LIC-16-0090, Response to Request for Additional Information Regarding Certified Fuel Handler Training Program

Response to Request for Additional Information Regarding Certified Fuel Handler Training Program

ML16281A479
Person / Time
Site:	Fort Calhoun
Issue date:	10/07/2016
From:	Marik S Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF8112, LIC-16-0090
Download: ML16281A479 (4)

Text

Omaha Public Power District LIC-16-0090 October 07, 2016 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station (FCS), Unit 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

Response to Request for Additional Information, Fort Calhoun Station, Unit No. 1

- Request for Additional Information RE: Certified Fuel Handler Training Program (CAC NO. MF8112)

References:

1. Letter from OPPD (S. M. Marik) to USNRC (Document Control Desk), "Request for Approval of Certified Fuel Handler Training Program," dated July 7, 2016 (LIC-16-0049)(ML16190A208)

2. Letter from NRC (C. F. Lyon) to OPPD (S. M. Marik), "Fort Calhoun Station, Unit No. 1 - Request for Additional Information Re: Certified Fuel Handler Training Program (CAC NO. MF8112)", dated September 20, 2016 (ML16263A049)

3. Letter from OPPD (S. M. Merik) to USNRC (Document Control Desk), "License Amendment Request (LAR) 16-03; Revised Fort Calhoun Station Technical Specifications to align staffing requirements to those required for decommissioning."

dated September 28, 2016 (LIC-16-0092)

Attached is the Omaha Public Power District (OPPD) response to a NRC request for additional information (RAI) (Reference 2) regarding Letter for Approval of Certified Fuel Handler (CFH)

Training Program (Reference 1), which proposed incorporation of the training program for use in training Certified Fuel Handlers.

A correction to paragraph seven (7) of the cover letter (Reference 1) is required to revise the stated standard to match Fort Calhoun Station (FCS) Technical Specifications. The standard referenced in the paragraph is revised as follows; "The FCS CFH Training and Retraining Program 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 ANSIIANS N18.1-1971 3.1 1978, "American National Standard for Selection and Training of Nuclear Power Plant Personnel," standards approved and implemented at FCS ."

444 SOUTH 16TH STREET MALL

• OMAHA, NE 68102-2247

U.S. Nuclear Regulatory Commission LIC-16-0090 Page 2 This letter contains no regulatory commitments .

If you should have any questions regarding this submittal or require additional information, please contact Mr. Bradley H. Blome at (402) 533-7270.

Respectfully,

~~f~

r=o,.

Shane M. Marik Site Vice President and CNO SMM/DMP Attachment c: K. M. Kennedy, NRC Regional Administrator, Region IV C. F. Lyon, NRC Senior Project Manager S. M. Schneider, NRC Senior Resident Inspector Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

LIC-16-0090 Attachment Page 1 REQUEST FOR ADDITIONAL INFORMATION CERTIFIED FUEL HANDLER TRAINING PROGRAM OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO. 1 DOCKET NO. 50-285 By letter dated July 7, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16190A208), Omaha Public Power District submitted a request for approval of the Certified Fuel Handler Training and Retraining Program at Fort Calhoun Station, Unit No. 1 (FCS).

The U.S. Nuclear Regulatory Commission staff has reviewed the information provided in your submittal and determined that additional information is required in order to complete its formal review of the request.

The NRC staff has reviewed Certified Fuel Handler Training Program approval requests for several decommissioning licensees, and those requests include a section titled "Evaluating Changes to the Certified Fuel Handler Training and Retraining Program," which generally states that changes may be made to 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 Section 50.120 of Title 10 of the Code of Federal Regulations. The submittal for FCS appears to be missing this section. Please provide a justification for why this section is not included in the submittal, or where the information is located if it is included.

OPPD Response

"( 1) suitable proficiency in the performance of the program's activities is maintained."

Changes to the FCS training and retraining program made without prior NRC approval ensure the program continues to comply with current Technical Specification (TS) 5.3.1 , which states the following:

"Each member of the plant staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, with the exception of the Manager- Radiation Protection (MRP) and the Shift Technical Advisor (STA), the senior reactor operator licensees, and the reactor operator licensees, who shall meet the requirements set forth in Regulatory Guide 1.8, Revision 3, dated May 2000, entitled "Qualification and Training of Personnel for Nuclear Power Plants.""

The proposed TS change to the Facility Staff Qualification, Section 5.3.1 and 5.3.2 (Reference 3) to align it with the decommissioning staffing requirements continues to ensure the program complies with the TS:

"5.3.1 Each member of the plant staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, with the exception of the Manager-Radiation Protection (MRP), who shall meet the requirements set forth in Regulatory Guide 1.8, Revision 3, dated May 2000, entitled "Qualification and Training of Personnel for Nuclear Power Plants."

LIC-16-0090 Attachment Page 2 5.3.2 An NRC approved training and retraining program for the CERTIFIED FUEL HANDLER shall be maintained. "

In addition to complying with TS 5.3.1 and proposed TS 5.3.2, suitable proficiency in the performance of the program 's activity is maintained in TQ-FC-1 01, Certified Fuel Handler Training and Retraining Program sections:

Section 2.5, Systems Approach to Training (SAT) "The SAT process contains the following elements:

2.5.1 Systematic analysis of the jobs to be performed.

2.5.2 Learning objectives derived from the analyses which describe desired performance after training .

2.5.3 Training design and implementation based on the learning objectives.

2.5.4 Evaluation of trainee mastery of the objectives during training.

2.5.5 Evaluation and revision of the training based on the performance of trained personnel in the job setting."

Section 3.1.2, "The program shall comply with ANSI N18.1-1971 (reference 5.7),

"Selection and Training of Nuclear Power Plant Personnel", as specified in Technical Specifications 5.3.1 and be consistent with level of hazard at the facility and to ensure the facility is maintained in a safe and stable condition." Also in the draft TQ-FC-1 01 ,

Certified Fuel Handler Training and Retraining Program, Section 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 applicable change processes and the program continues to comply with ANSI N 18.1-1971 (Reference 5. 7)."

And

"(2) changes are documented in an accessible manner that will allow the NRC to verify the adequacy of the program in accordance with Section 50.120 of Title 10 of the Code of Federal Regulations."

The information requested is presently located in the draft TQ-FC-101 , Certified Fuel Handler Training and Retraining Program, Section 4, DOCUMENTATION:

"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 CFH position at the facility (i.e., all fuel permanently transferred to a dry fuel storage facility)."