RS-16-140, Request for Approval of Certified Fuel Handler Training Program Relevant to Clinton, Quad Cities, and Oyster Creek Stations

Request for Approval of Certified Fuel Handler Training Program Relevant to Clinton, Quad Cities, and Oyster Creek Stations

ML16200A236
Person / Time
Site:	Oyster Creek, Clinton, Quad Cities
Issue date:	07/18/2016
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
RS-16-140
Download: ML16200A236 (15)

Text

Michael P. Gallagher Exelon Nuclear Vice President Exelon Generation License Renewal and Decommissioning 200 Exelon Way Kennett Square, PA 19348 610 765 5958 Office 610 765 5658 Fax www.exeloncorp.com michaelp.gallagher@exeloncorp.com 10 CFR 50.2 RS-16-140 July 18, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254. 50-265. and 72-53 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15

Subject:

Request for Approval of Certified Fuel Handler Training Program

References:

1. Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Certification of Permanent Cessation of Power Operations," dated June 20, 2016 (NRC Accession No. ML16172A137)

2. Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Certification of Permanent Cessation of Power Operations," dated June 20, 2016 (NRC Accession No. ML16172A151)

3. Letter from James Barstow (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Request for Approval of Certified Fuel Handler Training Program," dated January 29, 2016 (NRC Accession No. ML16029A387)

4. Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding Approval of Certified Fuel Handler Training Program,"

dated June 8, 2016 (NRC Accession No. ML16160A161)

July 18, 2016 U.S. Nuclear Regulatory Commission Page2 In References 1 and 2, Exelon Generation Company, LLC (EGC) provided formal notification to the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.4(b)(8) and 10 CFR 50.82(a)(1)(i) of EGC's determination to permanently cease power operations at Clinton Power Station (CPS) by June 1, 2017, and Quad Cities Nuclear Power Station (QCNPS) by June 1, 2018, respectively.

Once the certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessels are docketed for CPS and QCNPS in accordance with 10 CFR 50.82(a)(1 )(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 licenses will no longer authorize reactor operation or placement or retention of fuel in the reactor vessels. As a result, licensed reactor operators will no longer be required to support plant operating activities. Instead, approval of a Certified Fuel Handler (CFH) Training and Retraining Program is needed to facilitate activities associated with decommissioning and irradiated fuel handling and management.

Pursuant to 10 CFR 50.2, EGC hereby requests NRC approval of the proposed EGC CFH Training and Retraining Program for use at CPS and QCNPS. In 10 CFR 50.2, a Certified Fuel Handler is defined as "a non-licensed operator who has qualified in accordance with a fuel handler training program approved by the Commission."

In support of the development of the EGC program, EGC evaluated programs that had been implemented by other licensees. The proposed EGC program was patterned after other NRG-approved programs within the industry. Some examples include:

• Zion Station, Units 1 and 2 - Request for Approval of the Certified Fuel Handler Training and Retraining Program submitted on March 16, 1998, and subsequently approved by the NRC as documented in a letter dated July 20, 1998.

• Kewaunee Power Station - Request for Approval of Shift Manager/Certified Fuel Handler Training Program submitted by letter dated June 17, 2013(ML13176A117),

and subsequently approved by the NRC as documented in a letter dated May 12, 2014(ML14104A046).

• Vermont Yankee Nuclear Power Station - Request for Approval of Certified Fuel Handler Training Program submitted by letter dated October 31, 2013 (ML133258015), and subsequently approved by the NRC as documented in a letter dated October 1, 2014(ML14162A209).

A copy of the proposed EGC CFH Training and Retraining Program for use at CPS and QCNPS is provided in the attachment to this submittal. The attached CFH Training and Retraining Program is also provided as a supplement to the program submitted in References 3 and 4 for the Oyster Creek Nuclear Generating Station (OCNGS). The supplement to the CFH program is being provided in response to the July 14, 2016, teleconference between EGC and NRC representatives that was held to discuss and clarify EGC's response to the NRC's request for additional information (Reference 4). The attached proposed CFH Training and Retraining Program is identical for OCNGS, CPS, and QCNPS.

The EGC CFH Training and Retraining Program will ensure that the qualifications of personnel at OCNGS, CPS, and QCNPS following permanent shutdown and defueling are

July 18, 2016 U.S. Nuclear Regulatory Commission Page 3 commensurate with the tasks to be performed and the plant conditions requiring response.

10 CFR 50.120, "Training and qualification of nuclear power plant personnel," requires training programs to be established, implemented, maintained, and derived using a Systems Approach to Training (SAT) as defined in 10 CFR 55.4. The requirements of 10 CFR 50.120 apply to holders of operating licenses issued under 10 CFR 50. After permanent cessation of operation and certification of fuel removal, the OCNGS, CPS, and QCNPS licenses will no longer authorize operation of the reactor. However, the proposed EGC CFH Training and Retraining Program for use at OCNGS, CPS, and QCNPS will align with the provisions of 10 CFR 50.120 and 10 CFR 55.4 for SAT.

The EGC CFH Training and Retraining Program for use at OCNGS, CPS, and QCNPS will provide adequate confidence that appropriate SAT-based training of personnel performing CFH duties is conducted in a manner commensurate with the level of hazard at the facility in order to ensure the facility is maintained in a safe and stable condition. The program also allows for changes to be made without prior NRC approval provided the program continues to comply with applicable ANSI/ANS 3.1-1978, "American National Standard for Selection and Training of Nuclear Power Plant Personnel," approved and implemented at OCNGS and CPS, and ANSI N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel," standard approved and implemented at QCNPS.

EGC is requesting approval of the OCNGS CFH Training and Retraining Program by the original date requested in reference 3 of January 29, 2017. EGC is also requesting approval of the proposed EGC CFH Training and Retraining Program for CPS and QCNPS by April 4, 2017, in order to support future decommissioning efforts and activities at the sites. Once approved, the program shall be implemented following the docketing of the certifications required by 10 CFR 50.82(a)(1) at the effected sites that have been permanently defueled.

By separate submittals, EGC plans to provide additional licensing actions that would delete certain requirements for licensed operators and add new requirements for the CFHs at CPS and QCNPS to further facilitate decommissioning efforts. The licensing actions would include:

• A License Amendment Request (LAR) supporting staffing and training requirement Technical Specifications (TS) changes to TS Section 5.0, Administrative Controls, to reflect the revised station organization, including CFHs, which will be implemented once CPS and QCNPS are permanently defueled.

• An exemption request to permit suspension of certain security measures during severe weather conditions. Specifically, during severe weather conditions that may occur at CPS and QCNPS, 10 CFR 73.55(p)(1 )(i) and 10 CFR 73.55(p)(1 )(ii) require that the suspension of security measures be approved by a licensed senior operator, before taking this action. Requesting an exemption from these requirements to allow either a licensed senior operator or a CFH to approve the suspension of security measures would be proposed.

There are no regulatory commitments contained in this submittal.

July 18, 2016 U.S. Nuclear Regulatory Commission Page 4 If you have any questions regarding this submittal, please contact Mr. Timothy A. Byam at (630) 657-2818.

Respectfully, Michael P. Gallagher Vice President, License Renewal & Decommissioning Exelon Generation Company, LLC

Attachment:

Exelon Generation Company Certified Fuel Handler Training and Retraining Program cc: NRC Regional Administrator, Region I NRC Regional Administrator, Region Ill NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector- Quad Cities Nuclear Power Station NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ

July 18, 2016 Page 1 of 11 Exelon Generation Certified Fuel Handler Training and Retraining Program

1. PURPOSE 1.1 To outline development of a Certified Fuel Handler Training and Retraining Program for an Exelon Generation nuclear facility that is permanently shutdown and permanently defueled.

1.2 This program will apply to the Oyster Creek Nuclear Generating Station, Clinton Power Station, and the Quad Cities Nuclear Power Station Units 1 & 2 once the certifications of permanent cessation from operations and removal of fuel from the reactor have been submitted to the U.S.

Nuclear Regulatory Commission (NRC).

2. TERMS AND DEFINITIONS 2.1 Certified Fuel Handler - As defined in 10 CFR 50.2, 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 NRC.

2.2 Non-Licensed Operator - An operator who works in the plant under the direction and supervision of control room and/or operations management personnel in support of plant operations. Non-licensed operators operate, control, and monitor plant equipment outside the control room and may also be assigned auxiliary duties such as fire brigade member, medical response team member, or radiological emergency team member.

2.3 NRC-Licensed Operator - An individual who possesses an NRC-issued operator license or senior reactor operator license pursuant to 10 CFR 55, Operators Licenses to manipulate the controls of a facility or to direct the licensed activities of licensed operators.

2.4 Systems Approach to Training (SAT) - The SAT process contains the following elements:

1. Systematic analysis of the jobs to be performed.

2. Learning objectives derived from the analyses 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. MAIN BODY 3.1 GENERAL GUIDELINES 3.1.1 The Certified Fuel Handler Training and Retraining Program contained herein describes the training program to be implemented by Exelon Generation to ensure the monitoring, handling, storage, and cooling of spent nuclear fuel is performed in a manner consistent with ensuring the

July 18, 2016 Page 2 of 11 public health and safety for Exelon Generation facilities that have transitioned to a permanently defueled status.

3.1.2 The Certified Fuel Handler Training and Retraining 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 qualification (e.g., medical). The program shall comply with the applicable American National Standards Institute (ANSI)/American Nuclear Society (ANS) standard requirements for the qualification and training of plant personnel, as specified in the facility's Technical Specifications (TS) and be consistent with level of hazard at the facility and to ensure the facility is maintained in a safe and stable condition. Based on the permanently defueled status, as committed to under 10 CFR 50.82(a)(1), the Certified Fuel Handlers will not be trained as NRC-licensed operators; however, candidates in the training program will meet minimum operator experience requirements of the applicable ANSI/ANS standards as specified in the facility's TS.

3.1.3 The Certified Fuel Handler Training and Retraining Program will become effective upon:

1. NRC approval of the Certified Fuel Handler Training and Retraining Program; and

2. NRC approval of an amendment to the facility operating license eliminating requirements for NRC Licensed Senior Reactor Operators and Reactor Operators, and the requirement for the associated 10 CFR 55 Training Program.

3.1.4 Training of personnel can be conducted prior to the Certified Fuel Handler Training and Retraining Program being approved by the NRC or prior to the training program effective date.

3.1.5 The Certified Fuel Handler Training and Retraining Program is not accredited with the National Academy for Nuclear Training in accordance with ACAD 02-002, "The Process for Accreditation of Training in the Nuclear Power Industry." Although the program is not accredited, a SAT process will be applied to the Certified Fuel Handler Training and Retraining Program. The program adheres to the guidelines of NUREG-1220, "Training Review Criteria and Procedures,"

Revision 1.

3.1.6 A SAT process will be applied to the Certified Fuel Handler Training and Retraining Program.

The SAT process contains the elements as described in Section 2.4.

3.1.7 Changes to the Certified Fuel Handler Training and Retraining Program may be made without prior NRC approval provided the changes are appropriately evaluated in accordance with the conditions specified in Section 3.6 and the program continues to comply with the specified ANSI/ANS standard requirements as specified in the facility's TS.

3.1.8 The Plant Manager (or designee) may exempt an individual from specific training or retraining requirements as specified in Subsections 3.2.4.6 and 3.3.2.3. The requirement for a medical examination shall not be exempted.

July 18, 2016 Page 3 of 11 3.1.9 The Certified Fuel Handler Training and Retraining Program consists of an initial training program and a requalification training program.

3.2 INITIAL TRAINING 3.2.1 ELIGIBILITY REQUIREMENTS 3.2.1.1 Candidates for enrollment in the Certified Fuel Handler Initial Training program shall meet the applicable ANSI/ANS standard requirements for the qualification and training of plant personnel, as specified in the facility's TS.

3.2.1.2 Specifically, at the time of appointment to the Certified Fuel Handler position, the candidate shall have:

1. High school diploma or equivalent.

2. A minimum of two years power plant experience, in which one year is nuclear power plant experience. At least 6 months of the nuclear experience shall be at the facility.

3. Possess a high degree of manual dexterity and mature judgment.

3.2.1.3 For the purposes of the Certified Fuel Handler training program the definition of nuclear power plant experience listed in the applicable ANSI/ANS standard, as specified in the facility's TS, is amended to include nuclear power plant experience acquired at a defueled reactor site which has spent nuclear fuel stored in its Spent Fuel Pool (SFP).

3.2.2 FUNDAMENTALS TRAINING 3.2.2.1 The fundamentals training phase of the Certified Fuel Handler Training and Retraining Program consists of lecture, and/or self-study of topics appropriate to the monitoring, handling, storage, and cooling of spent nuclear fuel. The lecture method of instruction is the training of individual topics by classroom presentation. Self-study is training accomplished by the student through the independent study of texts, handouts, and other materials. Selection of topics will be based on a job analysis for the Certified Fuel Handler tasks and functions. The job analysis will be conducted by an incumbent SRO, training Subject Matter Expert and Site Decommissioning Transition Planning Organization Operations Lead, in accordance with the requirements of TQ-AA-221, "Exelon Nuclear Training - Analysis Phase." The procedure outlines a graded approach to evaluating job tasks and includes Difficulty, Importance, and Frequency (DIF) ratings for each new job task. Learning objectives will be derived from the analysis to describe the desired performance after training. Training materials will be designed based on the learning objectives. Depending on an analysis of the candidate's background, self-study may be used for up to 100% of the course material. A comprehensive exam at the end of the course will provide assurance of mastery of the skills, knowledge, and abilities required for successful performance of Certified Fuel Handler job and associated tasks.

3.2.2.2 Fundamental topics will include thermodynamics, heat transfer, fluid mechanics, radiological safety principles and monitoring, electrical theory, mechanical components operation,

July 18, 2016 Page 4 of 11 facility/system design and function, and facility administrative and safety procedures, as appropriate for the current plant status.

3.2.3 ON-THE-JOB TRAINING (OJT) 3.2.3.1 The on-the-job training phase of the Certified Fuel Handler Training and Retraining Program includes hands-on training of shift operations such as shift turnover, shift record keeping, removal and return of equipment to service, and specified watch standing activities. Watch standing activities include on-the-job training in operation of systems/components used to provide handling, storage, cooling, and monitoring of the fuel; normal, abnormal, and emergency procedures; accident analysis; Emergency Plan; facility license; and the content, bases, and importance of Technical Specifications. On-the-job training will be conducted using a process similar to the Exelon Generation training process defined in TQ-AA-203, "On-The-Job Training and Task Performance Evaluations," which provides the requirements for the development, implementation, and evaluation of, and qualification requirements for, OJT, Task Performance Evaluation (TPE), and Job Performance Measure (JPM) administration.

3.2.3.2 A minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of on-shift watches under the instruction of a Certified Fuel Handler must be completed as part of the qualification process.

3.2.4 CANDIDATE EVALUATION 3.2.4.1 A comprehensive final examination shall be administered at the end of the initial training program. Areas examined are described in Appendices A and B for the written and operating examinations respectively.

3.2.4.2 The written examination requires a minimum score of 80 percent to pass.

3.2.4.3 The operating examination will consist of JPMs. Passing criteria for an individual JPM is that the examinee successfully completes the assigned task in accordance with the governing procedure without missing any critical steps. Missed or incorrectly performed critical steps are the bases for JPM failure. Critical tasks for a JPM will be pre-identified as defined in NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 10.

3.2.4.4 Each JPM will be scored on a pass/fail basis. The candidate must pass at least 80 percent of the administered JPMs to successfully pass the operating examination.

3.2.4.5 An individual who fails to pass either the written or operating examination shall not perform Certified Fuel Handler duties until the individual has completed a remedial training program and passes an appropriate re-examination. Only those portions of the original examination that were failed need to be re-examined (i.e., written or operating exam).

3.2.4.6 The Plant Manager (or designee) may exempt an individual from specific training requirements based upon the individual's depth of experience and previous training. Any exemptions granted shall be based on an evaluation of the candidates training and/or work history to ensure that the

July 18, 2016 Page 5 of 11 intent of the exempted training objectives are satisfied. Such exemptions, including the basis, shall be documented using a process similar to the Exelon Generation training exemption process defined in TQ-AA-224, "Exelon Nuclear Training - Implementation Phase." The requirement for a medical examination shall not be exempted.

3.2.4.7 Training of current or previous NRC-licensed Operators at the facility entering a permanently shutdown and permanently defueled condition may be evaluated to determine if they satisfy all of the requirements of this training program, or if they only need to complete portions of this program to qualify as a Certified Fuel Handler. This evaluation will focus on the differences between the requirements of a Certified Fuel Handler and an NRC-licensed Operator to identify any additional training required to become a Certified Fuel Handler. Examples may include an examination on TS, fuel handling, and administrative controls required to perform the Certified Fuel Handler function.

1. The Certified Fuel Handler Training and Retraining Program allows for the evaluation of other facility personnel to determine if portions of the required training have already been completed and therefore may be exempted. The evaluation will concentrate on required areas to determine if the previous training and qualification/examination were equivalent to that required for a Certified Fuel Handler.

3.2.4.8 In general, the training of holders of Senior Reactor Operator licenses who are also qualified as Fuel Handling Supervisors will meet the qualification requirements for a Certified Fuel Handler.

However, it is expected that some additional training requirements may arise as the plant transitions to a permanently shutdown and defueled configuration. These additional training requirements may arise from changes to plant systems or procedures associated with SFP operations. Therefore, the training requirements will be specifically identified and enumerated using the SAT process prior to permanent defueling. The training history of each currently licensed Senior Reactor Operator who is identified as a candidate for a Certified Fuel Handler qualification will be separately evaluated to ensure that all the specific training requirements of the Certified Fuel Handler Training and Retraining Program are met.

3.2.4.9 Training to address any identified gaps between the individual's training history and the Certified Fuel Handler Training Program requirements will be completed prior to certification as Certified Fuel Handler.

3.2.4.10 The Plant Manager (or designee) shall approve the basis for evaluations qualifying an individual as a Certified Fuel Handler.

3.2.4.11 Any missed training or examination shall be made up within 90 days of the missed training activity. If required training or evaluation is not completed within the specified makeup period, the Certified Fuel Handler shall be suspended from Certified Fuel Handler duties, pending successful completion of the missed training or evaluation.

July 18, 2016 Page 6 of 11 3.2.5 QUALIFICATIONS 3.2.5.1 All candidates shall satisfy the following requirements:

1. Complete the Initial Training and Retraining Program or have the requirement exempted per Subsection 3.2.4.6.

2. Score > 80 percent on a written examination.

3. Pass > 80 percent of the administered JPMs on the operating examination.

4. Pass a medical examination by a physician to determine that the candidate's medical condition is not such that it might cause operational errors that could endanger other plant personnel or the public health and safety.

3.3 RETRAINING PROGRAM 3.3.1 COURSE SCHEDULE 3.3.1.1 Candidates for enrollment in the Certified Fuel Handler Retraining Program (aka: requalification training program) shall have successfully completed the initial Certified Fuel Handler Training Program.

3.3.1.2 The retraining phase of the Certified Fuel Handler Training and Retraining Program shall be administered in a biennial training cycle. This cycle includes annual operating examinations and biennial written examination. Biennial and annual are as defined in NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 10.

3.3.1.3 All Certified Fuel Handlers will participate in the retraining program. The Certified Fuel Handler retraining phase consists of lecture and/or self-study of topics appropriate to the monitoring, handling, storage, and cooling of nuclear fuel. The content of the retraining program will be based upon the tasks selected during program development for the retraining cycle. A retraining plan will be developed and will be approved by the Plant Manager (or designee). The training plan will be developed utilizing the SAT process described in Section 2.4. Retraining will typically include a review of changes associated with the facility and procedures, as well as problem areas associated with the monitoring, handling, storage, and cooling of nuclear fuel, and selected topics from the initial training program.

3.3.1.4 Participants in the Certified Fuel Handler retraining phase of the program must pass a biennial written examination and an annual operating examination to maintain their qualification. Areas examined are described in Appendices A and B for the written and operating examinations, respectively.

3.3.1.5 The written examination requires a minimum score of 80 percent to pass.

3.3.1.6 The operating examination will consist of JPMs and each JPM will be scored on a pass/fail basis.

July 18, 2016 Page 7 of 11 3.3.1.7 Passing criteria for an individual JPM is that the examinee successfully completes the assigned task in accordance with the governing procedure without missing any critical steps. Missed or incorrectly performed critical steps are the bases for JPM failure. Critical tasks for a JPM should be pre-identified as defined in NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 10.

3.3.1.8 Each JPM will be scored on a pass/fail basis. The candidate shall pass at least 80 percent of the administered JPMs to successfully pass the operating examination.

3.3.1.9 Periodic written and/or operating exams may be administered during the retraining cycle to assess student knowledge and training effectiveness.

3.3.1.10 An individual who fails to pass either the comprehensive biennial written or annual operating examination shall not perform Certified Fuel Handler duties until a remedial training program is completed and an appropriate re-examination is passed. Only those portions of the examination that were originally failed need to be successfully re-examined prior to restoring qualifications (i.e., written or operating exam).

3.3.2 MAINTENANCE OF CERTIFIED FUEL HANDLER QUALIFICATIONS 3.3.2.1 To maintain the Certified Fuel Handler qualification, the following requirements must be satisfied or they may be exempted per Subsection 3.2.4.6.

1. Complete all required Certified Fuel Handler retraining.

2. Score > 80 percent on the biennial written examination.

3. Pass > 80 percent of the administered JPMs on the annual operating examination.

4. Pass a biennial medical examination by a physician to determine that the Certified Fuel Handler's medical condition is not such that it might cause operational errors that could endanger other plant personnel or the public health and safety.

5. Stand the designated Certified Fuel Handler watch for a minimum of eight (8) hours per calendar quarter. A Certified Fuel Handler who fails to meet this time requirement can regain qualified status by serving eight (8) hours of watch under the instruction of a qualified Certified Fuel Handler. The time under instruction should include a review of the spent fuel pool cooling system and shift turnover procedures.

3.3.2.2 An individual who fails to meet any of the requirements for maintaining the Certified Fuel Handler qualification shall be removed from all duties associated with that position until such time as the discrepancies can be resolved. Shift Operations shall be notified of the individual's removal and subsequent status.

3.3.2.3 The Plant Manager (or designee) may exempt an individual from a specific retraining requirement. Such exemptions, including the basis, shall be documented using a process similar to the Exelon Generation training exemption process defined in TQ-AA-224. The requirement for a biennial medical examination shall not be exempted. An individual shall not be exempted from the annual operating or biennial written examinations unless that individual

July 18, 2016 Page 8 of 11 prepared the examination. No individual may be exempted from any two consecutive annual operating exams. No individual may be exempted from any two consecutive biennial written examinations.

3.4 PROGRAM EVALUATION 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. As part of the training process, routine assessments of the effectiveness and accuracy of the training program are conducted by appropriate management personnel at the facility in a permanently defueled condition during and at the end of each two (2) year training cycle. Evaluation results shall be reviewed by a station oversight board as defined in site procedures. The station oversight board will verify the resolution of any discrepancies identified by the evaluation. Any required changes to the program determined by the station oversight board, shall be incorporated into the program.

3.5 RECORD RETENTION 3.5.1 Records associated with the Certified Fuel Handler Training and Retraining Program will be retained in retrievable format until there is no longer a need for a Certified Fuel Handler position at the facility (i.e., all fuel permanently transferred to a dry fuel storage facility).

3.6 EVALUATING CHANGES TO THE CERTIFIED FUEL HANDLER TRAINING AND RETRAINING PROGRAM 3.6.1 The Certified Fuel Handler Training and Retraining Program is based on SAT; therefore, Exelon may change elements without NRC approval as long as the following are applicable:

1. suitable proficiency in the performance of the program's activities is maintained; and

2. changes are documented in an accessible manner that will allow the NRC to verify the adequacy of the program in accordance with 10 CFR 50.120.

4. REFERENCES 4.1 10 CFR 50.2, "Definitions" 4.2 10 CFR 50.120, "Training and qualification of nuclear power plant personnel" 4.3 SECY-00-145, "Integrated Rulemaking Plan for Nuclear Power Plant Decommissioning,"

dated June 28, 2000 4.4 Statements of Consideration for the "Decommissioning of Nuclear Power Reactors,"

Proposed Rule (60FR37374, dated July 20, 1995) and Final Rule (61FR39278, dated July 29, 1996) 4.5 NUREG-1220, "Training Review Criteria and Procedures" 4.6 NUREG-1021, "Operator Licensing Examination Standards for Power Reactor," Revision 10 4.7 ANSI/ANS 3.1 - (1978) (1981), "Selection and Training of Nuclear Power Plant Personnel" 4.8 ANSI N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel"

July 18, 2016 Page 9 of 11 4.9 Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants" 4.10 NRC Safety Evaluation, "Crystal River Unit 3 - Review of Certified Fuel Handler Training and Retraining Program," June 26, 2014 (ADAMS Accession No. ML14155A181) 4.11 NRC Safety Evaluation, "Kewaunee Power Station - Approval of Shift Manager/Certified Fuel Handler Training Program," May 12, 2014 (ADAMS Accession No. ML14104A046) 4.12 NRC Safety Evaluation, "San Onofre Nuclear Generating Station, Units 2 and 3 - Approval of Safe Storage Shift Manager/Certified Fuel Handler Training Program," August 1, 2014 (ADAMS Accession No. ML13268A165) 4.13 NRC Safety Evaluation, "Vermont Yankee Nuclear Power Station - Review of Certified Fuel Handler Training and Retraining Program," October 1, 2014 (ADAMS Accession No. ML14162A209) 4.14 NRC Safety Evaluation for Amendment 160 to License DPR-36, Maine Yankee, November 26, 1997 (ADAMS Accession No. 9712040233) 4.15 NRC Safety Evaluation for Certified Fuel Handlers Training and Retraining Program for Zion Nuclear Power Station Units 1 and 2, July 20, 1998 (ADAMS Accession No. 9807240263) 4.16 NRC Safety Evaluation, "Millstone Nuclear Power Station, Unit 1 - Approval of Certified Fuel Handler Training Program," February 11, 1999 4.17 TQ-AA-203, "On-The-Job Training and Task Performance Evaluation" 4.18 TQ-AA-221, "Exelon Nuclear Training - Analysis Phase" 4.19 TQ-AA-222, "Exelon Nuclear Training - Design Phase" 4.20 TQ-AA-223, "Exelon Nuclear Training - Development Phase" 4.21 TQ-AA-224, "Exelon Nuclear Training - Implementation Phase" 4.22 TQ-AA-224-F040, "Training Exemption Form" 4.23 TQ-AA-225, "Exelon Nuclear Training - Evaluation Phase" 4.24 ACAD 02-002, "The Process for Accreditation of Training in the Nuclear Power Industry" 4.25 ACAD 07-001, "Guidelines for the Continuing Training of Licensed Personnel" 4.26 NEI 15-04, Rev. 0, "Guidelines for a Certified Fuel Handler Training and Retraining Program" - (Draft 11/3/15)

July 18, 2016 Page 10 of 11 APPENDIX A WRITTEN EXAMINATION AREAS CERITFIED FUEL HANDLER TRAINING AND RETRAINING PROGRAM The written examination shall include a sample of the following aspects of the Certified Fuel Handler position:

(1) Design, function, and operation of systems used in handling, storage, cooling, monitoring of nuclear fuel, and auxiliary support systems.

(2) Purpose and operation of the radiation monitoring systems.

(3) Radiological safety principles and procedures including radiation hazards that may arise during normal, maintenance, and abnormal activities.

(4) Principles of heat transfer, thermodynamics, and fluid mechanics as they apply to fuel handling, storage, cooling, and monitoring.

(5) Conditions and limitations of facility license, including content, basis and importance of Technical Specifications.

(6) Assessment of facility condition and selection of appropriate procedures during normal, abnormal and emergency situations.

(7) Fuel handling facilities and procedures.

July 18, 2016 Page 11 of 11 APPENDIX B OPERATING EXAMINATION AREAS CERTIFIED FUEL HANDLER TRAINING AND RETRAINING PROGRAM The operating examination will consist of Job Performance Measures and shall include a sample of the following aspects of the Certified Fuel Handler duties and tasks:

(1) Evaluate annunciators; valve, pump, and breaker status indicators; and instrument readings as necessary to determine/perform appropriate remedial actions.

(2) Evaluate the ability to manipulate the controls required to obtain desired operating results during normal, abnormal, and emergency conditions. This includes the spent fuel pool cooling system and those auxiliary and emergency systems that could affect the release of radioactive material to the environment.

(3) Evaluate radiation monitoring system readings, including alarm conditions, to determine appropriate actions. Such actions may include setting an alarm setpoint to monitor a release or determine appropriate remedial actions for an alarm condition.

(4) Evaluate abnormal or emergency conditions to determine if the emergency plan for the facility should be implemented and, if implemented, evaluate performance of duties as required by the emergency plan.