ML16259A347

Approval of the Certified Fuel Handler Training and Retraining Program

ML16259A347
Person / Time
Site:	FitzPatrick
Issue date:	10/17/2016
From:	Render D Plant Licensing Branch 1
To:	Entergy Nuclear Operations
Wengert T, DORL/LPLIV-2, 415-4037
References
CAC MF7282
Download: ML16259A347 (14)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 17, 2016 Vice President, Operations Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT -APPROVAL OF THE CERTIFIED FUEL HANDLER TRAINING AND RETRAINING PROGRAM (CAC NO. MF7282)

Dear Sir or Madam:

By letter dated January 15, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16015A455), as supplemented by letters dated June 3 and August 18, 2016 (ADAMS Accession Nos. ML16155A327 and ML16231A437, respectively), Entergy Nuclear Operations, Inc. (Entergy or the licensee), submitted its Certified Fuel Handler (CFH) Training and Retraining Program for the James A. FitzPatrick Nuclear Power Plant (JAF) to the U.S. Nuclear Regulatory Commission (NRC) for approval.

After certifications of permanent cessation of operations and of permanent removal of fuel from the reactor vessel for JAF are submitted in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Sections 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, licensees may elect to amend their licenses to allow CFHs, instead of licensed reactor operators, to support plant activities. Therefore, 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 JAF 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 fuel handler training program. A copy of the related safety evaluation is enclosed.

If you have any questions, please contact Thomas Wengert at 301-415-4037 or via e-mail at Thomas.Wengert@nrc.gov.

Sincerely, Diane L. Render, Project Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

Safety Evaluation cc w/enclosure: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION CERTIFIED FUEL HANDLER TRAINING AND RETRAINING PROGRAM ENTERGY NUCLEAR OPERATIONS, INC.

JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333

1.0 INTRODUCTION

After certifications of permanent cessation of operations and permanent removal of fuel from the reactor vessel for James A. FitzPatrick Nuclear Power Plant (JAF) are submitted in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.82(a)(1 )(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), 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, licensees may elect to amend their licenses to allow CFHs, instead of licensed reactor operators, to support plant activities. Therefore, 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.

By letter dated January 15, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16015A455), as supplemented by letters dated June 3 and August 18, 2016 (ADAMS Accession Nos. ML16155A327 and ML16231A437, respectively),

Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted its CFH Training and Retraining Program for JAF to the U.S. Nuclear Regulatory Commission (NRC) for approval.

The enclosure to the August 18, 2016, letter contains a complete revision of the proposed JAF CFH Training and Retraining Program.

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 50.2 of 10 CFR, "Definitions," requires that CFHs be qualified in accordance with an NRG-approved training program.

2.0 REGULATORY EVALUATION

Pursuant to 10 CFR 50.120(b), each holder of an operating license shall establish, implement and maintain a training program derived from a systems approach to training (as defined in 10 CFR 55.4) providing for the training and qualification of, among other nuclear power plant personnel, non-licensed operators. As stated 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 Commission." Under 10 CFR 50.54(y), at a Enclosure

nuclear power reactor facility for which the licensee has certified that operations have permanently ceased and fuel has been permanently removed from the reactor vessel, a CFH is authorized to approve taking reasonable action that departs from a license condition or a technical specification (TS) in an emergency when this action is immediately needed to protect the public health and safety and no action consistent with license conditions and technical specifications that can provide adequate or equivalent protection is immediately apparent.

In its Proposed Rule, "Decommissioning of Nuclear Power Reactors," published in the Federal Register on July 20, 1995 (60 FR 37374), the Commission explained that a certified fuel handler at a permanently shutdown and defueled nuclear power reactor undergoing decommissioning has the requisite knowledge and experience to evaluate plant conditions and make such judgements. The Final Rule, published in the Federal Register on July 29, 1996 (61 FR 39278),

adopted a definition of "Certified Fuel Handler" in 10 CFR 50.2.

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 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 ....

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, 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; 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 qualifications 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 shut down and defueled would reassess their staffing plans related to decommissioning organization structure; retaining, re-assigning or releasing staff; and meeting minimum staffing requirements in TSs 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 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 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, 2016 (ADAMS Accession No. ML14162A209).

The regulatory requirements and guidance that the NRC staff used in its review of the proposed CFH Training and Retraining Program for JAF 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 NRC inspection to verify 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 JAF 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 for JAF, as provided in Attachment 1 to Entergy's submittal dated January 15, 2016, as supplemented by the letter dated August 18, 2016, was reviewed by the NRC staff. In its January 15, 2016, letter, the licensee stated, in part, that the approval of a CFH Training Program " ... is needed to facilitate activities associated with decommissioning and irradiated fuel handling and management."

The proposed CFH Training and Retraining Program in the enclosure to the licensee's letter dated August 18, 2016, Section 1.1, "Initial Training Program," subsection "Fundamentals

Training," states that the fundamental training phase of the CFH Training Program consists of lectures and/or self-study of 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 facility status. Further, as described in subsection "On-The-Job Training (OJT)," the OJT of the CFH Training and Retraining Program will include 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. The OJT will also include training on the facility license, and the content, bases, and importance of TSs. 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.

The proposed CFH Training and Retraining Program enclosed in the licensee's letter dated August 18, 2016, Section 1.2, "Retraining Program," states that all CFHs will participate in the retraining program. The CFH retraining program 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 JAF meets all 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 JAF 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 the 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 January 15, 2016, that the CFH Training and Retraining Program for JAF "will ensure that the qualifications of personnel are commensurate with the tasks to be performed and the conditions requiring response." Further, Entergy stated, in part, that the CFH Training and Retraining Program will " ... align with the provisions of 10 CFR 50.120 .... " and "provides adequate confidence that appropriate SAT based training of personnel who will perform Certified Fuel Handler duties is conducted to ensure the facility is maintained in a safe and stable condition."

Section 1, "Introduction," of the proposed CFH Training and Retraining Program, enclosed in the letter dated August 18, 2016, states that "[t]he Certified Fuel Handler Training and Retraining Program contained herein describes the training program to be implemented by licensees to ensure the monitoring, handling, storage, and cooling of nuclear fuel is performed in a manner consistent with ensuring the public health and safety." In the letter dated June 3, 2016, in response to Request for Additional Information (RAl)-2, Entergy clarified that the term "licensees," as used in the above mentioned sentence, is in reference to the holders of Renewed Facility Operating License No. DPR-059: Entergy Nuclear Operations, Inc. and Entergy Nuclear FitzPatrick, LLC.

Also, Section 1 of the enclosure in the letter dated August 18, 2016, states, in part, that "[t]he 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 (e.g., medical)." Further, Section 1 states that the CFH Training and Retraining Program is based on a SAT process and consists of an initial training program and a retraining program, as described therein. In addition, Section 1 states that although the CFH Training and Retraining Program is not accredited with the National Academy for Nuclear Training, it will adhere to the guidelines of Revision 1 of NUREG-1220, "Training Review Criteria and Procedures" (ADAMS Accession No. ML102571869), which are applicable to a permanently defueled facility and based on a SAT process.

The NRC staff reviewed the proposed CFH Training and Retraining Program for JAF contained in its letter dated January 15, 2016, as supplemented by letter dated August 18, 2016, 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 1.1 of the proposed CFH Training and Retraining Program for JAF states that the selection of topics for the fundamentals training phase of the program will be based on a job analysis for the CFH tasks and functions. The job analysis will be performed by an individual holding a Senior Reactor Operator (SRO) license at the facility. A Difficulty, Importance and Frequency (DIF) rating will be assigned to each CFH task by a holder of an SRO license who is familiar with the expected plant conditions during decommissioning. A review of the DIF ratings for each task will be performed by Operations and Training personnel and management.

Learning objectives will be derived from the analysis to describe the performance after training.

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. The training plan will be developed utilizing the SAT process, and will adhere to the guidelines of NUREG-1220, Revision 1, that are applicable to a permanently defueled facility.

The NRC staff reviewed Entergy procedures EN-TQ-201, "Systematic Approach to Training Process," Revision 21; EN-TQ-201-01, "SAT -Analysis Phase," Revision 15; and EN-TQ-201-02, "SAT - Design Phase," Revision 2 (referenced in Section 1.1 of the proposed CFH Training and Retraining Program dated August 18, 2016). Procedure EN-TQ-201 establishes the process for SAT, to be used for the development, administration, and maintenance of training programs at Entergy nuclear facilities. Procedure EN-TQ-201-01 describes the activities performed in the analysis phase of the SAT process and provides specific guidance to ensure that the completion of the job/needs analysis results in a valid task list, with relevant job analysis data, and that tasks identified in the job analysis are further analyzed to identify the key elements, knowledge, and skills required for successful completion.

Procedure EN-TQ-201-02 describes the activities performed in the design phase of the SAT process and provides guidance on how the information developed in the analysis phase of the SAT process should be used to produce training design specifications for the development, implementation, and evaluation of the training program, and ensures that such specifications are developed systematically and are traceable to job and task performance requirements.

The NRC staff finds the licensee's plan to use these procedures to conduct systematic analysis of jobs to be performed and to derive learning objectives from that analysis to be consistent with SAT elements 1 and 2 above.

Section 1.2 of the proposed CFH Training and Retraining Program for JAF 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 retraining plan will be developed utilizing the SAT process, and will adhere to the guidelines of NUREG-1220, Revision 1, that are applicable to a permanently defueled facility.

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

SAT element 3 requires that the training design and implementation be based upon the learning objectives. Section 1.1 of the proposed CFH Training and Retraining Program for JAF states that training materials will be designed based on the learning objectives.

The NRC staff reviewed Entergy procedure EN-TQ-201-03, "SAT - Development Phase,"

Revision 8 (referenced in Section 1.1 of the proposed CFH Training and Retraining Program

dated August 18, 2016). Procedure EN-TQ-201-03 describes the activities performed in the development phase of the SAT process. It provides specific guidance on the use of training specifications developed in the design phase, and the development of training materials in a manner that ensures that learning objectives are achieved.

The NRG 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 above.

Section 1.1 of the proposed CFH Training and Retraining Program for JAF 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 "Candidate Evaluation," states, in part, that a comprehensive final examination shall 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 1O (ADAMS Accession No. ML14352A297). The operating examination requires passing a minimum of 80 percent of the administered JPMs to pass.

Section 1.2, "Retraining Program," of the proposed CFH Training and Retraining Program for JAF states that participants in the CFH retraining program must pass a biennial written examination and an annual operating examination to maintain their qualifications. 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 NRG staff reviewed Entergy procedure EN-TQ-201-04, "SAT - Implementation Phase,"

Revision 6 (referenced in Section 1.1 of the proposed CFH Training and Retraining Program in the submittal dated August 18, 2016). Procedure EN-TQ-201-04 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, collection and evaluation of student feedback, conduct of in-training evaluation, and documentation of training.

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

Section 1.3, "Program Evaluation," of the proposed CFH Training and Retraining Program states that routine assessments of the effectiveness and accuracy of training 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 Entergy procedure EN-TQ-201-05, "SAT - Evaluation Phase,"

Revision 3 (referenced in Section 1.1 of the proposed CFH Training and Retraining Program in the submittal dated August 18, 2016). Procedure EN-TQ-201-05 describes the activities performed in the evaluation phase of the SAT process. It provides specific guidance for the conduct of the activities during the evaluation phase, including monitoring feedback, verification of training effectiveness, and maintenance of program effectiveness.

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 above.

3.2.2 Compliance with 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 for JAF enclosed in its letter dated January 15, 2016, as supplemented by letter dated August 18, 2016, and confirmed that each of the 10 CFR 50.120(b)(3) requirements is satisfied as discussed below:

Section 1.1, subsection "Fundamentals Training," states that the job analysis for the CFH tasks and functions will be performed by an individual holding an SRO license at the facility. 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. Further, subsection "Candidate Evaluation," states that a comprehensive final examination shall be administered at the end of the initial training program and will consist of a written examination and an operating examination, which are described in Appendices A and B, respectively, of the proposed CFH Training and Retraining Program. Further, Section 1.2, subsection "Evaluation of Retraining," states that the participants in the CFH retraining 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 for JAF 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 this satisfies element "a" above.

Section 1 "Introduction," states, in part, that the training program shall comply with the facility's TSs and be consistent with the level of hazard at the facility and ensure that the facility is maintained in a safe and stable condition. It further states that candidates in the training program must meet minimum applicable operator experience requirements of the facility Technical Specifications.

In the June 3, 2016, submittal, in response to RAl-2b, Entergy clarified that the abovementioned statements refer to JAF TS 5.3, "Plant Staff Qualifications." A generic reference to the TS is used in the JAF CFH Training and Retraining Program document for administrative reasons, in the event that it may be revised or renumbered by a subsequent license amendment. The NRC staff finds that this is consistent with element "b" above.

Section 1.3 "Program Evaluation," states, in part, that routine assessments of the effectiveness and accuracy of training are conducted by appropriate management personnel during and at the end of each 2-year training cycle.

These routine assessments ensure that the JAF CFH Training and Retraining Program contains the guidance necessary to ensure compliance with the requirements of the SAT process, and that the program is revised to incorporate changes to the program, as appropriate, to reflect industry experience, changes to the facility, procedures, regulations, and quality assurance requirements. Evaluation results are reviewed by a station oversight board and any required changes, as determined by the board, are 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 1.4, "Records Retention," states that records associated with the proposed CFH Training and Retraining Program will be retained in 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 1.5, "Evaluating Changes to the CFH 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 JAF 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 JAF in the enclosure contained in the letter dated August 18, 2016, pursuant to 10 CFR 50.2. Because the program is based on SAT, the licensee may change elements of the program without NRC approval provided 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, NRR Date: October 17, 2016

ML16259A347 *via email OFFICE NRR/DORL/LPL4-2/PM NRR/DORL/LPL4-2/LA NRR/DRA/APHB/BC*

NAME TWenoert PBlechman SWeerakkodv DATE 9/19/16 9/19/16 9/12/16 OFFICE OGC- NLO NRR/DORL/LPL 1-1/BC NRR/DORL/LPL 1-1/PM NAME DRoth TTate SKoenick for DRender TWengert for DATE 9/30/16 10/14/16 10/17/16