ML13268A165

Approval of Safe Storage Shift Manager/Certified Fuel Handler Training Program

ML13268A165
Person / Time
Site:	San Onofre
Issue date:	08/01/2014
From:	Chernoff M Plant Licensing Branch IV
To:	Thomas J. Palmisano Southern California Edison Co
Chernoff M
References
TAC MF2601, TAC MF2602
Download: ML13268A165 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 1, 2014 Mr. Thomas J. Palmisano Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128

SUBJECT:

SAN O[':JOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3-APPROVAL OF SAFE STORAGE SHIFT MANAGER/CERTIFIED FUEL HANDLER TRAINING PROGRAM (TAC NOS. MF2601 AND MF2602)

Dear Mr. Palmisano:

By letter dated August 20, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13234A024), as supplemented by letters dated September 3, 2013, and February 6, 2014 (ADAMS Accession Nos. ML13248A108 and ML14041A209, respectively), Southern California Edison (SCE) submitted the San Onofre Nuclear Generating Station (SONGS), Unit 2 and 3 Safe Storage Shift Manager/Certified Fuel Handler (SM/CFH) training program for approval. By letter dated June 12, 2013 (ADAMS Accession No. ML131640201), SCE submitted a certification to the U.S. Nuclear Regulatory Commission (NRC) indicating it permanently ceased power operations at SONGS, Units 2 and 3 on June 7, 2013. Accordingly, the licenses for SONGS, Units 2 and 3 no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel.

The purpose of the SM/CFH training program is to ensure that the qualifications of the Shift Manager and Certified Fuel Handlers are commensurate with the tasks to be performed and the conditions requiring response.

The NRC has reviewed the submittals and approves the SONGS, Units 2 and 3 Certified Fuel Handler training program as requested.

T. Palmisano A copy of the NRC staff's Safety Evaluation is enclosed.

Sincerely, mo -./!. C4..6JO Margaret H. Chernoff, Senior Project Manager Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362

Enclosure:

Safety Evaluation cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE SAFE STORAGE SHIFT MANAGER/CERTIFIED FUEL HANDLER TRAINING PROGRAM SOUTHERN CALIFORNIA EDISON SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 DOCKET NOS. 50-361 AND 50-362

1.0 INTRODUCTION

By letter dated August 20, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13234A108), as supplemented by letters dated September 3, 2013, and February 6, 2014 (ADAMS Accession Nos. ML13248A108 and ML14041A209, respectively), Southern California Edison (SCE), the licensee for San Onofre Nuclear Generating Station (SONGS), Units 2 and 3, submitted its proposed Safe Shutdown Shift Manager/Certified Fuel Handler (SM/CFH) training program to ensure that the qualifications of the Shift Manager and Certified Fuel Handlers are commensurate with the tasks to be performed and the conditions requiring response. This request was submitted as a result of SCE's decision to permanently cease operation of SONGS, Units 2 and 3.

By letter dated June 12, 2013 (ADAMS Accession No. ML131640201), SCE submitted a certification to the U.S. Nuclear Regulatory Commission (NRC) indicating it had permanently ceased power operations at the SONGS, Units 2 and 3 (SONGS) on June 7, 2013. By letters dated July 22, 2013 (ADAMS Accession No. ML13204A304), and June 28, 2013 (ADAMS Accession No. ML13183A391 ), SCE certified that it had permanently defueled the SONGS Units 2 and 3 reactor vessels. The Part 50 licenses for SONGS, Units 2 and 3 no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel.

2.0 REGULATORY EVALUATION

The regulatory framework concerning operator and fuel handler staffing was discussed by the U.S. Nuclear Regulatory Commission (NRC) staff in Attachment 1, "Integrated Rulemaking Plan for Emergency Planning, Insurance, Safeguards, Staffing and Training, and Backfit at Decommissioning Nuclear Power Plants" to SECY-00-145, "Integrated Rulemaking Plan for Nuclear Power Plant Decommissioning," dated June 28, 2000. As noted therein, The operator staffing regulations in 10 CFR 50.54(m) specify the minimum licensed operator staffing levels for operating reactors (e.g., minimum staff per shift for licensed operators and senior Enclosure

operators) but do not provide any alternatives for licensees that have certified that they are permanently shutdown and defueled under 10 CFR 50.82(a)(1 ). For decommissioning plants, the NRC has been approving license amendments that discontinue the requirements for licensed operators and allow shift staffing consisting of a certified fuel handler (certified by an NRC-approved training program) and an additional nonlicensed operator ..

In August 1996, a major decommissioning rule became effective that made a number of changes to 10 CFR Part 50 to simplify the decommissioning regulations. One of the changes involved the adoption of a definition of "certified fuel handler in 10 CFR 50.2.

The certified fuel handler is intended to be the onshift licensee representative who is not only responsible for safe fuel handling operations at a decommissioning plant, but is always present on shift to ensure the safe maintenance and storage of spent fuel and the overall safety of any decommissioning-related activities at the facility. However, there are no regulations that specify substantive requirements for the presence and regulatory responsibilities of a certified fuel handler during decommissioning.

In addition, the certified fuel handler must be qualified in accordance with a certified fuel handler training program approved by the Commission. However, there are no regulations besides the definition that specifies the training requirements for the certified fuel handler.

• Considering the definition of CFH in 10 CFR 50.2 and the background provided by Final Rule, Decommissioning of Nuclear Power Reactors, 61 Fed. Reg. 39278 (July 29, 1996), which added the definition, plus the insights provided in SECY-00-145, the NRC staff determined that an acceptable CFH training program should ensure that the trained individual has requisite knowledge and experien,ce in spent fuel handling and storage, reactor decommissioning, and is capable of evaluating plant conditions and exercising prudent judgment for emergency action decisions. In addition, since the CFH is defined as a non-licensed operator, the NRC staff also used the criteria in 10 CFR 50.120 and assessed the program against the elements of a systems approach to training provided in the definitions section of 10 CFR 55.4.

Following issuance of the 1996 decommissioning rule, the NRC commenced review and approval of CFH training programs for permanently shutdown and defueled reactors consistent with the requirements in the rule. Reactors that permanently shutdown would reassess their staffing plans related to decommissioning organization structure; retaining, re-assigning or releasing staff; and meeting minimum staffing requirements in technical specifications and regulatory required programs (e.g., emergency response organizations, fire brigade size, security, etc.). The effort balanced personnel and plant status commensurate with the reduced risk once the certifications associated with permanent cessation of operation had been submitted. Included in the effort was the transition from licensed operators to CFHs. With a simplified operating configuration in the perr'nanently shutdown and defueled condition, licensed

operators were replaced with CFHs following NRC approval of the CFH training program .

. Consistent with these changes, the training and requalification programs required by 10 CFR 55 were modified to reflect the reduced staffing levels and responsibilities of the operations staff.

Past practice by the NRC related to review of a CFH training program (see NRC safety evaluations for Maine Yankee, dated November 26, 1997 (ADAMS Accession No. ML9712040233), and Zion, dated July 20, 1998 (ADAMS Accession No. ML9807240263) included confirming that the program was based on a systems approach to training (SAT) as defined in 10 CFR 55.4. On May 12, 2014 the NRC staff approved a CFH program for Kewaunee (ADAMS Accession No. ML14104A046).

Therefore, the regulatory requirements that the NRC staff used in its review of the SONGS Certified Fuel Handler training program are as follows:

1. 10 CFR 50.2, "Definitions," Certified Fuel Handler means, for a nuclear power reactor facility, a non-licensed operator who has qualified in accordance with a fuel handler training program approved by the Commission.

2. 10 CFR 50.120, "Training and qualification of nuclear power plant personnel."

(b)(2) The training program must be derived from a systems approach to training as defined in 10 CFR 55.4, and must provide for the training and qualification of the following categories of nuclear power plant personnel:

(i) Non-licensed operator.

(b)(3) The training program must incorporate the instructional requirements necessary to provide qualified personnel to operate and maintain the facility in a safe manner in all modes of operation. The training program must be developed to be in compliance with the facility license, including all technical specifications and applicable regulations. The training program must be periodically evaluated and revised as appropriate to reflect industry experience as well as changes to the facility, procedures, regulations, and quality assurance requirements. The training program must be periodically reviewed by licensee management for effectiveness. Sufficient records must be maintained by the licensee to maintain program integrity and kept available for NRC inspection to verify adequacy of the program.

3. 10 CFR 55.4, "Definitions." Systems approach to training means a training program that includes the following five elements:

(1) Systematic analysis of jobs to be performed.

(2) Learning objectives derived from the analysis which describe desired performance after training.

(3) Training design and implementation based on the learning objectives.

(4) Evaluation of trainee mastery of the objectives during training.

(5) Evaluation and revision of the training based on the performance of trained personnel in the job setting.

3.0 TECHNICAL EVALUATION

The staff reviewed the specific elements of the SONGS SM/CFH training and retraining program against the regulatory requirements of 10 CFR 50.120, consistent with previous NRC staff reviews and approvals of decommissioning reactor CFH programs, together with certain other elements of 10 CFR 50.120 applicable to training programs.

3.1 CFH Training Program Broad-Scope Objectives Based on the discussion of applicable regulatory requirements in Section 2.0, the staff used the following three broad-scope objectives for review of the SM/CFH training program:

(1) Safe conduct of decommissioning activities (2) Safe handling and storage of spent fuel (3) Appropriate response to plant emergencies The staff examined the SONGS SM/CFH training program for these objectives. In its description of the SONGS SM/CFH Training Program, SCE states that the SM/CFH "program is designed to ensure personnel are qualified to perform assigned tasks. The program applies to individuals selected as shift manager/certified fuel handers for SAFSTOR." The program also "ensures that the qualifications of the Shift Manager and Certified Fuel Handlers are commensurate with the tasks to be performed and the conditions requiring response." The training program "provides adequate confidence that appropriate SAT based training of personnel who will perform Shift Manager and Certified Fuel Handler duties is conducted to ensure the facility is maintained in a safe and stable-condition."

The proposed training and retraining program was reviewed. This program requires lectures and/or self-study activities, on-the-job training and testing related to the facility license (content, bases, and importance of Technical Specifications) as well as on procedures and facilities. The procedures include abnormal and emergency operations, radiation protection and industrial safety, shift manager functional duties and responsibilities, supervisory responsibilities, and administrative requirements. The NRC staff finds inclusion of these topics to be consistent with objective (1) above.

The program also includes lectures and/or self-study activities, on-the-job training and testing related to the monitoring, handling, storage, and cooling of nuclear fuel. The training program addresses design, function, and operation of systems used in handling, storage, cooling and monitoring of nuclear fuel, radiological safety principles, theoretical principles and normal and abnormal operations The NRC staff finds this to be consistent with objective (2) above.

The staff also found that the training and retraining program include a focus on the use of normal, abnormal and emergency procedures. Also included is training on accident analysis and the plant Emergency plan. The training program requires the SM/CFH to be qualified as an Emergency Coordinator. The staff finds this to be consistent with objective (3) above.

Therefore, the NRC staff concludes that the SONGS SM/CFH training and retraining program meets all of the broad-scope objectives discussed above.

3.2 Training Program Evaluation 3.2.1 Use of the Systems Approach to Training (SAT)

In its August 20, 2013 submittal, SCE stated that the SONGS Units 2 and 3 Certified Fuel Handler Training and Retraining Program was based on analyses consistent with the SAT method defined in 10 CFR 55.4, and was developed using the SAT in 10 CFR 50.120, "Training and Qualification of Nuclear Power Plant Personnel."

The licensee's submittal included S023-XXI-TPD-SMCFH, "Safe Storage Shift Manager/Certified Fuel Handler Training Program Description." In this document, SCE states that the SM/CFH training and retraining program "describes the training program to be implemented by SONGS to ensure the monitoring, handling, storage and cooling of nuclear fuel is performed in a manner consistent with ensuring the public health and safety. The program describes the personnel to whom the program applies, the areas in which training is provided, what constitutes certification, how certification is maintained and required qualifications."

The staff has reviewed the SONGS SM/CFH training program to ensure that it includes all five of the required elements of a SAT-based program:

(1) Systematic analysis of jobs to be performed.

(2) Learning objectives derived from the analysis which describe desired performance after training.

(3) Training design and implementation based on the learning objectives.

(4) Evaluation of trainee mastery of the objectives during training.

(5) Evaluation and revision of the training based on the performance of trained personnel in the job setting.

In the supplemental letter dated February 6, 2014, SCE stated that SONGS document S023-XXI-TRN, Conduct of Training, directs the use of a systems approach to training to govern the development and implementation of the SM/CFH training program. After SONGS permanently ceased operations, staff performed a CFH job analysis by collecting information from a variety of sources to understand job performance requirements and training needs. This meets elements ( 1) and (2) of the SAT.

Element 3 of a SAT-based program requires that the training design and implementation be based upon the learning objectives. In the supplemental letter dated February 6, 2014, SCE stated that the tasks and their associated lesson plans, which contain the learning objectives for that task, are listed in the SM/CFH Training Program Description. The licensee stated that the SM/CFH Training Program for Units 2 and 3 was derived from the Unit 1 CFH Training Program and the Units 2 and 3 licensed operator training program, and thus the learning objectives for the SM/CFH training program had already been developed. The licensee further states that development of new or modified learning objectives as a result of changes to the CFH job is prescribed in the station procedure for Conduct of Training. The NRC staff reviewed the licensee's description of its process to design and implement training based upon the learning objectives and concluded that element 3 of the SAT process is satisfied.

In section 6.3.9.2 and 6.3.9.3 of the Training Program Description, the licensee's training/retraining program description states the trainees are evaluated by written and oral examinations both requiring a minimum score of 80% to pass and an operating exam consisting of five Job Performance Measures with critical steps that form the bases for failure as required by element (4), above.

Section 6.4.6 requires routine assessments of the effectiveness and accuracy of training by appropriate management during and at the end of each two year training cycle. Any required changes to the program determined by station management, shall be incorporated into the program. Because the program evaluations include assessments both during and after training, and provides management oversight of both the effectiveness and accuracy of training, the staff finds the bi-annual program evaluation acceptable and consistent with element (5).

3.2.2 Additional10 CFR 50.120(b)(3) Requirements The NRC staff also verified that the licensee's SM/CFH training and retraining program met the requirements of 10 CFR 50.120(b)(3). Specifically 10 CFR 50.120 (b)(3) requires that the training program:

a. incorporate the instructional requirements necessary to provide qualified personnel to operate and maintain the facility in a safe manner in all modes of operation;

b. be developed to be in compliance with the facility license, including all technical specifications and applicable regulations;

c. be periodically evaluated and revised as appropriate to reflect industry experience as well as changes to the facility, procedures, regulations, and quality assurance requirements; *

d. be periodically reviewed by licensee management for effectiveness; and,

e. ensure the licensee maintains and keeps available sufficient records to maintain program integrity and allow for NRC inspection to verify the adequacy of the program.

The NRC staff reviewed the SONGS SM/CFH training and retraining program and confirmed that each of the 10 CFR50.120(b)(3) requirements are satisfied as discussed below:

The instructional requirements for the SM/CFH training and retraining program are contained in Attachment 3 of the Training Program Description. These requirements were developed using the SAT process, as described previously. The instructional areas include those necessary to

' *ensure that the SM/CFH are trained in the areas necessary to maintain the facility and operate equipment in a safe manner. The NRC staff finds this satisfies element a above.

The regulations require that the training program must be developed to be in compliance with

. the facility license, including all technical specifications. Section 1.2 of the Training Program Description states that the program shall be in accordance with ANSI N18.1, "Selection and Training of Nuclear power Plant Personnel," consistent with the level of hazard at the facility and to ensure the facility is maintained in a safe and stable condition. The NRC staff finds this to be consistent with requirement b above.

In its February 6, 2014, letter, the licensee stated that as training needs for CFH's arise because of changes to plant systems, procedures, or staffing, procedure S023-XXI-TRN, Conduct of

Training, requires that the task list be updated to reflect changes to the CFH job. The SM/CFH Training Program Description states that routine assessments of the effectiveness and accuracy of training are made by SONGS management personnel during and at the end of each two-year training cycle. Required changes to the program will be incorporated into the program. The staff reviewed the licensee's description of the provisions for evaluating and revising the SM/CFH training program and concluded that the provisions satisfy the program evaluation requirements of 10 CFR 50.120(b)(3), as summarized in elements c and d above.

In section 8.0 of the Training Program Description, the licensee's training/retraining program description states that records associated with the SFM/CFH Training and Retraining program shall be collected and maintained by the Training Program Owner. The NRC staff determined that this provision satisfies element e above.

4.0 CONCLUSION

The staff has completed its review of the SONGS Certified Fuel Handler training program. The described program is consistent with SAT processes defined by 10 CFR 55.4 and fulfills the requirements of 10 CFR 50.120(b)(2) and (3). Based on the finding and conclusions described above, the staff approves the SONGS Certified Fuel Handler training program. In accordance with 10 CFR 50.120, sufficient records must be maintained by the licensee to maintain program integrity and kept available for NRC inspection to verify adequacy of the program.

Principal Contributor: Molly J. Keefe

ML13268A165 OFFICE NRR/DORULPL4-2/PM NRRIDORULPL4-2/LA NRR/DRAIAHPB/BC NAME MChernoff JBurkhardt DC hung DATE 06/24/14 06/02/14 06/26/14 OFFICE OGC NRR/DORULPL4-2/BC N RR/DORULPL4-2/PM NAME DRoth- NLO DBroaddus MChernoff DATE 07/03/14 07/31/14 08/01/14