ML16222A787

Unit 1; and Quad Cities Nuclear Power Station, Units 1 and 2 - Review of Certified Fuel Handler Training and Retraining Program

ML16222A787
Person / Time
Site:	Oyster Creek, Clinton, Quad Cities
Issue date:	09/06/2016
From:	John Lamb Plant Licensing Branch 1
To:	Bryan Hanson Exelon Nuclear
Lamb J
References
CAC MF8109, CAC MF8138, CAC MF8139, CAC MF8140
Download: ML16222A787 (14)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 6, 2016 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

OYSTER CREEK NUCLEAR GENERATING STATION; CLINTON POWER STATION, UNIT NO. 1; AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 -APPROVAL OF CERTIFIED FUEL HANDLER TRAINING AND RETRAINING PROGRAM (CAC NOS. MF8109, MF8138, MF8139, AND MF8140)

Dear Mr. Hanson:

By letters dated January 29, 2016, and July 18, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML16029A387 and ML16200A236, respectively), as supplemented by letter dated June 8, 2016 and e-mail dated June 14, 2016 (ADAMS Accession Nos. ML16160A161 and ML16166A374, respectively), Exelon Generation Company, LLC (Exelon or the licensee), submitted its Certified Fuel Handler (CFH) Training and Retraining Program for the Oyster Creek Nuclear Generating Station (OCNGS); Clinton Power Station, Unit No. 1 (CPS); and Quad Cities Nuclear Power Station, Units 1 and 2 (QCNPS) to the U.S. Nuclear Regulatory Commission (NRC) for approval.

By letter dated January 7, 2011 (ADAMS Accession No. ML110070507), the licensee submitted a Notification of Permanent Cessation of Power Operations for OCNGS. In this letter, Exelon provided notification to the NRC of its intent to permanently cease power operations at OCNGS no later than December 31, 2019.

By letter dated June 20, 2016 (ADAMS Accession No. ML16172A137), the licensee submitted a Notification of Permanent Cessation of Power Operations for CPS. In this letter, Exelon provided notification to the NRC of its intent to permanently cease power operations at CPS by June 1, 2017.

By letter dated June 20, 2016 (ADAMS Accession No. ML16172A151), the licensee submitted a Notification of Permanent Cessation of Power Operations for QCNPS. In this letter, Exelon provided notification to the NRC of its intent to permanently cease power operations at QCNPS by June 1, 2018.

B. Hanson After certifications of permanent cessation of operations and of permanent removal of fuel from the reactor vessel for OCNGS, CPS, and QCNPS are submitted in accordance with Title 10 of the Code of Federal Regulations (1 O CFR) 50.82(a)(1 )(i) and (ii), the 10 CFR Part 50 license no longer authorizes operation of the reactor or placement or retention of fuel in the reactor vessel.

As a result, licensed reactor operators will no longer be required to support plant activities.

Instead, approval of a CFH Training and Retraining Program is needed to facilitate activities associated with decommissioning and irradiated fuel handling and management.

The licensee requested NRC approval of the OCNGS, CPS, and QCNPS CFH Training and Retraining Program to ensure that the monitoring, handling, storage, and cooling of irradiated fuel is performed in a safe manner. As defined in 10 CFR 50.2, the CFH is a non-licensed operator who has qualified in accordance with a fuel handler training program approved by the NRC. Non-licensed personnel are trained in accordance with 10 CFR 50.120.

The NRC has reviewed the submittals and approves the OCNGS, CPS, and QCNPS CFH Training and Retraining Program as requested.

A copy of the related staff evaluation is enclosed.

If you have any questions, please contact me at 301-415-3100 or via e-mail at John.Lamb@nrc.gov.

G. Lamb, Senior Project Manager nt Licensing IV-2 and Decommissioning ransition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-219, 50-461, 50-254, and 50-265

Enclosure:

Safety Evaluation cc w/enclosure: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 STAFF EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION CERTIFIED FUEL HANDLER TRAINING AND RETRAINING PROGRAM EXELON GENERATION COMPANY, LLC OYSTER CREEK NUCLEAR GENERATING STATION CLINTON POWER STATION, UNIT NO. 1 QUAD CITIES NUCLEAR POWER STATION, UNITS 1AND2 DOCKET NOS. 50-219, 50-461, 50-254, AND 50-265

1.0 INTRODUCTION

By letter dated January 7, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML110070507), Exelon Generation Company, LLC (Exelon or the licensee) submitted a Notification of Permanent Cessation of Power Operations for Oyster Creek Nuclear Generating Station (OCNGS). In this letter, Exelon provided notification to the U.S. Nuclear Regulatory Commission (NRC) of its intent to permanently cease power operations at OCNGS no later than December 31, 2019.

By letter dated June 20, 2016 (ADAMS Accession No. ML16172A137), the licensee submitted a Notification of Permanent Cessation of Power Operations for Clinton Power Station, Unit No. 1 (CPS). In this letter, Exelon provided notification to the NRC of its intent to permanently cease power operations at CPS by June 1, 2017.

By letter dated June 20, 2016 (ADAMS Accession No. ML16172A151), the licensee submitted a Notification of Permanent Cessation of Power Operations for Quad Cities Nuclear Power Station, Units 1 and 2 (QCNPS). In this letter, Exelon provided notification to the NRC of its intent to permanently cease power operations at QCNPS by June 1, 2018.

After certifications of permanent cessation of operations and of permanent removal of fuel from the reactor vessel for OCNGS, CPS, and QCNPS are submitted in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.82(a)(1 )(i) and (ii), the 10 CFR Part 50 licenses no longer authorize operation of the reactor or placement or retention of fuel in the reactor vessel. As a result, licensed reactor operators will no longer be required to support plant 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.

Enclosure

By letters dated January 29, 2016, and July 18, 2016 (ADAMS Accession Nos. ML16029A387 and ML16200A236, respectively), as supplemented by letter dated June 8, 2016 and e-mail dated June 14, 2016 (ADAMS Accession Nos. ML16160A161 and ML16166A374, respectively),

Exelon submitted its CFH Training and Retraining Program for OCNGS, CPS, and QCNPS to the NRC for approval.

The proposed CFH Training and Retraining Program is to be used to satisfy training requirements for the plant personnel responsible for supervising and directing the monitoring, storage, handling, and cooling of irradiated nuclear fuel in a manner consistent with ensuring the health and safety of the public. Section 10 CFR 50.2, "Definitions, requires that CFHs be qualified in accordance with an NRC-approved training program.

2.0 REGULATORY EVALUATION

The regulatory framework concerning operator and fuel handler staffing was discussed by the NRC staff in SECY-00-145, "Integrated Rulemaking Plan for Nuclear Power Plant Decommissioning, Attachment 1, "Integrated Rulemaking Plan for Emergency Planning, Insurance, Safeguards, Staffing and Training, and Backfit at Decommissioning Nuclear Power Plants" dated June 28, 2000 (ADAMS Accession No. ML003721626), which states, in part:

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 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 the Final Rule, "Decommissioning of Nuclear Power Reactors," published in the Federal Register on July 29, 1996 (61 FR 39278), 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 experience in spent fuel handling and storage, and 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, "Training and qualification of nuclear power plant personnel," and assessed the program against the elements of a systems approach to training (SAT) provided in the definitions section of 10 CFR 55.4.

Following the issuance of the 1996 decommissioning rule, the NRC commenced the review and approval of CFH training programs for permanently shutdown and defueled reactors consistent with the requirements in the rule. Nuclear power plants that are permanently shutdown and defueled 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, security, etc.). The effort balanced personnel and plant status commensurate with the reduced risk once the certifications associated with permanent cessation of operations and permanent defueling had been submitted. Included in the effort was the transition from licensed operators to CFHs. With a simplified operating configuration in the permanently 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 Part 55, "Operators' Licenses," were modified to reflect the reduced staffing levels and responsibilities of the operations staff.

Past practice of the NRC staff included reviewing the proposed CFH training program to confirm that the program was based on a systems approach to training as defined in 10 CFR 55.4.

Examples of such precedents include NRC safety evaluations for Maine Yankee Atomic Power Plant, dated November 26, 1997 (Legacy Library Accession No. 9712040233); and for Zion Nuclear Power Station, Units 1 and 2, dated July 20, 1998 (Legacy Library Accession No. 9807240263). In more recent years, the NRC staff has approved CFH training programs for Kewaunee Power Station, dated May 12, 2014 (ADAMS Accession No. ML14104A046), Crystal River Unit 3 Nuclear Generating Plant, dated June 26, 2014 (ADAMS Accession No. ML14155A181 ), San Onofre Nuclear Generating Station, Units 2 and 3, dated August 1, 2014 (ADAMS Accession No. ML13268A165), and Vermont Yankee Nuclear Power Station, dated October 1, 2014 (ADAMS Accession No. ML14162A209).

Therefore, the regulatory requirements and guidance that the NRG staff used in its review of the proposed CFH Training and Retraining Program for OCNGS, CPS, and QCNPS are as follows:

• 10 CFR 50.2, which states, in part, that 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.

• 10 CFR 50.120, which states, in part, that:

(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 NRG inspection to verify the adequacy of the program.

• 10 CFR 55.4, "Definitions," which states, in part, that Systems approach to training means a training program that includes the following five elements:

(1) Systematic analysis of the 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 NRC staff reviewed the specific elements of the proposed CFH Training and Retraining Program for OCNGS, CPS, and QCNPS, against the regulatory requirements of 10 CFR 50.120, consistent with previous NRC staff reviews and approvals of decommissioning reactor CFH training programs, together with the elements of a systems approach to training as defined in 10 CFR 55.4.

3.1 CFH Training Program Broad-Scope Objectives Based on the discussion of the applicable regulatory requirements in Section 2.0, the NRC staff used the following three broad-scope objectives as criteria for an acceptable CFH Training and Retraining Program:

(1) Safe conduct of decommissioning activities.

(2) Safe handling and storage of spent fuel.

(3) Appropriate response to plant emergencies.

The proposed CFH Training and Retraining Program, as provided in the Attachment to Exelon's submittal dated January 29, 2016, and supplemented by submittals dated June 8, 2016, June 14, 2016, and July 18, 2016, was reviewed by the NRC staff. The licensee stated, in part, in its submittal dated July 18, 2016, that the approval of a CFH Training and Retraining Program "is needed to facilitate activities associated with decommissioning and irradiated fuel handling and management."

In the CFH Training and Retraining Program in the licensee's submittal dated July 18, 2016, Section 1, "Purpose," Subsection 1.2 states that the CFH Training and Retraining Program will apply to OCNGS, CPS, and QCNPS, once the certifications of permanent cessation from operations and of removal of fuel from the reactor have been submitted to the NRC for these facilities. Section 3.2, "Initial Training," Subsection 3.2.2, "Fundamentals Training," states that the fundamentals training phase of the CFH Training and Retraining Program consists of lecture and/or self-study of several topics. The selection of topics will be based on a job analysis for the CFH tasks and functions and will include, among others, radiological safety principles and monitoring, facility/system design and function, and facility administrative and safety procedures, as appropriate for the current plant status. Further, as described in Subsection 3.2.3, "On-The-Job Training (OJT)," the OJT phase of the CFH Training and Retraining program will include hands-on training of shift operations such as shift turnover, shift recordkeeping, removal and return of equipment to service, and specified watch standing activities. The OJT will also include training on the facility license, and the content, bases, and importance of the facility's technical specifications. The NRC staff finds the inclusion of these topics in the initial training program to be consistent with objective (1) above.

The proposed CFH initial training program also includes lectures and/or self-study of topics appropriate to the monitoring, handling, storage, and cooling of nuclear fuel, including topics on thermodynamics, heat transfer, fluid mechanics, electrical theory, and mechanical components operation. The OJT phase of the CFH Training Program includes watch-standing activities, such as operation of systems/components used to provide handling, storage, cooling, and

monitoring of fuel. The NRC staff finds the inclusion of this information to be consistent with objective (2) above.

Further, the OJT phase of the proposed CFH initial training program includes training on normal, abnormal, and emergency procedures, accident analysis, and the facility's emergency plan.

The NRC staff finds the inclusion of this information to be consistent with objective (3) above.

In the CFH Training and Retraining Program in the licensee's submittal dated July 18, 2016, Section 3.3, "Retraining Program," states that all CFHs will participate in the retraining program.

The CFH retraining phase will consist of lectures 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.

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. The NRC staff finds the inclusion of these topics in the retraining program to be consistent with the broad-scope objectives.

Based on the above, the NRC staff concludes that the proposed CFH Training and Retraining Program for OCNGS, CPS, and QCNPS, meets all of the three broad-scope objectives.

3.2 CFH Training and Retraining Program Evaluation The NRC staff reviewed the specific elements of the proposed CFH Training and Retraining Program for OCNGS, CPS, and QCNPS, against the regulatory requirements of 10 CFR 50.120(b)(2) and (b)(3), consistent with previous NRC staff reviews and approvals of decommissioning reactor CFH training programs, and has summarized the results of this review below.

3.2.1 Use of a Systems Approach to Training (SAT)

Section 50.120(b)(2) of 10 CFR, states, in part, that "[t]he training program must be derived from a systems approach to training as defined in 10 CFR 55.4 .... " The licensee stated, in part, in its submittal dated July 18, 2016, that "[t]he EGC [Exelon] CFH Training and Retraining Program will ensure that the qualifications of personnel at OCNGS, CPS, and QCNPS following permanent shutdown and defueling are commensurate with the tasks to be performed and the plant conditions requiring response." Further, Exelon stated, in part, that the CFH Training and Retraining Program "will align with the provisions of 10 CFR 50.120 and 10 CFR 55.4 for SAT" and "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."

Section 3.1, "General Guidelines," Subsection 3.1.1 of the CFH Training and Retraining Program in the submittal dated July 18, 2016, states that "[t]he 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 public health and safety for Exelon Generation facilities that have transitioned to a permanently defueled status."

Also, Section 3.1, Subsection 3.1.2 in the submittal dated July 18, 2016, states, in part, that

"[t]he 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)." Further, Subsections 3.1.6 and 3.1.9 state that the CFH Training and Retraining Program is based on a SAT process and consists of an initial training program and a requalification training program, which are described in the submittal.

The NRC staff reviewed the proposed CFH Training and Retraining Program, to ensure that it includes all five of the required elements of a SAT-based program, which are:

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

Section 3.2 of the proposed CFH Training and Retraining Program states that the selection of topics for the fundamentals training phase of the programwill be based on a job analysis for the CFH tasks and functions. The job analysis will be performed by an incumbent Senior Reactor Operator (SRO), training Subject Matter Expert (SME) and Site Decommissioning Transition Planning Organization Operations Lead, in accordance with the requirements of TQ-AA-221, "Exelon Nuclear Training - Analysis Phase." This procedure outlines a graded approach to evaluating job tasks and includes Difficulty, Importance, and Frequency ratings for each new job task. The proposed CFH Training and Retraining Program further states that learning objectives will be derived from the analysis to describe the desired performance after training.

The NRC staff reviewed Exelon procedures TQ-AA-221, Revision 7 and procedure TQ-AA-222, "Exelon Nuclear Training - Design Phase," Revision 2 (referenced in Section 4.19 of the letter dated July 18, 2016). Procedure TQ-AA-221 describes the activities performed in the analysis phase of the SAT process and provides specific guidance to ensure that the outcome of the analysis phase includes an approved task/topic list representing the tasks performed by each affected work group and a determination of which tasks/topics require initial and/or continuing training. Procedure TQ-AA-222 describes the activities performed in the design phase of the SAT process and provides guidance on the development of learning objectives, determination of training settings, preparation of training program procedures, development of evaluation instruments, and design of qualification structures. The NRC staff finds the licensee's plan to use these procedures to conduct a systematic analysis of jobs to be performed and to derive learning objectives from that analysis to be consistent with SAT elements 1 and 2.

Section 3.3, Subsection 3.3.1, "Course Schedule," of the proposed CFH Training and Retraining Program states that all CFHs will participate in the retraining program. 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 approved by the Plant Manager (or designee). The training plan will be developed utilizing the SAT process.

The NRC staff finds this approach to be consistent with SAT elements 1 and 2.

SAT Element 3 requires that the training design and implementation be based upon the learning objectives. Section 3.2, Subsection 3.2.2 states that training materials will be designed based on the learning objectives.

The NRC staff reviewed Exelon procedure TQ-AA-223, "Exelon Nuclear Training -

Development Phase," Revision 7 (referenced in Section 4.20 of the letter dated July 18, 2016).

Procedure TQ-AA-223 describes the activities performed in the development phase of the training system development process. It provides specific guidance on the development of approved training material to ensure that learning objectives are achieved.

The NRC staff reviewed the licensee's process to design and implement training based upon the learning objectives and finds it to be consistent with SAT element 3.

Section 3.2, Subsection 3.2.2, of the CFH Training and Retraining Program states that 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 the CFH job and associated tasks. Further, Subsection 3.2.4, "Candidate Evaluation," states that a comprehensive final examination is to be administered at the end of the initial training program. The comprehensive examination will include a written and an operating examination. The written examination requires a minimum score of 80-percent to pass. The operating examination will consist of Job Performance Measures (JPMs), and each JPM will be scored on a pass/fail basis. 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. The critical tasks for each JPM will be defined in accordance with NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 10 (ADAMS Accession No. ML14352A297). The operating examination requires passing a minimum of 80 percent of the administered JPMs to pass.

Section 3.3, Subsection 3.3.1 states that participants in the CFH retraining program must pass a biennial written examination and an annual operating examination to maintain their qualification.

The written examination requires a minimum score of 80-percent to pass. The operating examination will consist of JPMs and each JPM will be scored on a pass/fail basis.

The operating examination requires passing a minimum of 80-percent of the administered JPMs to pass.

The NRC staff reviewed Exelon procedure TQ-AA-224, "Exelon Nuclear Training -

Implementation Phase," Revision 9 (referenced in Section 4.21 of the submittal). Procedure TQ-AA-224 describes activities performed in the implementation phase of the SAT process. It provides specific guidance on the major activities of the implementation phase, including

implementation of a training plan, conduct of training, conduct of in-training evaluation, and documentation of training.

The NRC staff reviewed the licensee's process to evaluate the trainee mastery of the objectives during training and retraining and finds it to be consistent with SAT element 4.

Section 3.4, "Program Evaluation," of the CFH Training and Retraining Program states that routine assessments of the effectiveness and accuracy of the training program are conducted by appropriate management personnel during and at the end of each 2-year training cycle.

Evaluation results are reviewed by a station oversight board as defined in site procedures and any required changes, as determined by the station oversight board, are incorporated into the program.

The NRC staff reviewed Exelon procedure TQ-AA-225, "Exelon Nuclear Training - Evaluation Phase," Revision 4 (referenced in Section 4.23 of the letter dated July 18, 2016). Procedure TQ-AA-225 describes the activities performed in the evaluation phase of the training system development process. It provides specific guidance for the conduct of the activities during the evaluation phase, including monitoring feedback, evaluating training effectiveness, and initiating corrective actions.

The NRC staff reviewed the licensee's process to evaluate and revise the training based on the performance of trained personnel and finds it to be consistent with SAT element 5.

Based on the above, the NRC staff concludes that the proposed CFH Training and Retraining Program includes the five elements of 10 CFR 55.4 and thus complies with 10 CFR 50.120(b )(2).

3.2.2 Compliance with the Requirements of 10 CFR 50.120(b )(3)

The NRC staff also verified that the proposed CFH Training and Retraining Program meets 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 proposed CFH Training and Retraining Program and confirmed that each of the 10 CFR 50.120(b)(3) requirements is satisfied as discussed below:

Section 3.2, Subsection 3.2.2.1 states that the job analysis for the CFH tasks and functions will be conducted by an incumbent SRO, training SME, and Site Decommissioning Transition Planning Organization Operations Lead. Learning objectives will be derived from the analysis to describe the desired performance after training, and training materials will be designed based on the learning objectives.

Subsection 3.2.4 states that a comprehensive final examination must be administered at the end of the initial training program consisting of a written examination and an operating examination described in Appendices A and B, respectively. Further, Section 3.3, Subsection 3.3.1.4 states that participants in the CFH retraining phase of the program will be required to pass a biennial written examination and an annual operating examination to maintain their qualification, with examination areas described in Appendices A and B, respectively. Appendices A and B of the proposed CFH Training and Retraining Program provide a compendium of instructional areas that the licensee has identified as required instructional areas necessary to ensure that the CFHs will be trained in all areas necessary to maintain the facility and operate equipment in a safe manner. The NRC staff finds that this satisfies element "a" above.

Section 3.1, Subsection 3.1.2 states that the training program shall comply the applicable American National Standards Institute/American Nuclear Society standard requirements for the qualification and training of plant personnel, as specified in the facility's technical specifications, and shall be consistent with the level of hazard at the facility and ensure that the facility is maintained in a safe and stable condition. The NRC staff finds that this is consistent with element "b" above.

Section 3.4 states that 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. Routine assessments of the effectiveness and accuracy of the training program are required to be conducted by appropriate management personnel at the facility in a permanently defueled condition during and at the end of each 2-year training cycle. Evaluation results are required to be reviewed by a station oversight board. Resolution of any discrepancies identified by the evaluation will be verified by the station oversight board, and any required changes, as determined by the board, are required to be incorporated into the program. The NRC staff reviewed the provisions for evaluating and revising the CFH Training and Retraining Program and finds that they satisfy the program evaluation requirements of elements "c" and "d" above.

Section 3.5, "Record Retention," states that records associated with the proposedCFH Training and Retraining Program will be retained in a retrievable format until there is no longer a need for the CFH position at the facility (i.e., when all fuel is permanently transferred to a dry fuel storage facility). Further, Section 3.6, "Evaluating Changes to

the Certified Fuel Handler Training and Retraining Program," states that changes may be made to the training program 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. The NRC staff finds that this is consistent with element "e" above.

4.0 CONCLUSION

The NRC staff's review of the proposed CFH Training and Retraining Program for OCNGS, CPS, and QCNPS determined that the program adequately addresses the safe conduct of decommissioning activities, the safe handling and storage of spent fuel, appropriate response to plant emergencies, and is consistent with the SAT processes defined by 10 CFR 55.4 and the requirements of 10 CFR 50.120(b)(2) and (b)(3). Based on the above findings, the NRC staff approves the CFH Training and Retraining Program for OCNGS, CPS, and QCNPS, pursuant to 10 CFR 50.2. Because the program is based on SAT, the licensee may change elements of the program 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.

Principal Contributor: V. Huckabay Date: September 6, 2016.

ML16222A787 *via email OFFICE NRR/DORL/LPL4-2/PM NRR/DORL/LPL3-2/PM NRR/DORL/LPL3-2/PM NAME Jlamb EBrown JDion DATE 8/9/16 8/11/16 8/11/16 OFFICE NRR/DORL/LPL4-2/LA NRR/DRNAPHB/BC* OGC- NLO NAME PBlechman SWeerakkodv JWachutka DATE 8/10/16 8/9/16 8/22/16 OFFICE NRR/DORL/LPL3-2/8C(A) NRR/DORL/LPL4-2/BC NRR/DORL/LPL4-2/PM NAME EMiller SAnderson Jlamb DATE 8/30/16 8/30/16 9/6/16