ML13309A750
| ML13309A750 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 10/30/2013 |
| From: | Mark D. Sartain Dominion, Dominion Energy Kewaunee |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 13-278B | |
| Download: ML13309A750 (7) | |
Text
'Dominion Energy Kewaunee, Inc.
5000 Dominion Boulevard, Glen Allen, VA 23060ominioW Web Address: www.dom.com October 30, 2013 U. S. Nuclear Regulatory Commission Serial No. 13-278B Attention: Document Control Desk LIC/CDS/RO Washington, DC 20555-0001 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE, INC.
KEWAUNEE POWER STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR APPROVAL OF SHIFT MANAGER / CERTIFIED FUEL HANDLER TRAINING PROGRAM (TAC MF2370)
By letter dated June 17, 2013 (Reference 1), Dominion Energy Kewaunee, Inc. (DEK),
requested approval of the Kewaunee Power Station (KPS) Shift Manager / Certified Fuel Handler (CFH) Training Program. As stated in that letter, approval of the KPS CFH Training Program is needed to facilitate activities associated with decommissioning and irradiated fuel management as documented in DEK's Post-Shutdown Decommissioning Activities Report and Updated Irradiated Fuel Management Plan.
Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the CFH Training Program (References 2 and 3).
The RAI questions and associated DEK response are provided in Attachment 1 to this letter. In addition to the CFH Training Program, this response also relates to submittals associated with NRC tracking numbers TAC MF1952 (Permanently Defueled Technical Specifications) and TAC MF2743 (Exemption from 10 CFR 50.54(m)).
Please contact Mr. Jack Gadzala at 920-388-8604 if you have any questions or require additional information.
Sincerely, Mark D. Sartain Vice President - Nuclear Engineering and Development
Attachment:
- 1. Response to Request for Additional Information
Serial No. 13-278B Certified Fuel Handler Training Program Page 2 of 2
References:
- 1. Letter from Paul A. Blasioli (DEK) to NRC Document Control Desk, "Request for Approval of Shift Manager / Certified Fuel Handler Training Program," dated June 17, 2013 (ADAMS Accession No. ML13176A117)
- 2. Email from Karl D. Feintuch (NRC) to Jack Gadzala, Craig Sly, et al (DEK),
"MF2370 - Review of Training Plan for Certified Fuel Handler (CFH) training -
Request for Additional Information (RAI)," dated September 25, 2013
- 3. Email from Karl D. Feintuch (NRC) to Jack Gadzala, Craig Sly, et al (DEK),
"MF2370 - Review of Training Plan for Certified Fuel Handler (CFH) training -
[Corrected] Request for Additional Information (RAI)," dated September 27, 2013 Commitments made by this letter: None cc:
Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Dr. K. D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-Dl 5 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707
Serial No. 13-278B ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:
REQUEST FOR APPROVAL OF SHIFT MANAGER / CERTIFIED FUEL HANDLER TRAINING PROGRAM KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.
Serial No. 13-278B Page 1 of 4 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:
REQUEST FOR APPROVAL OF SHIFT MANAGER / CERTIFIED FUEL HANDLER TRAINING PROGRAM By letter dated June 17, 2013 (Reference 1), Dominion Energy Kewaunee, Inc. (DEK),
requested approval of the Kewaunee Power Station (KPS) Shift Manager / Certified Fuel Handler (CFH) Training Program. As stated in that letter, approval of the KPS CFH Training Program is needed to facilitate activities associated with decommissioning and irradiated fuel management as documented in DEK's Post-Shutdown Decommissioning Activities Report and Updated Irradiated Fuel Management Plan.
Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the CFH Training Program (References 2 and 3).
The RAI questions and associated DEK response are provided below.
NRC Question MF2370-RAII-AHPB-Keefe-001-2013-09-25 Please describe the version control process(es) by which modifications to the training program, if any, are implemented for personnel who had completed their CFH qualification activities prior to when the modifications were or would be made.
Of particular interest would be changes that might occur as a result of the NRC staff review of the CFH Training Program under TAC MF2370.
Response
Procedure TR-KW-101, "Conduct of Training," Section 3.4, "Request for Training Submittal and Review," would be used for assessing changes to the CFH Certified Fuel Handler Program. Any additional or different training required for incumbents, would be assessed by the training program owner, based on the requirements of Procedure TR-KW-101. Procedure TR-KW-101 was submitted to NRC on September 17, 2013, along with a response to a request for additional information regarding the CFH Training Program (Reference 4).
DEK has procedural controls in place for implementing changes following NRC approval. Changes to the CFH Training Program that might occur as a result of the NRC staff review under TAC MF2370 would be subject both to the administrative controls for implementing NRC approved changes in LI-AA-101, "Licensing Basis Document Control Process," and to the requirements of Procedure TR-KW-101.
Initially, any changes to the training program are processed per the requirements of Procedure TR-KW-101 and the program then becomes formally approved. After NRC approval, LI-AA-101 administrative controls require a review to ensure that the approved program is consistent with the staffs safety evaluation report.
Serial No. 13-278B Page 2 of 4 NRC Question MF2370-RAII-AHPB-Keefe-002-2013-09-25 Section 6.7.2 of the Certified Fuel Handler Training Program describes exemptions for Initial and Continuing Training requirements and specifies that the Operations Manager can be the manager who decides these exemptions.
NUREG-1625, "Proposed Standard Technical Specifications for Permanently Defueled Westinghouse Plants," a draft NUREG dated March, 1998, which is based on approved Trojan defueled technical specifications, specifies that this responsibility is assigned to the position of the "Plant Superintendent" and intended for the management level having overall responsibility for the facility.
- a. Does the Kewaunee Operations Manager have the overall responsibility for the facility?
- b. Please describe the management organizational structure at the Kewaunee facility.
Response
- a. The Kewaunee Operations Manager does not have the overall responsibility for the facility. In accordance with Technical Specification (TS) 5.1.1, the plant manager has the overall responsibility for the facility. TS 5.1.1 will continue to maintain the plant manager as the individual with overall responsibility for the facility even after approval of the permanently defueled TS.
- b. The management organizational structure at the Kewaunee facility is described in the Dominion Nuclear Facility Quality Assurance Program Description (QAPD)
DOM-QA-1. QAPD revisions are prepared and submitted to the NRC as required by 10 CFR 50.54(a).
DOM-QA-1, Section 1, "Organization," provides the following description for Operations.
The Operations group is responsible for operating the facility in accordance with the applicable license, including those in a decommissioning phase that still contain nuclear fuel.
Overall facility operation is directed by a management position responsible for Operations activities.
At KPS, the operations manager reports directly to the plant manager.
The operations manager has the overall responsibility for activities involving safe handling of nuclear fuel, including the supervision of Certified Fuel Handlers.
As such, the operations manager is the appropriate management position with responsibility for training of Certified Fuel Handlers.
Serial No. 13-278B Page 3 of 4 NRC Question MF2370-RAII-AHPB-Keefe-003-2013-09-25 Has the licensee developed a program evaluation element, consistent with 10 CFR 55.4, Systems approach to training, (5), Evaluation and revision of the training..., in its proposed training program to assure continuing effective training over the long term? If so, please describe the program. If not, please identify why this is acceptable.
Response
Yes.
Procedure TR-KW-101, "Conduct of Training," Section 3.17, requires the completion of an annual review of the Training Programs (including Certified Fuel Handler), by the Program Owner/Training Supervisor, to evaluate and resolve issues to ensure Training Program effectiveness. Procedure TR-KW-101 was submitted to NRC on September 17, 2013, along with a response to a request for additional information regarding the CFH Training Program (Reference 4).
Additional information regarding the Systems Approach to Training is discussed in the response to NRC Question MF2370-RAII-AHPB-Keefe-004-2013-09-25 below.
NRC Question MF2370-RAII-AHPB-Keefe-004-2013-09-25 Please indicate whether the training program discussed in ADAMS Accession No. ML13176A117 (Dominion Letter 13-278) dated June 17, 2013, adheres to the guidelines of NUREG-1220, "Training Review Criteria and Procedures." If there are deviations from the guidance of NUREG-1220, please describe how the training program complies with the requirements for SAT-based training.
Response
Since NUREG-1220 is intended for guidance only, a detailed review of the CFH Training Program was not performed against the guidance contained in NUREG-1220.
However, because the CFH Training Program was developed in accordance with KPS procedures that implement a Systems Approach to Training (as discussed in 10 CFR 50.120, and defined in 10 CFR 55.4), we believe that this training program is consistent with the intent of NUREG-1220.
Procedure TR-KW-101, "Conduct of Training," describes the process in administering and maintaining SAFSTOR training programs.
This procedure provides the Systems Approach to Training, as discussed in 10 CFR 50.120, "Training and qualification of nuclear power plant personnel," and defined in 10 CFR 55.4, "Operators' licenses; Definitions." Procedure TR-KW-101 was submitted to NRC on September 17, 2013,
Serial No. 13-278B Page 4 of 4 along with a response to a request for additional information regarding the CFH Training Program (Reference 4).
As discussed in Reference 4, the KPS Certified Fuel Handler Training Program was developed using the systems approach to training discussed in 10 CFR 50.120.
The program was developed by Training and Operations personnel using an approved task list and creating a task training work matrix. The task training work matrix was used to determine the initial and continuing training required for each task based on the Difficulty, Importance, Frequency (DIF) process (analysis), which determines if initial and continuing training are required. Learning objectives were determined from the task list based on the required knowledge and skills for each task (design of the program).
The training materials (lesson plans/exams) and the Shift Manager / Certified Fuel Handler Qualification Manual were then developed from the learning objectives (development of the training program). The Shift Manager / Certified Fuel Handler Training Program Guide was issued, which established the program (implementation of the training program). KPS Procedure TR-KW-101, "Conduct of Training," ensures that the systems approach to training is used for trainee evaluation and for maintaining and evaluating the Shift Manager / Certified Fuel Handler Training Program, including an annual review of the program, which is documented and reported to senior management (program evaluation and revision).
References
- 1. Letter from Paul A. Blasioli (DEK) to NRC Document Control Desk, "Request for Approval of Shift Manager / Certified Fuel Handler Training Program," dated June 17, 2013 (ADAMS Accession No. ML13176A117)
- 2. Email from Karl D. Feintuch (NRC) to Jack Gadzala, Craig Sly, et al (DEK), "MF2370
- Review of Training Plan for Certified Fuel Handler (CFH) training - Request for Additional Information (RAI)," dated September 25, 2013
- 3. Email from Karl D. Feintuch (NRC) to Jack Gadzala, Craig Sly, et al (DEK), "MF2370
- Review of Training Plan for Certified Fuel Handler (CFH) training - [Corrected]
Request for Additional Information (RAI)," dated September 27, 2013
- 4. Letter from Paul A. Blasioli (DEK) to NRC Document Control Desk, "Response to Request for Additional Information: Request for Approval of Shift Manager / Certified Fuel Handler Training Program," dated September 17, 2013 (ADAMS Accession No. ML13263A186)