training was useful for the operators. The facility evaluators continue to identify performance issues and address the issues through coaching and / or remediation of the individuals and / or crews.

Strike Status The contract was settled on August 11, 2003. In accordance with the exemption the requalification cycle must be completed 90 days after resolution of the strike (November 9, 2003). The following is the projected schedule to meet the November 9, 2003 deadline.

Aug. 11 - Sept. 1 Reintegration training / Reactivation of reactor operators.

(There are four reactor operators that are inactive and must stand 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> under instruction; One-on-One)

Sept. 2, - Oct. 3 Five-week crew training prior to the exam cycle.

Oct. 6 - Nov. 7 Five-week exam cycle.

Nov 9, 2003 Requalificaiton 2 year cycle ends.

TRAINING Each shift crew is divided into two training crews and receives the following training.

SESSION 1 June 24, July 2, July 10, each training crew received four hours of simulator training / coaching and four hours of class room training. The simulator training consisted of two scenarios and turbine controls training. This training was observed by a resident and two operator license examiners.

Scenario 1 normal evolution Core Spray Pump Surveillance minor malfunction loss of power to bus 1 B2 major event steam leak requiring Scram plus an ATWS Scenario 2 normal evolution EDG surveillance minor malfunction SLC tank heater failure malfunction condenser vacuum leak / reactivity change major event unisolable RWCU leak into secondary containment / SCRAM / Emergency Depressurization

ATTACHMENT 1 Observations In general, the performance was acceptable, with some noted weakness.

Communications were not sharp and there was some shifting of command and control as the scenario developed. None of these behaviors warranted a crew failure. Coaching addressed the communications and command/control issues.

The coaching was adequate and appropriate.

Scenario 1 In general, the training crews performed satisfactorily on this scenario.

However, there were some examples in which the training crews were slow to respond to plant indications as described below.

There was one example in which an operator allowed RPV pressure to drift out of a given pressure band, due to competing priorities of maintaining RPV level. This adverse pressure trend was identified and corrected within 50 psig of the designated pressure band. This would not have resulted in a crew failure and the crew was coached on this issue.

There was one example in which the shift manager (SM) acting as a control room supervisor (CRS) on the training crew had difficulty transitioning into the ATWS EOP. The shift technical advisor (SRO) assisted focusing the CRS in the EOPs. This resulted in delaying actions.

However, the actions were completed. This appeared to be an issue with the individual, not the crew and was complicated by the recent changes in Exelon's guidance to directing EOPs. EOP actions must be directed by the CRS, the operators cannot take action of an ATWS unilaterally, other than immediate actions from the scram procedures. This would not have resulted in a crew failure and the crew was coached.

There was one example in which the training crew did not insert a manual SCRAM before the drywell reached 3 psig. The training crew was coached and the scenario was re-run. The crew properly inserted a manual scram before the automatic scram occurred on the second run.

Failure to insert a manual scram before the automatic scram occurs would not have resulted in a crew failure.

Scenario 2 In general, the training crews did not perform as well on scenario 2 as the first scenario. Specifically, one training crew missed a critical task that would have resulted in a crew failure, if the crew was being tested. This scenario was more difficult than the first scenario because it required

ATTACHMENT 1 more communication and required critical parameters (Area Max Normal/

Max Safe Temperatures) to be obtained from the back panels.

One training crew failed to identify that one area exceeded a Max Safe Temperature and did not insert the required reactor scram. The crew was approaching a second area Max Safe Temperature when the scenario was stopped for coaching. When the scenario was restarted the crew identified the Max Safe Temperatures but depressurized using the turbine bypass valves instead of using relief valves as specified in the emergency operating procedures (EOPs). Coaching was conducted on the reactor pressure vessel (RPV) Control EOP. We concluded, as well as the operations manager that the crew would have failed if they were being tested. The failure would have resulted because they failed to complete the critical task of scramming the reactor when the first area exceeded a Max Safe Temperature. The crew received coaching during the training scenario and was coached by the director of operations before returning to licensed duties.

Several of the crews demonstrated weakness on the Secondary Containment Control Guideline; particularly on using "back panel" indicators to determine when an "area" exceeded Max Normal and/or Max Safe temperatures. The crews were coached on the Secondary Containment Control Guideline.

One training crew demonstrated weak command / control. The SM who was the CRS on the training crew demonstrated weakness in directing crew operations. Specifically, the CRS did not direct a load reduction to maintain vacuum above the scram set point and did not direct a manual scram until after an operator told him (CRS) to scram the reactor. In both of these cases he should have directed the action in the procedure rather than poling the operator's opinion prior to taking the action in the procedures. The crew as well as the individual was coached on these issues.

SESSION 2 July 30, August 7, August 15, each training crew will receive four hours of simulator training / coaching with an "as-found" evaluation and four hours of class room training.

The July 30, 2003, training consisted of 1 as-found scenario, plus remediation. (This crew only had 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of simulator due to E-Plan exercise in the afternoon.)

minor malfunction 1 Rod Drifting in

ATTACHMENT 1 major malfunction LOCA plus full ATWS, complicated by subsequent MSIV closure, loss of all CRD pumps and failure of System I SLC.

Observations Crew

• Performance Both crews completed all critical tasks and were considered "pass". These crews were more proficient than the crews that were observed on July 10. Their communication skills were very good and they were better prepared to use EOP flow charts. It should also be noted that the actual shift on duty at the plant would consist of all 10 individuals. The composite knowledge and skill of these 10 individuals exceeds either "crew, and is adequate to safely operate the facility.

Failures One individual in each crew was considered UNSAT.

Operator 1 missed some parameters that should have been communicated to the Unit Supervisor, had difficulty implementing the procedure for venting the drywell and did not secure feedwater in a timely manner.

His remediation included table-top practice with EOP support procedures and one-on-one instruction for bases of EOP support actions.

Operator 2 (CRS) had difficulty implementing the level/power part of the EOPs (chose the wrong level band) and missed entry conditions to RPV control and Primary Containment Control.

His remediation was to include additional simulator practice using EOP flow charts with similar (ATWS) scenarios.

Licensee Evaluators The licensee's process for evaluating the performance of the crews consisted of three individuals observing and documenting their observations, completing a post-scenario evaluation, documenting their findings, de-briefing the crews, and establishing necessary remediation plans. We concurred with the licensee's evaluation of the crews. The process was sufficient to adequately evaluate each operator and crew.

The Aug. 7, 2003, training consisted of one as-found scenario.

ATTACHMENT 1 minor malfunction EMRV inadvertent opening Feedwater heater trip CRD pump trip major malfunction Full ATWS with a failure of ARI, delay in depressurizing the scram air header (scripted) and failure of "A" feedwater pump.

Observations Crew Performance Both crews completed all critical tasks and were considered "pass". In addition, all individuals were judged a "pass". My comparative evaluation was that these two crews were more proficient than the crews I observed on July 10 and on July

30. Their communication skills were very good and they were prepared to use EOP flow charts and EAL charts.

Appropriate EALs (for the stuck open EMRV) were declared in five minutes for the first crew and 10 minutes for the second. This is noteworthy since they did not have an STA position filled for the scenario. They, also, anticipated use of AOPs, based on alarms and parameters, and were proficient on back panel operations/readings.

Failures None Licensee Evaluators I agreed with the licensee's evaluation of the crews. It should, also, be noted that the actual shift on duty at the plant would consist of all eight individuals plus an STA. The composite knowledge and skill of these eight individuals exceeds either "crew, and is adequate to safely operate the facility.

Other I also attempted to determine if there were outward signs of fatigue in the crew (due to the protracted strike coverage). I found no evidence of this. Whatever actions the licensee has been taking to control fatigue is, apparently, working.

REINTEGRATION RO Proficiency August 20, 2003, a total of 19 ROs were evaluated for proficiency. The NRC observed 14 of the 19 ROs. The ROs were tested in crews (2 ROs at a time) using a training instructor as the SRO. Each crew was evaluated using at least one short scenario.

ATTACHMENT 1 Scenario 1 minor malfunction Pressure Regulator Failure major malfunction Isolation Condenser Steam Leak EOP Scram / secondary containment temperatures Scenario 2 minor malfunction Loss of Condenser Vacuum major malfunction ATWS with condenser ATWS W/o condenser Scenario 3 minor malfunction Primary Containment Steam Leak Major malfunction ATWS with ARI successful Spray Drywell Observations Crew Performance Seven of the eight crews observed completed all actions satisfactorily. In general, these crews performed adequate panel manipulations and self check. Three way communication was adequate; however, it was noted that during times of increased activity and stress three way communications were reduced. This did not result in missed actions or incorrect actions.

Failures One crew failed the evaluation. This crew was remedaited and successfully passed a second evaluation later in the day.

This crew did not adequately control RPV level post trip.

Specifically, the crew did not secure Feedwater Pumps /

CRD Pumps for several minutes in accordance with procedures when level was greater than 170". In addition, communication was not directed and at a low volume level.

After remediation the crew was able to correctly maintain RPV level post scram and communications were directed and easily understood.

Licensee Evaluators The licensee's process for evaluating the performance of the crews consisted of two individuals observing and documenting their observations, completing a post-scenario evaluation, documenting their findings, debriefing the crews, and providing verbal remediation plans. We concurred with the licensee's evaluation of the crews. The process was sufficient to adequately evaluate each operator and crew.

ATTACHMENT 1 Other This evaluation was useful in that it provided an excellent tool to verify that each RO was mentally ready to return to licensed activities.

ATTACHMENT 1 OC REQUAL ACTION ITEMS:

1) Hub's site visit Wk of 7/28 Can the ROs return to shift without taking the annual operating exam and a comprehensive written exam?

Response

YES. The annual operating exam is required to be completed yearly. The last annual operating exams were completed in 2002. Therefore, the licensed operators must complete an annual operating exam before December 31, 2003.

The regulation does not required a "rolling year," just a calendar year.

Since the requal period has been exempted and extended to December 31, 2003, the written exam for the period does not have to be done until the end of the period.

The licensee does plan some evaluation prior to resuming licensed duties but it currently stops short of giving a written test. The conditions upon which the exemption was granted do not include a commitment to do this testing for the striking ROs resuming licensed duties should it occur before Dec. 31, 2003.

If the strike extends past October 1, 2003 and the facility reports they can not complete the acceleration program and required testing by Dec. 31, 2003 for the returning ROs, then the cleanest approach appears to be to terminate the RO licenses and have them apply with a waiver of the written and operating test.

The facility will have to certify completion of the acceleration program and required testing similar to what is done for INPO loanees. The program office has made it clear there will be no further exemptions or extensions.

If the strike extends past the end of the year, then the adequacy of the current program for SROs on watch, which is scaled back, will have to be questioned.

Basis 10 CFR 55.59 (a) (2) "Requalification," requires in part "Each licensee shall: .....

(2) Pass a comprehensive requalification written examination and an annual operating test.

ATTACHMENT 1

2) Resident Concern Wednesday 8/6/03 The reintegration plan for the reactivation of ROs has three ROs standing watch under-instruction with two SROs. Should the under-instruction watch be performed with a one SRO-to-one RO ratio or is the two SRO-to-three RO ratio acceptable?

Response

Reactivation of licensed operators should* (not shall) in this case be done on a one-to-one basis. Specifically, for normal activation, the RO reactivating must stand watch "in the position" to which the individual will be assigned. Based on the conditions, it would be prudent for the operators to reactivate. Exelon has pronounced that the operators on strike are NOT PROFICIENT and will provide reintegration training to make them proficient. It is not logical for the facility to say they are NOT PROFICIENT then cut a corner to reactivate them.

It should be noted that from a purely technical interpretation of the regulation (10 CFR 55.53(e)), the ROs are still active until October 1, 2003 and would not need to reactivate if they returned to work before October 2003. The licensee proposed 3 ROs on 2 SROs is better than nothing, not a violation of our regulations but still not logical in light of the facilities pronouncement.

Basis 55.53 (e) "Conditions of licenses," requires To maintain active status, the licensee shall actively perform the functions of an operator or senior operator on a minimum of seven 8-hour or five 12-hour shifts per calendar quarter.

10 CF 55.53(f), "Condition of License," states in part that "...before resumption of functions authorized by a license issued under this part, an authorized representative of the facility licensee shall certify the following:

(1) That the qualifications and status of the licensee are current and valid; and (2) That the licensee has completed a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift functions under the direction of an operator or senior operator as appropriate and in the position to which the individual will be assigned. The 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> must have included a complete tour of

ATTACHMENT 1 the plant and all required shift turnover procedures.

Technical Specifications Section 6.2.2.2 "Facility Staff," require two (2) licensed Nuclear Plant Operators. If Exelon has two ROs in the control room (reactor and balance of plant), then no more than two reactor operators can be under-instruction in the control room at a time because there are only two positions to which the individual will be assigned.

3) Resident Concern Wednesday 8/6/03 The residents are concerned that if the ROs do not start the reintegration by October 2003, that Exelon may request a second exemption to allow the ROs to resume licensed duties after December 31, 2003, without completing the required exams.

Response

The current exemption requires the biennial written exam and the annual operating exam to be completed by December 31, 2003. To meet the condition of their license the ROs and SROs must complete the biennial written exam and annual operating exam by December 31, 2003. Based on discussions with Dave Muller (author of original Exemption Request) we do not plan to issue another exemption to allow the RO to return to shift without completing the exams after December 2003.

As noted above the cleanest way is to terminate license and request waiver.

4) COMPLETE Response to State of New Jersey Letter on training 7/30/23 Complete Determine the changes to the licensed operator requalification program and then based on this information perform steps (2), (3) and (4).

Complete Respond to the state of New Jersey's July 8, 2003, letter with the information gathered in (1) above.

Complete Discuss above items with J. Lipoti, NJDEP by Friday July 18, 2003.

Complete Determine the need for additional Licensed Operator Requalificaiton Program inspection (IP 71111.11). This could be a

ATTACHMENT 1 for cause exams, 71111.11 Inspections, or continued monitoring.

Letter sent to state of New Jersey on Wednesday July 30, 2003.

FUTURE TRAINING DATES SESSION 2 July 30, August 7, August 15, each training crew will receive four hours of simulator training / coaching and four hours of class room training. This session will also include

• "as-found," scenario evaluation for each training crew 0 Remediation as needed / additional scenarios

• Simulator training to ensure / reinforce that all individuals understand that the reactor should be manually scrammed based on parameter trends rather than waiting until a scram set point is exceeded. (Based on weakness observed during June / July training.

Session 3, 4, & 5 will be canceled because of the completion of the strike on August 11, 2003. See preliminary schedule on page 1.

SESSION 3 September 8-9, September 16-17, September 22-23, September 30-October 1, each training crew will receive four hours of simulator training / coaching and four hours of class room training. This session will also include 0 Annual Requalification JPMs (part of annual operating test)

• "as-found," scenario evaluation for each training crew (most likely-but not finalized yet)

• additional content based previously identified weaknesses in Session 2.

SESSION 4 October 16-17, October 20-21, October 28-29, November 7-10, each training crew will receive at least four hours of simulator training / coaching and four hours of class room training. This session will also include 0 Biannual Requalification written exam

• "as-found," scenario evaluation for each training crew (most likely-but not finalized yet)

ATTACHMENT 1

• additional content based previously identified weaknesses in Session 3.

SESSION 5 November 12-13, November 19-20, December 3-4, December 11-12, This session may not contain any simulator training. The two day period may be completely used for the simulator scenario portion of the annual operating test.

ATTACHMENT 2 Oyster Creek Post Strike (Reintegration) Inspection Plan August 12, 2003 Inspection Dates:**

August 6, 2003 thru September 27, 2003

• • End date may change based upon issues revealed during inspection Inspectors:**

Bob Summers - OC SRI Steve Dennis - OC RI Gil Johnson (or alternate) - DRS Alan Blamey - DRS Tom Hipschman - DRS

• • Other inspectors TBD as needed Inspection Guidance:

IP 92711 - Continued Implementation of Strike Plans During an Extended Strike IP 92712 - Resumption of Normal Operations After a Strike RI 1080.2 - NRC Preparations for Pending Licensee Strike Background/Purpose:

On May 22, 2003, IBEW Local 1289, representing over 200 workers at Oyster Creek, went on strike after talks broke down during contract negotiations with AmerGen. NRC Inspectors and senior managers have monitored plant operation since the strike began to ensure the licensee's strike contingency efforts were effective in maintaining public health and safety. On August 5, 2003, following weeks of negotiations, the union bargaining group agreed to present AmerGen's latest contract offer to the union members for a vote. On August 7, 2003, the union members approved the contract and will begin to return to Oyster Creek on August 11, 2003.

f Due to the lengthy strike (over 11 weeks), additional inspection focus is needed to ensure a safe transition to normal plant operations. The inspection effort will determine the efficacy of the licensee's implementation of their reintegration plan and evaluate the resumption of normal plant operations. Additionally, the inspection will also focus on human performance, which is a substantive cross-cutting issue at OC in the area of procedure adherence inadequacies.

ATTACHMENT 2 16 Inspection Objectives: (IP 92712, IP 92711, RI 1080.2)

1. Review Licensee Reintegration Plan (Summers, Dennis, DRP, DRS)

- Verify an orderly turnover plan has been developed for all affected departments.

- Verify the plan addresses training and qualification issues.

- Verify the plan addresses employee concern issues which may arise during the reintegration.

- Verify the plan addresses any backlog issues in the engineering department.

- Verify that deviations to the plan are documented and addressed lAW licensee corrective action program.

- Verify May 30, 2003, and June 26, 2003, exemption request commitments are being met.

- Verify that plans are in place for Licensed Operators to complete all missed training/testing required for maintaining an active license lAW 10CFR55.

- Verify the plan includes adequate measures to prevent tampering with plant equipment or data as well as to promptly detect and react to tampering that might occur.

- Verify the plan provides for appropriate decision making as to whether or not individuals or groups are ready to return to in plant work.

2. Review Licensee's Operations Organization (Summers, Dennis, DRS)

- Review requalification training evaluations to verify that operators are proficient. Use guidance from 71111.11 B & Q.

- Verify that operations shift crews are staffed in lAW with Tech Spec requirements.

3. Training and Qualification (Summers, Dennis, DRP)

- Review and verify a sample of training and qualification records for returning personnel in the maintenance, I&C, Rad Pro, Fire Protection, and Chemistry organizations to verify the records are current and personnel have up-to-date proficiency. Interview personnel as appropriate.

4. Emergency Preparedness (DRS - during week of graded exercise on September 9, 2003)

- Verify through a sample of training records review that records are current and returning personnel are cognizant of their roles and responsibilities in the EP organization. Interview personnel as appropriate.

5. Security (Summers, Dennis)

- Verify that security management and security officers have addressed and are prepared to deal with emergent issues onsite, including tampering, and during plant entry and exit.

6. Plant Conditions/Crew Turnovers (Summers, Dennis, DRS, DRP)

- Observe control room crew turnovers to ensure issues and duties are communicated and deficiencies are understood.

- Observe job briefings, in all departments, for normal surveillance activities and emergent issues, to ensure personnel communication, procedure adherence, and job knowledge are adequate.

- Accompany operators on building rounds and observe other department personnel during performance of maintenance activities to verify adequate job knowledge and procedure adherence.

ATTACHMENT 2 17

7. Engineering (Hipschman)

- Review and assess engineering corrective action backlog to determine if any risk significant issues have been deferred and if so, how they are being addressed and how do they affect plant operation.

8. Maintenance (Summers, Dennis, DRP)

-.Continue to track work scheduling backlog in PMs, STs, Corrective and Elective Maintenance.

Inspection Schedule:

Weekend and round the clock site coverage is not recommended at this time. Once operations department proficiency watches begin (August 18) - 2 shift coverage is recommended. (NOTE:

due to the response to the grid event on August 14, the resident staff did not begin 2-shift coverage on August 18. Additional control room observations of turnover involving the proficiency watch-standers began on August 20. Extended shift coverage will continue during the next week.) Once other department staffing and normal work week scheduling returns to normal (September 1) - weekend coverage should be considered. These recommendations can be adiusted and are contingent on plant operational issues.

August 6 - 15

- Review reintegration plan Inspection Effort:

1 inspector, 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> August 11 - 15

- 50 people per day will return to work, for two days only, during the first week. Each group of 50 will receive one day of training on the backsite consisting of GET, FFD, and senior management discussion of worker expectations, core values, employee conduct, and other "soft" issues affecting worker relationships with supervision and peers. Day two will consist of a plant tour and general housekeeping duties. The remaining three days of the week for each group will be vacation days off, with the exception of the operators, who will report to training.

Inspection Effort:

2 or 3 inspectors, in plant, 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each, per week - day shift 1 DRS inspector to observe operator training on August 15 - 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> August 18 - September 27

- Operations will begin on shift proficiency watches for ROs, around the clock

- Maintenance, I&C, and Rad Pro will begin 2 weeks of offsite training and requalification.

- Maintenance, I&C, and Rad Pro return to the plant the week of 9/1/03 Inspection Effort:

2 or 3 inspectors - 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per week/2 overlapping shifts - observe Ops turnovers & RO proficiency watches.

ATTACHMENT 2 18 1 DRS Inspector as necessary, August 18 & 19 - to observe RO reintegration training.

DRS requal inspection to be scheduled this fall - Date TBD Additional Inspection effort information:

Conduct of Inspection MC 0612 will be the guidance utilized for determining the thresholds of findings such as greater than minor. In addition, findings which are considered to be potentially greater than minor should be evaluated consistent with MC 0609, "Significance Determination Process (SDP),"

dated 4/30/2002. Observations, findings, or potential violations will be discussed daily with the SRI/RI. Also, findings of potential risk significance should be discussed with the SRI/RI at the time of identification or as soon as possible. SRI/RI will brief Branch Chief as needed.

Documentation and Information Requests Documents and information requested during the course of the inspection will be listed, tracked, and documented by the individual inspectors and provided to the SRI/RI when submitting inspection documentation.

Inspection Report Documentation Format The outline of Manual Chapter 0612 is to be followed. Any documentation for the inspection report must be provided to the SRI/RI by October 1, 2003.

STARFIRE Information:

Inspection time charges to STARFIRE = Feeder to Inspection Report 50-219/2003-004 Preparation Time = GIP, 50-219/2003-004 Inspection Time = OA, IP 92712, 50-219/2003-004 Documentation Time = GID, 50-423/2003-004 Estimated insp. hrs for this inspection procedure = approx. 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> and includes all DRS/DRP efforts**

• • estimate is based upon 40-50 hours per for 4 to 6 weeks

• • some of the inspection effort will be counted toward other ROP baseline inspection requirements Site Contacts Licensee Dave Slear, Licensing (609) 971-4112

ATTACHMENT 2 19 Bill Stewart, Reg Affairs (609) 971-4775 NRC Bob Summers or RI Office - (609) 693-0702/0717 Steve Dennis Resident Cell Ph. - 484-868-1476