ML20195F545
| ML20195F545 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 06/11/1999 |
| From: | Ladd M AFFILIATION NOT ASSIGNED, NORTHERN STATES POWER CO. |
| To: | |
| Shared Package | |
| ML20195F538 | List: |
| References | |
| ISFSI, NUDOCS 9906150025 | |
| Download: ML20195F545 (64) | |
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r, m UNITED STATES OF AMERICA -
NUCLEAR REGULATORY COMMISSION Defore the Atomic Safety and Licensing Board i
In the Matter of -
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PRIVATE FUEL STORAGE L L.C.
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Docket No. 72-22 l
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(Private Fuel Storage Facility)
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DECLARATION OF MICHAEL LADD Michael J. Ladd states as follows under penalties ofperjury:
1.
I am the Training Process Manager at the Prairic Island Nuclear Generat-ing Station for the Northern States Power Company. In that position I am responsible for reviewing, evahiating, and implementing the training program at the Prairie Island plant.
I am providing this declaration in support of a motion for summary disposition of Con-tentions Utah F and Utah P in the above captioned proceeding to show that Private Fuel Storage's (PFS) training and cenification program for the Private Fuel Storage Facility g
(PFSF) satisfies the requirements of Subpart I of 10 C.F.R. Part 72.
2.
My professional and educational experience is summarized in the cur-riculum vitae attached as Exhibit I to this declaration. I have extensive experience de-signing and evaluating NRC training programs. I have been and am currently responsible for ensuring that all training programs for the Prairie Island Nuclear Site meet and or ex-ceed NRC and Institute of Nuclear Power Operations ("INP0") guidelines for training and qualification. This involves review and use of all NRC Regulations, NRC and INPO Ouidelines, NRC Regulatory Guides, American National Standards Institute (ANST) standards associated with nuclear power plant training and simulator training, as well as 9906150025 990611 PDR ADOCK 07200022 t'
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m W. Ud all rules of usage, when implementing the NRC's " Systematic Approach to Training develop, implement and evaluate training programs.
3.
In addition, throughout my career,! have had a wide range of other re-sponsibilities related to the training ofpersonnel for nuclear facilities. I have been an in-structor for General Employco Training, opemtions, engincering, maintenance, radiation protection and chemistry and emergency planning. I have also served as an Operations instructor in Which capacity I designed the inllial, continuing training, and simulator training for the Monticello Nuclear Plant. I have also performed audit exams for various utilities across the United States on operator license candidates for both pressurized water o'
reactors and boiling water reactors. I have also served as a Technical Training Superin-l tendent in which capacity I supervised a staff of 11 instructors and engineers that ana-lyzed, designed, developed, implemented and evaluated training programs for Radiation Protection and Chemistry, Electrical and Mechanical Maintenance, Engineering, Instru-mentation and Control, and Construction and Craft personnel at Prairic Island, I have also developed and reviewed task lists and associa:ed training program descriptions and course outlines as well as on-the-job training (OJT) and oral and written exams for all disciplines at a nuclear facility. In February of 1998, I assisted in an evaluation of the Fitzpatrick Nuclear Power Plant in New York to evaluate their Operations training. In March of this year, I was team member of the World Association ofNuclear Operators that evaluated the Three Mile island Nuclear Generating plant. My area of concentration was, training qualification and management of all site training programs.
4.
I am knowledgeable of the PFS training program. Before providing this declaration, I have thoroughly reviewed the training program as described in the PFSF License Application (LA) and Safety Analysis Report (SAR) and evaluated it against the requirements set forth in 10 C.F.R. {$ 72.190,192 and 194 and related NRC and industry guidelines, standards and practices.
5.
The State of Utah alleges in Utah F that the training and certification of PFS personnel as described in the LA and the SAR fail to satisfy Subpart I of 10 C.F.R. 2 e
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- 1 Part 72 and will not assure that the PFSF is operated in a safe manner. I have reviewed the State's allegations and the PFSF training program and have determined that, contrary to the Statc's allegation, the PF5 program provides for the proper training, testing, and 1
. certification of PFSF personnel in accordance with NRC regulations and well established principles for the training ofnuc1 car personnel. In addition, PFS has set forth in appro-priate detail personnel qualifications and testing and training requirements for PFSF per sonnel.
6;
. NRC regulations provide that a program for the training ofIndependent Spent Fuel Installation (ISFS1) personnel is to consist of" training, proficiency testing, and certification ofISFSI... personnel." 10 C.F.R. f 72.192. The pFSF LA and S AR provide for such a training program. The PFSF training program as described in the LA.
and the SAR identifies those PFSF personnel that are to be trained and the specific arcas in which training is to occur. It provides for systematic approach to their training by adopting the " Systematic Approach to Training" (SAT), which is a well defined training
. process mandated by the NRC for the training of nuclear plant operators under 10 C.F.R.
l i 55.4 for developing the detailed curriculum for training PFSF personnel in the areas identified in the LA and the SAR. As it does for operator training, the PFS program similarly provides for a systematic approach for testing operator proficiency and it pro-vides the standards which are to be used in operator certification for the PFSF. This is a comprehensive program that more than adequately covers each of the points that 10 C,F.R. ( 72.192 mandates for the training ofISFSI personnel.
7.
In terms of those persons who are to be trained, the SAR provides that
"[i]ndividuals who operate equipment and controls that have been identified as *1mpor-tant to safety' in the Safety Analysis Report and in the NRC license must be trained and certified. Superv'.sory personnel who direct the operation of equipment and controls that j
are 'important to safety' must also be certified." SAR at 9.3-3. Thus. the scope of the PFS training program is in accordance with NRC requirements set furth in 10 C.F.R. 6 3
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72.190, which mandates the training of personnel operating equipment important to safety and their supervisors.
8.
The SAR goes on to identify the specific areas in which these persons are to be trained. It provides that "the "PFS Operator Train!ng Program" will address the i
following subject areas: 1) canister transfer system design and operations,2) canister transfer system normal and off-normal procedures,3) storage facility normal and off-normal procedures,4) nonnal and off-normal transportation procedures for on-site trans-portation 5) maintenance, 6) storage cask temperature monitoring system, 7) radiation detection, monitoring, sampling, and survey instruments, 8) facility layout and functions, 1
- 9) operator responsibility and authority,10) Technical Specifications,11) normal and emergency communications,12) transportation, and 13) topics covered in General Em-playee Training (OET) with specific emphasis on operations. SAR at 9.3-3 to-4. (The SAR also specifies the topics in which OET will be provided, which includes facility op-oration and design. SAR at 9.3-2 to -3.)
9.
In addition to substantive topics, the SAR provides that "[a]!! [PFS) per-sonnel involved in activities important to safety will be trained on the associated procc-dures prior to conducting the activity. Fonnal training of personnel on facility procedures will be substantially complete prior to the receipt ofradioactive materials at the PFSF."
SAR at 9.4-5. Further, PFS has specified the " format and depth of coverage" of the for-mal procedurcs that PFS will generate for the activities importut to safety at the PFSF and on which all PFSF personnel involved in such actifitics will be trained. SAR at 9.4-4.
10.
As part of their certification training, appropriate personnel will also con-duct preoperational testing of the actual storage system components at the PFSF. The testing will be conducted without fuel but will include full load testing of all rigging and attachments, and limitr of travel on lining and transfer equipment. SAR at 9.2-4. "The purpose for operational testing is to ensure that... personnel involved in spent fuel ship-ping, receipt, and canister transfer, onsite transport, and storage operations perform their intended tasks in accordance with approved procedurcs, with ALARA awareness, with 4
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emciency, and without compromising personnel or public safety." SAR at 9.2 5. The specific piecca of equipment on which PFS personnel will conduct preoperational testing as pad of their ocrtification are specified in the PFS SAR. SAR at 9,2-4. The specific operational tests that pFS personnel will perform as past of their certification are also specified in the SAR. SAR at 9.2-5 to -4.
I1.
' Finally, the SAR pinvides that where training in addition to that specified -
in the SAR is required, training materials will be developed using the Systematic Ap-
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proach to Training (described in Paragraphs 12-14). SAR at 9.3-4. Exceptions to the use of the SAT method in the development of the curriculum for the training program will be approved on a case-by case basis by the emergency preparodness coordinator. SAR at 9.3-4.
12.
Thus, the SAR identifies the arcas on which PFSF personnel who operate equipment and controls that have been identitled as "important to safety" and their super-visors are to be trained. Further, the SAR providea that training in thcae areas will be im-ple.7 tented "using a Systematic Approach to Training," SAR st 9.3-1, which as previously noted is a well defined process mandated by the NRC for the training of nuclear plant op-erators under 10 C.F.R. i 55.4. The SAT as defined in 10 C.F.R. 6 55.4 includes five be-sic c!cments. These are:
- 1) Systematic analysis of thejobs to be performed.
- 2) Leaming objectives derived from the analysis which describe desired performance aftor training.
- 3) Training design and impicmentation 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 l;erformance of trained personnel in the job settina.
13.
The PFSF SAR elaborates on how PFS will use the SAT to implement its.
training program. The SAR provides that following the SAT method, the training pro-d 5
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gram will be " based upon analysis of thejob performance requirements to establish the.
knowledge level and skills that am required for each position" at the PFSF. SAR at 9.3
- 1. The SAR goes on to state that:
Explicit learning objcctives and performance measurcs are generated fmm this analysis. Training plans are then developed which identify training settings, sequences, and materials required. The training program is im.
plemented by conducting the training activities, documenting the training
. and evaluating the program's effectiveness.
4 Job descriptions will detail the training, education, and experience re-quirements for each position. An individual asacasment of the employee's needs will be conducted relative to the identified training mquirements of each of the mspective positions. Training will consist of classroom and on-the-job training (OJT), as appropriate, for all individuals, commensu-rate with theirjob duties an responsibilities.
I SAR at 9.3-1. ' Training materials will be developed by the site personnel qualified on
[the relevant] tasks. Training will also be delivered by individuals quallflod on the par-ticular tasks,'or by appropriate contractors." Id. at 9.3-4. In conducting their training, trainers will follow a curriculum that outlines the steps necessary to perform each task on which they are instructing. PFS Response to RAI 910 (May 19,1998), attached as Ex-hibit 2 to this declaration.
14.
. Thus, the PFS training program provides for the comprehensive training of
. PFSF personnel in the various areas that they will be required to function in accordance with the well-established pdnciples of the SAT. The SAT is a well-defined process -
impicmented at nuclear power plants throughout industry-by which PFS will identify the functions to be performed at the PFSF, develop individualjob tasks for each of the
' functions, and link those individualjob tasks to individual training curriculum and objec-tives, testing requirements and uMmately certification. The implementation of the PFS triining program through the y eli defined industry-wide approach dermed by the SAT is analogous to a quality assurance program that is implemented through its quality assur-unce procedurcs.
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if. M U 15.
The PFS training program also provides personnel qualification and test-ing and certification requirements fcr PFSF personnel. PFS has specified, pursuam to 10 C.F.R. ( 72.28(a), the minimum personnel qualification requirements for holders of key positions at the PFSF, including: General Manager /ChictOperating Officer, Radiation Protection Manager, Radiation Protection Technicians, Lead Mechanic / Operator, Me-chanics. Lead Instrument and Electrical Technician, Instrument and Electrical Techni-cians, Lead Quality Assurance Technician. Quality Assurance Technician and Quality Assurance Auditor, Lead Nuclear Engineer, Nuclear Engineers, Security Captain. and the Emergency Preparedness Coordinator. SAR at 9.1-23 to -27.
16.
The PFS training program also acts forth both formal testing requinments, tied to specific passing examination grades as well as on-thejob training (OJT) requiro-ments that "will be documented in a set of Qualification Cards containing the Job Per.
formance Measures of practical factors that are required to be performed by the Opera-tor." LA at 7-1. The LA sets forth the related proficiency testing and certification stan-I dards as follows:
{As described above.] [t]he OJT requirements will be documented in a set of Qualification Cards containing the Job Performance Measures ofprac-tical factors that are requirod to be performed by the Operator. Each per-son to become Certified must have these Qualification Cards completed prior to being allowed to independently perfonn the applicable tasks....
The operators will have to pass comprehensive written and practical ex-aminations in order to become Certified. The trainee must score 80% or higher on the written cxam to pass. The practical exam shall be on a pass / fall basis, as evaluated by previously Certified personnel.,..
v LA at 7-1. Thus, the PFS training program provides that proficiency is to be tested by completion of OJT qualification cards, a practical exam based on the OJT, and a formal written exam. PFS elaborated on the formal testing process in response to a Request for 1
AdditionalInformation from the NRC Staff. PFS reiterated that,"[ alt the conclusion of task training, proficiency testing will be administered to ensure that proper understanding has been achieved by the person being trained. A test will be prepared and graded by the insuuctor and will be retained in the facility records for a two year period." Response to 7
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RAI 9-10 (May 19,1998). Such testing will flow directly from PFS's use of the SAT to
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implement its training program, for under 10 C.F.R. 6 55.4 the SAT calls for " training design and implementation based on the learning objectives" and " evaluation of trainee i
mastery of the objectivos during training."
17.
Finally, the PFS training program provides the standards under which op-erators are to become certified before independently operating equipment important to safety. Specincally, they follow the areas ofpmficiency testing. An operator must have completed the OJT qualification cards, pass the practical exam, and achieve an 80% or higher on the formal written exam. LA at 7-1. PFS will certify that all personnel are trained as required as past of the PFSF Operational Readiness Rcvicw, before receiving l
spent fuel at the PFSF. SAR at 9.2-7.
18.
Further, in accordance with the SAT methodology, the SAR provides for the evaluation of the PFS training program: "the effectiveness of the training, and the training program will bc cvaluated by reviewing written test performances, performance on walk through evaluations, on-the-job training, and feedback from trainces, supervi-sors, and instructors." Ld. at 9.3 2 j
19.
After initial training, testing, and certification, all PFS employees will re-ceive periodic retraining. All PFS personnel will receive OET retraining - on all GET
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topics -at least once every two years. SAR at 9.3 5. PFS employees will also receive job-specific and certification retraining at least once every two years. Topics for retrain-ing will be selected from initial training, NRC bulletins and information notices, major equipment and procedure changes, relevant industry events, and topics designated by the 3
PFSF Ocneral Manager or requested by other site personnel. SAR at 9.3-5. PFS elabo-I rated on the retraining that it would undertake in response to RAI 9-10 as follows:
Retraining and refresher training will be provided at intervals that are ap-i propriate to the specific task. Retraining will involve a review of the basic tasks plus special attention to those items within the task which have un-dergone change. When new equipment is added or modifications in ex-8 1
l isting equipment of a significant nature are madc, procedures will be modified and retraining on the revised procedure and equipment by a g
qualified instructor will be provided to those persons already certified prior to operation of that equipment.
Exhibit 2, Response to RAI 9-10 (May 19.1998).
l 20.
In summary, PFS has described in detail the specific subject arcas and PFSF systems and components on which PFS employees will receive training, defined the process (i.e., the SAT) by which this training is to be implemented, and set forth the i
requirements and standards for the testing of proficiency and certification ofPFSF per-l sonnel. The PFS training program more than adequately addresses each of the three NRC requirements specified in 10 C.F.R. { 72.192 and there is no basis for the State's claim in Utah F that PFS has not submitted or adequately " defined a training and certification pro-gram" for the PFSF.
21.
Indeed, the level of detail in the PFSF training program as described in the g
LA and the SAR is equivalent to, or exceeds, that found in the license applications and safety analysis reports for other ISFSIs. Attached as Exhibit 3 to this declaration is the
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training program included in the Part 72 license application for the ISFSI located at the f
Calvert Cliffs Nuclear Power Plant; attached as Exhibit 4 is the training program included in the Part 72 license application for the ISFSI located at the Prairie Island Nuclear Gen-erating Plant. As can be seen from reviewing these programs, the level of detail in the PFSF license application on the whole exceeds that found in these two ISFSI applica-tions. Although both generally referred to using their existing nuclear plant training pro-grams, the development of the training program for ISFSI specific activities in these ap-plications was generally less than that set forth in the PFSF application. Thus, based on accepted NRC practice, and the SAT principles on which the PFSF training program is based, the training program set forth in the PFSF LA and SAR provides sullicient infor-mation regarding the " training, proficiency testing, und certification ofISFSI... person-nel" to satisfy NRC requirements set forth in 10 C.F.R. { 72.192.
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afsc% vua nues e, m 22.
In Utah F, the State raises a number of specific alleged deficiencies in the PFS Training Program. I have reviewed each of these assertions and have found none to j
be' meritorious. First, the State asserts in basis I for Utah F that PFS has failed to submit a " listing ofphysical conditions that would bar a person from employment in specific po-v sitions." However 10 C.F.R. I 72.194 (physical requirements) requires no such listing of physical or mental conditions that would bar a person from employmont at an ISFST. It 1
simply requires that "[a]ny condition that might cause impairedjudgement or motor co-1 ordination must be considered in the selection of personnel for activities that are impor-tant to safety " It explicitly goca on to state that "[t]hese conditions need not categori-cally disqualify a person, if appropriate provisions are made to accommodate such de-d fect." 10 C.F.R. 6 72.192.
23.
In basis 3 to Utah F, the State asserts that PFS has not shown that the j
qualifications that will be required of PFSF personnel are sufficient to guarantee that the I
facility will be operated safely in a number of respects, the first being that neither the General Manager nor the Operators are required to have any experience in dry storage operations. The State's assertion is unfounded, in that the General Manager and the Op-erators will be tramed to operate the PFSF safely as described above and moreover. their qualifications will be consistent with the qualifications of similarly situated personnel at nuclear power plants licensed by the NRC as well as those personnel that operate ISFSIs licensed under Part 72 located at nuclear power plants.
24.
In addition to being trained and certified, the PFS General Manger and op-erators will have sufficient education and experience to operate the PFSF safely. The PFS SAR states that the PFS Ocneral Manager will have ten years of" responsible experi-ence within the nuclear industry" and a bachclor's degree "in an engineering or scientific field generally associated with nuclear power production, fuel storage, or radiation pro-tcction." SAR at 9.1-23 to -24. Ftuthermore the General Manager shall be familiar with all applicable rules, regulations, codes and procedures. SAR at 9.1-15. Thus the PFS g
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General Manascr's qualifications will be more than sufficient to ensure that the PFSF is operated safbly.
25.
Further, prior experience in dry-storage operations per se is not required.
NRC regulations require that the license upplication include "the technical qualifications, including training and experience, of the applicant to engage in the proposed activities."
10 C.F.R. I 72.28(a). American National Standard N18.1-1971, Selection and Training ofNuclear Power Plant Personnel, f 4.1 (March 1971), states that Nuclear power plant personnel shall have that combination of education, experience, health, and skills commensurate with their level of responsi-bility, which provides reasonable assurance that decisions and actions during all normal and abnormal conditions will be such that the plant is operated in a safe and efficient manner
%us the standard does not call for prior experience in the specific jobs that personnel will perform at a plant. The NRC Staff has stated that it accepts the ANSI standard "as
[a] sourec[] for criteria and guidance, as applicable, for ISFSI... training." Standard Review Plan for Spent Fuel Dry Storage Facilities, NUREG-1567 (Draft, Oct.1996). at 13-7. Indeed, given the greater complcxity of operating and maintaining a nuclear power plant compared to that of an ISFSI, application of the ANSI standard for nuclear power plants to ISFSIs is conservative.
26.
The ANSI standard continues, regarding plant managers: "At the timo of initial core loading or appointment to the active position. the plant manager shall have ten years of responsible power plant experience, of which a minimum of three years shall be nuclear power plant experience." g { 4.2.1. " Nuclear power plant experience" is de-fined as "that nuclear experienoo acquired in the design, construction, startup, or opera-tion of nuclear power plants." g { 4.1. Thus the standard does not call for plant manag-ers to have specific experience in any single facet orplant operation, but rather that they have sufficient nuclear experience generally to understand plant operations and to make decisions such that the plant is operated in a safe and ellicient manner. Moreover, the 10 11 9
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a years of nuclear experience to be required of the PFSF General Manager substantially exceeds the 3-year muumum required by the ANSI standard.
' 27.
Regarding the education ofplant operators, the ANSI standard indicates that thor,e plant operators who will not bc licensed reactor operators should have a high school diploma or equivalent. ANSI N18.1-1971 l 4.5.1. Under this standard, non-
- licensed operators nced not have prior nuclear plant experience or prior experience at the specificjobs they will perform at the plant. PFS operators-who will not be licensed re-acto' r operators - will have high school diplomas plus four to six years of prior experience in mechanical maintenance. SAR at 9.1-24 to -25. Thus, they will have more experience than called for by the ANSI standard and therefore will be more than sufficiently quali-fied to operate the PFSF safely.
I 28.
Finally, as indicated in paragraph 7, all operators and all personnel who supervise them must be trained and certified. The PFS SAR, as shown above, describes the initial and continuing training programs and how eachjob and task at the PFSF will be constantly evaluated to ensure the training program is effective. Potential PFSF op-crators and the General Manager will have to complete a combination of classroom, OJT, and practical factors to demonstrate their mastery of the tasks they will be required to perform as PFSF operators.
29.
In basis 3 to Utah F, the State asserts further that PFS has not shown that the ' ualifications that will be required oTPFSF personnel are sufficient to guarantee that q
the facility will be operaied safely, in that the detail ofinstmetion courses, training pro-v grams, or work on simulation facilities is not laid out.
30.
The State's assertion is unfbunded, la that, as shown above, the PFS SAR docs provide sufficient detail regarding the PFS training program. PFS has also set forth I
the instruction courses that will be used to train PFS employees. As described in para-graph 8, PFS has specified the subject areas in which trainees will be instructed. As de-scribed in paragraphs 9-10, PFS has specified that trainees will be instructed on FFSF 12
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procedures and will be trained on actual PFSF equipment. As described in paragraph 9, PFS has specified the format and depth of coverage of the procedures on which trainees will be instructed. Further details are generated through the implementation procedures.
and are not required to be submitted with the application. Finally, the State's contention regarding simulator training is simply irrelevant, in that (as described in paragraph 10 above) PFS personnel will not be trained on simulators but rather, at least the initial PFSF '
personnel, will be trained on actual PFSF equipment prior to the receipt of fuel at the fa-cility. PFS SAR at 9.2-4 to -5. Therefore, contrary to the State's claim, trainees will -
have successfully manipulated real equipment prior to the receipt of spent nuclear fuel at i
the PFSF.
31.
In basis 3 to Utah F. the State asserts further that PFS has not shown that the qualifications that will be required of PFSF personnel are suflicient to guarantee that o,
the facility will be operated safely, in that PFS has not specified any written examinations and operating tests, including the items that would be on such a test. The State's assor-1 tion is wrong. PFS has specified the axaminations and twt that will be given to operators before they are certified. As described in paragraphs 16 and 17 above, PFS has described its testing and certification programs Furthermore, as also described above, PFS has specified the subjects and equipment on which operators are to be trained. Thus, PFS has specified the examinations and operating tests that PFSF trainocs will take; hence, PFS's submission is sufficient to meet NRC requirements.
32.
In basis 3 to Utah F, the State asserts further that PFS has not shown that the qualifications that will be required of PFSF personnel are sufficient to guarantcc that thc facility will be operated safely,in that PFS has not specified the terms of qualification and revocation of operator license, provisions for rcqualification, and enforcement.
33.
This claim is wrong as well. As described in paragraphs 16 and 17 above, PFS has specified the terms for qualification of PFSF operators. Furthermore, as de-scribed in paragraph 19 above, at least once every two years all PFS employees will be retrained generally and operators will rcccive certification retraining. The SAR also i
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l'.14 states specifically that personncl failurcs during operational testing, which is part of the operator certification program.' will result in " additional training, retraining. or dismissal e
of personnel." SAR at 9.2-5. Thus, PFS has in fact specified the terms of quali5 cation and requalification of PFSF operators and the means of enforcement of PFS training tv-f quidments.
34.
Furthermore, PFS will constantly evaluate its trainir:g program and the
' performance ofits employees in order to correct any deficiencies that might develop.
Page 9.3-2 of the SAR states, "[t]he training program depends on a constant evaluation of.
thejob or task to be perfonned, the work environment, and the training provided, to de-j termine whether the program is effective in producing and maintaining compctent om-ployees. Data from these evaluations are used to identify and correct deficiencics and to accommodate changing needs." The SAR commits PFS to the ongoing evaluation ofits.
training program; this is the final stcp in the SAT. The Evaluation phase of the SAT en-surcs that the PFS training program is dynamic and maintains its t:ffectiveness by evalu-
- 1 ating the opcrator's performance with written and practical evaluations at a minimum of every two years. This methodology ensures that any change in operator proficiency or knowledge that is training-related will require a change in the training program. Also, ongoing evalcation will require revicwing the training process to ensure that it is effec-tive in maintaining qualification and cenification of PFS personnel.
35.
In basis 3 to Utah F, the State asserts further that PFS has not shown that the qualifications that will be required of PFSF personnel are sufficient to guarantee that the facility will be operated safely. in that PFS merely states that "cach member of the site staffinvolved with important to safety activities will be required to meet the mini-mum qualifications of the License," without stating those qualifications and how they will assure the public health and safety.
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i 36.
The State overlooks important materialin the PFS SAR. SAR section 9.4 c'
states that "all personnel involved in activities important to safety will be trained on the j
associated procedures prior to conducting the activity.... Personnel performing activi-14
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ties important to safety will be certilled to perform such functions and will undergo re-4 fresher training and testing a minimum of every two years." SAR at 9.4-5. Those per-sonnel will go through the PPS training program described above, including its testing j
t and certification programs. Furthermore, in the implementation of the PF5 training pro-gram, the SAT will identify those critical tasks important to operator, sitc, and public health and safety. Personnel involved in activities important to safety will be trained on
, those tasks and will be certified and reevaluated at least once every two years to ensum proficiency. Nuclearindustry accredited training facilities follow this same snethodology to ensure that alto personnel are qualified and the health and safety of the public is main-tained at and around nuclear facilitics.
37.
In basis 3 to Utah F the State asserts further that PFS has not shown that i
the qualifications that will be required of PFSF personnel are adequate, in that PFS promises " Programs for additional site famillarization traming and ongohtg training and retraining" without stating the specific details of the training program and the minimum passing grade for certification.
38.
Contrary to the State's claim, PFS has indeed described the process by which PFSF employecs, including operators, will receive training and be certified subse-quent to receiving their initial training (see paragraph 19). Retraining will be conducted by means similar to those used to conduct initial training and on subjects similar to those on which initial training was conducted, but, consistent with the SAT process. PFS will continuously reevaluate its training program to ensure that it is flexible and best imparts to PFSF operators the knowledge and skills necemuy to operate the PFSF safely. Re-garding certification grades, the PFS training program iacbdes (as Indicated in para.
graphs 16-17) details such as the minimum passing grade for written exams (80%) and the standards fbr evaluating trainee perfonnance on the OJT and practical factors (pass / fail). Furthermore, during the implementation of the PFS training program, course descriptions and outlines will be written and derived, by following the Systematic Ap-proach to Training, that will provide greater detail related to initlai, fhmiliarization, certi-
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surtnewum nran e.m
' fication and qualification, and continuing training for all PFSF technical disciplines. As reflected by the Calvert Cliffs and Prairie Island ISFSI applications, Exhibits 3 and 4, those course descriptions and outlines, as products of the implementation of the training program, do not need to be submitted with the license application. The State is simply
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. calling for a level of detail that is not required at the license application stage.
39.
In basis 3 to Utah F, the State asserts further that PFS has not shown that the qualifications that will be required of PFSF personnel are sufficient to guarantee that
,s the facility will be operated safely, in that specific operational tests are stated on SAR 9.2-5 without Indicating the minimum terms for passing the course. The State's claim is baseless and simply ignorcs what the PFS LA and SAR says about the examination and certification of PFS employees on OJT and practical factors. As described in paragraphs 16-17, the PFS training program sets forth both formal testing requirements, tied to spe-cific passing examination grades as well as OJT requirements. The SAT to be followed by PFS requires that training objectives are written at the right cognitive and psychomo-tor Icvel to ensure that the trainee has mastered the necessary knowledge or ability upon completion of the evaluation phase of training. Each training objective will include a condition, a behavior to be demonstrated, and a standard for mastery. OJTs, JPMs, prac-tical factors, written exams, oral exams are written from the training objectives. Again, as stated above, the PFS License Application states that "OJT requirements will be documented in a set of Qualification Cards containing the Job Performance Measures of
. practical factors that are required to be performed by the Operator. Euch person to be -
come certified must have these Qualification Cards completed prior to bcing allowed to independently perfonn the applicable tasks." LA at 7-1. Therefbre, PFS has specified how it will derivs pcrformance measures for operational tests and how it will evaluate trainees against those performance measures.
40.
In short, the various claims raised by the State in its basis 3 to Utah F are without merit. Throughout this basis, the State is seeking more detail than that required by the NRC regulations at the license application stage, as is reflected by the Calvert 16 f
i n.-
J
,wtnrurwtonru
- r. u Cliffs and Prairic Island ISFSI training programs attached as Exhibits 3 and 4 to this declaration. There are sound reasons why such detail is not required at the license appli-cation stage. Among other reasons, the equipment on which training would be required has not yet been acquired. Nor are the procedures on which training would be required developed, or required to be developed, at the license application stagc; such procedures are not written until plant staff are on board Moreover, as a practical matter, it is desir-able to have the plant manager and other senior staffinvolved in preparing the curriculum and other detailed aspects for the implementation of the raining program.
41.
In Utah P, the State contends that the Applicant has fhlied to describe a fully developed radiation protection program that ensures ALARA occupational expo-sures to radiation by not " adequately describing a training program that insures all por-
. sonnel" who direct activitics or work directly with radioactive materials or areas arc ca-pable of evaluating "the significance of radiation doses in tenns of potential risk, includ-ing outlines of the training classes." I have revicwed the PFS application with respect to training for radiation protection and have determined that the information in the applica-tion is more than adequate at this, the license application stage. A fully developed Ra-diation Protection Training program, as alleged by the State, need not be described in the SAR. In particular, an outline of courses is a level of detail that far exceeds that required at the license application stage. The training information provided in the PFS SAR is suf-ficient for purposes of the application.
42.
In the SAR, PFS has conunitted to implementing a Radiation Protection Program in accordance with 10 C.F.R. (( 72.126,20.1011, and 19.12, and an ALARA program following the requirements of 10 C.F.R., Part 20 and the guidelines of NRC Regulatory Guides 8.8 and 8.10. SAR at 7.1-1 to -3. These provisionn to which PFS has conunitted require instruction in the significance of radiation dose. For examplo.10 C.F.R. i 19.12(a) calls for instruction in "the health protection problems associated with exposure to radiation." Further, the SAR expressly provides that "PFSF personnel will be trained and updated on ALARA practicos and dose reduction techniques to assure that 17
AFTr%rnannrm
- r. U1 each individual understands and follows procedures to maintain his/her dosc ALARA."
1 at 7.1-3 Further, during General Employee Training, all PFSF personnel will be 1
trained in "[t]he nature and sources of radiation and contamination, interactions of radia-tion with matter, biologics! effects of radiation, methods of detecting and controlling ra-diation and contamination, ALARA concepts, facility access and visitor controls, decon-tamination procedures, use of monitoring and personal protective equipment, regulatory j
and administrative exposure and contamination limits, and site specific hazards." SAR at 9.3-3. Thus, PFS has committed to, and has made provision for, educating PFSF person-nel in radiation safety, including the significance of radiation dose. The SAT will pro-vi.ic further detail in the implementation of this training.
43.
In conclusion, the PFS training program meets the requirements of the law as stated in 10 C.F.R. { 72.192. The specific details of course outlines, program de-scriptions, exams, objectives, OJTs and practical factors will be written and rewritten as PFS uses the SAT to implement its training program. The details submitted in the Private Fuel Storage Safety Analysis Report exceed what 10 C.F.R. I 72.192 requires.
I declare under penalty and perjury that the foregoing is true and correct.
Executed on June 11,1999.
MichKJ. Ladd 18
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EXHIBIT 1 l
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RESUME Michael J. Ladd 2008 Chestnut Drive Hudson, Wisconsin 54016 Phone:
(715)-381-1244 (Home)
(612) -3 86-1165 Ext. 4007 (Work)
EDUCATION Completed MBA at Webster College, (July 1981), Management & Business Completed.a BS in Occupational Education at Southern Illinois University, (August 1980)
Anticipate completion of BS at Winona State University, (1999)
EXPERIENCE November 1996 to Present - Training Process Manager Prairie Island:
I am responsible for maintaining the systematic approach to training and Institute of Nuclear Power Operations (INPO) accreditation in all Prairie Island training programs while integrating all training resources into the line organization.
Prairie Island training was identified as one of the top nine training programs out of 238 with excellent training at the 1998 INPO CEO conference. Preparing all Training Programs for accreditation renewal in 2000.
Represent PI on all NSP and Generation Training Committees and Process Reengineering teams.
February 2 996 to November 1996 - Senior Nuclear Consultant:
I Provided technical, operational, and administrative support to the CEO, President of Generation, the VP Nuclear, the Director Licensing and Management Itsues on all issues related to Nuclear Generation BWR and PWR. I was the INPO Nuclear Energy Institute, Investor Relations point of contact for all initiatives and emerging issues related to our nuclear plants.
I j
also acted as the point of contact for most other NSP Depts needing
)
information on our nuclear plants such as communications and risk management.
I wrote many presentations for the CEO, President Generation, VP Nuclear and the Director of Licensing on nuclear issues.
April 1991 to February 1996 -Technical Training Superintendent:
I provided direction, support and supervision 10 Instructors and Engineers, to administer & maintain 7 INPO accredited programs and SRO Certification program.
Oversee the Emergency Preparedness Training & Scenario development process.
Summer of 1993 Acting Training Manager for Prairie Island Nuclear Generating Site. Member of Minnesota Quality Award assessment team.
Training Representative for NSP on feasibility of becoming an Operating Company with Point Beach & Kewaunee summer of 1994.
Assisted Corporate Training Dept. in the f
development of an apprenticeship training program for a new Multi Skilled Plant Mechanic. Team Leader for NSP Generation Training Process Improvement team 1995/6 T-6 Team.
Completed 4 successful t--
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INPO accreditation. renewal visits for all Technical and Operations training programs.
Maintained SALP 1 in plant support for 2 SALP periods, July 1985 to April 1991 - Administrator of Emergency Preparedness:
Coordinate and administer Emergency Planning for both-NSP nuclear plants.
Coordinate offsite planning with Minnesota and Wisconsin's Health Department and Division of Emergency Services, as well as various Wisconsin and Minnesota counties. Assist all agencies in ridentifying resources and staffing needs. Manated budget of 1.5 Million dollars, Supervised 4 personnel.
Established an-Emergency Preparedness (EP) resource sharing network for NRC Region 3
, Utilities. Maintained SALP 1 in EP for.4 SALP periods. Wrote emergency
- plans, procedures and training for both NSP's Nuclear Facilities and assisted in writing State and County Emergency plans, procedures and training.
July 1881 to 1984 - Simulator / Operations Training Instructor:
Monticello Nuclear Generating Plant. Taught SRO classes, annual License Requalification, developing Licensing and Retraining' programs, lesson plan development, writing, administering and grading RO/SRO exams;, additionally managed the Acceptance Testing program for the Monticello simulator, wrote and reviewed all Operations and Simulator curriculum.
On-going project of INPO accreditation for all Operations training. Assisted in the development of the fuel shipping plan and provided three weeks fuel shipment training and public relations work in-Wisconsin.
Performed SRO and RO audit exams for various BWR and PWR Nuc Gen Stations-across the US from 1982 to 1992.
Experience I
March 1981 to July 1982 - Training Engineer Westinghouse Electric Corporation. I Taught NSSS systems and power conversion systems within the classroom. Additionally, I provided in-plant tours at the Zion Nuclear Power Plant. My tasks also involved providing training on the SNUPPS simulator.
I was also involved in writing lesson texts and lesson plans for all ECCS systems for Rochester Gas and Electric. An on-going objective was the writing and programming of lessons in Tutor language for computer assisted instruction.
November 1979 to March 1981 - Consultant employed by Westinghouse:
Responsibilities included curriculum development in the area of Heat Transfer and Thermodynamics.
I wrote the first Heat Transfer Fluid flow & thermodynamics book for Westinghouse, post TMI.
Additional responsibilities included nuclear fundamentals training for National and International
b students. 'Jul additional task was writing of ' marketing brochures for newly.
-developed. instructional' programs.
September'1970 to March 1981.- Active duty US Navy:
Highest rank ~ attained while on active duty was E-7 Chief Petty Officer.
In charge of Operations'and' Mechanical Maintenance for various nuclear and fossil fueled ships. Qualified all the senior.
operations watches on every ship I served.on. Additional duties and responsibilities included training officer assigned'to the apprentice training division, recruit training command,. Great Lakes,.
Illinois. 'I was' responsible for developing, administering and managing.
educational systems for the Fireman, Airman and Seaman programs. Additional responsibilities-
- included acting as a technical advisor for the Instructional Program Development Center,' Great Lakes,. Illinois.
psi fossil fueled boilers.
I^also' wrote power transfer courses for 600 & 1200 TRAINING The Seven Habits of Highly Effective People, 1998 Performance Improvement International, Reducing Human Error, 1998 Human Performance Improvement Techniques for Managers August - 1997 Improving Your Management Effectiveness - July 1997 Evaluating Training Programs - July 1997 Minn. Management Academy, Executive Development Center UofM - November 1995.
' Human Performance Evaluation System - November 1994 Error Reduction Techniques - November 1993' Celebrate Diversity February 1993 Managing and Motivating Employees - November 1991 Leadership Development, NSP Course - February 1991 Join the Management Team, NSP Course - January 1990-Affirmative Action - January 1991 Ethics,,NSP Course - November 1988 Project Management, University of Minnesota - December 1987
-Managing for Productivity, NSP Course - September 1986 How to deal with the Media - June 1986 Information Management System - February 1985 Emergency Planning, Harvard University - June 1985 BWR SRO License, February 10, 1984, License # SOP-30323 SRO BWR Hot License Certification, Morris Simulator - November 1982 SRO/RO Retraining, Morris Simulator - December 1982
-SRO/RO PWR Certification - March 1981 SNUPPS & Zion Simulator Training, Westinghouse - August 1981 Systems Training, Westinghouse - July 1981 Instructor Training, Westinghouse, (Instructor Certified) - March 1981 Fundamentals Training, Westinghouse - January 1980 Company Commanders School, US Navy - September 1978 Class C School, Instructor Duty School - August 1978 Engineman Basics - December 1974 Class'C School, Air Conditioning & Refrigeration School - Nov. 1973 Engineering Laboratory Technician School - November 1972
SIC Nuclear Submarine Prototype.- August 1972 US Naval Nuclear Power School - February 1972 Class A School, Machinist Mate.- April 1971 Basic Propulsion Engineering School - February 1971
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1 EXHIBIT 2 l
l Private Fuel Storage, uC P.O. Box C4010, La Crosse, #7 34602 4010 John D. Parkyn, Chairrnan of the Board May 19,1998 Director Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555 RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION PRIVATE FUEL STORAGE FACILITY DOCKET NO. 72-22 / TAC NO. L22462 PRIVATE FUEL STORAGE L.L.C.
References:
- 1) NRC Letter, Delligatti to Parkyn, Request for Additional Information, dated April 1,1998
- 2) PFSLLC Letter, Parkyn to Director, Office ofMaterial Safety and Safeguards, Response to Request for AdditionalInformation, dated April 29,1998 Please find enclosed Private Fuel Storage responses (original plus 15 copies) to the NRC Request for Additional Information (Ref.1). A response is provided for each RAI, but as noted in my April 29,1998 letter (Ref. 2), certain RAIs require supplementalinformation in accordance with the included schedule.
Some RAI responses contain proprietary information as noted and will be submitted under l
separate cover with the required affidavit in accordance with 10 CFR 2.790.
If you have any questions regarding this response, please contact me at 608-787-1236 or our Project Director, John Donnell, at 303-741-7009.
Sincerely yours,
' { $'
\\
ohn D. Parkyn, Chairman Private Fuel Storage, LLC JDP:cis Enclosures cc:
Mr. Leon Bear Ms. Denise Chancellor Mr. Mark Delligatti Mr. Jay Silberg
CHAPTER 9-CONDUCT OF OPERATIONS Section 9.3 Training and Certification of Personnel 9-10 (a)
Per the requirements of 10 CFR 72.190, describe the operator requirements for the equipment and controls that have been identified as important to safety.
(b)
Per the requirements of 10 CFR 72.192, provide information on the training program to show a systematic approach to training, proficiency testing, and certification of personnel.
(c)
Per the requirements of 10 CFR 72.194, provide information on the program for the certification of the physical conditiori and the general health of personnel who will operate equipment and controls that are important to safety.
RESPONSE
(a) For equipment and controls that have been identified as important to safety, a designated check-off list of the required training will be prepared along with the operating procedures. Personnel operating or supervising the operation of equipment or controls important to safety will be certified in such operation. The method of certification will be by an approved training and requalification program maintained by the facility. The prerequisites for procedures effecting equipment and coi/uvis important to safety will state specifically that the person performing the procedure must hold the applicable certification.
(b) The training program wLl be developed using a job and task analysis to define the various functions wnich must be performed by different staff members.
Each prescribed task will be covered in a training module which will be presented by a person who is qualified to perform the procedure or to train persons on the procedure. The person performing the training will follow a defined curricula which will outline the steps that are required to perform the task. The procedures to be used in performing the task will be used as a basis of the training curricula, so that persons being trained to perform a task (particularly those which are important to safety) will be trained in the precise manner and steps used in performing the task. At the conclusion of task training, proficiency testing will be administered to ensure that proper understanding has been achieved by the person being trained. A test will be prepared and graded by the instructor and will be retained in the facility records for a two year period.
The certificetion of personnel in functional areas such as fuel handling will be documented in a personnel training file, which will include an outline of the tasks PFSF SAR RAI No.1, Question 9-10 Page1of2
they are authorized to perform, the date training was provided, the person providing the training, and a certification indicating that a suitable proficiency test was passed. Retraining and refresher training will be provided at intervals that are apr.ropriate to the specific task. Retraining will involve a review of the basic tasks plus special attention to those items within the task which have undergone change. When new equipment is added or modifications in existing equipment of a significant nature are made, procedures will be modified and retraining on the revised procedure and equipment by a qualified instructor will be provided to those persons already certified prior to operation of that equipment.
(c) The program to ensure the certification of the physical condition and general health of personnel who will operate equipment controls important to safety will require all staff members designated as operators of equipment or controls important to safety to have a physical examination by a licensed physician every two years in accordance with NRC Form 396. Observation of continued fitness-for-duty will be controlled by procedures and training of staff personnel. These procedures and training will include the infonistien necessary to ensure that staff reporting for the performance of work which involves the operation of equipment or controls identified as important for safety are capable of performing such duties without impairment. The procedures and training will include the authonty for any trained staff member to deny the right of a person to operate equipment or controls important to safety should they fail to meet the standards of fitness-for-duty, Permanent conditions of staff members that could cause impaired judgment or motor coordination will be considered for accommodation by the physician performing the physical examination using NRC Form 396. Temporary conditions causing impaired judgment or motor coordination will be considered in the procedures as a possible cause for restricted performance of these duties if, in the opinion of trained personnel, further evaluation by a physician is required.
i PFSF SAR RAI No.1, Question 9-10 Page 2 of 2
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EXHIBIT 3 4
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF BALTIMORE GAS & ELECTRIC COMPANY CALVERT CLIFFS INDEPENDENT SPENT FUEL STORAGE INSTALLATION LICENSE APPLICATION
)
UNDER 10 CFR PART 72
]
-~r CHAPTER 7 ISFSI OPERATOR TRAINING As' discussed in Section 9.3 of the Calvert Cliffs ISFSI Safety Analysis Report, all personnel working at the Calvert Cliffs ISFSI will receive training and indoctrination geared toward providing and maintaining a well-qualified work force for. safe and efficient operation of the ISFSI. ' The existing Calvert Cliffs training program will. be used to provide this training and
(
indoctrination. Additional sections to this program will be added as described
)
below to include information specific to the. ISFSI. The Calvert Cliffs training program will therefore be directly applicable to the Calvert Cliffs ISFSI and is incorporated into this ISFSI training program via reference.
Sections will be added to the Calvert Cliffs training program to include the following subjects:
General Systems Overview (including nuclear engineering principles)
Technical Specifications and Procedures Applicable Regulations and Standards
'NUHOMS Loading and Retrieval Operations HSM Monitoring Equipment Training Transfer Cask Operation and Maintenance Transfer Trailer Operation and Maintenance
)
Hydraulic Ram Operation and Maintenance 4
Lifting Yoke Operation and Maintenance Vacuum Drying System Operation and Maintenance Optical Alignment Following completion of the training program, ISFSI supervisors, operators and workers in ISFSI-related activities will be given a written and practical exam to ensure they. understand the important aspects of the information described above.
Documentation of training activities and certifications of proficiency will be retained by the Nuclear Training Section at Calvert Cliffs.
Retraining will be consistent with retraining requirements in effect at the Calvert Cliffs Nuclear Power Plant for personnel involved in fuel handling operations.
7.1
M ANU AL NO. O_ __YP.bE CON h00.ED
'JAN 151993 v.
0 INDE3ENDENT S3ENT FUEL "i
STORAGE l\\lSTALLATION (ISFSI)
THIS MANUAL IS DISTRIBUTED
' r' BY THE NUCLEAR ENERGY DIVISION DOCUMENT SERVICES UNIT ASSIGNED TO 4
- n f,$Ilgika a E%:JR"!c %,
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CALVERT CLIFFS ISFSI SAFETY ANALYSIS REPORT
{
g,3 TRAINING PROGRAM L-
- e All personnel working at the Calvert Cliffs ISFSI receive training and indoctrination geared toward providing and maintaining a well-qualified work force for safe and efficient operation of the ISFSI.
The existing Calvert l
Cliffs trm:ning program, as described in Section 12.2 of the CCNPP UFSAR
{
(Reference 9.1), is used to provide this training and indoctrination.
i Additional stctions have been added to this program to include infomation specific to the ISFSI.
g.3.1 PROGRAM DESCRIPTION g.3.1.1 Trainino for ISFSI Operations Persorft1 l Generalized training is provided to Operations personnel in the applicable regulations and standards and in the nuclear engineering principles of cooling, radiological shielding, and structural characteristics of the 4
DSC/HSM.
Detailed operator training is provided for DSC preparation and handling, fuel l loading, transfer cask preparation and handling, and transfer trailer lo 9.3.1.2 Trainino for Maintenance Personnel l Generalized training is provided to Maintenance personnel on the applicable regulations and standards and on the nuclear engineering principles of "w
cooling, radiological shielding, and structural characteristics of the DSC/HSM.
l Specific training is provided for use of the automated seal welding equipment for the top end shield plug and top cover plate; operation of the transfer trailer; alignment of the cask skid with the HSM; alignment of the hydraulic ram assembly; and nomal and off-normal operation of the hydraulic ram.
,l Specific training is also provided for cleaning of the HSM air inlets and outlets.
9.3.1.3 Trainino for Health Physics Personnel l Generalized training is provided to Health Physics personnel on the applicable regulations and standards and on the nuclear engineering principles of cooling, radiological shielding, and structural characteristics of the DSC/HSM.
i l Specific training is provided in radiological shielding design of the system, particularly the top end shield plug. DSC/ transfer cask and the DSC/HSM.
9.3.1.4 Trainino for Security Personnel Details of the training program for security personnel are provided in the l Security Plan which is withheld from public disclosure in accordance with 10 CFR 2.790(d) and 10 CFR 73.21.
9.3-1 Rev. 2
CALVERT CLIFFS ISFSI SAFETY ANALYSIS REPORT g,3.2 RETRAINING PROGRAM Retraining is consistent with retraining requirements in effect at Calvert Cliffs Nuclear Power Plant for personnel involved in fuel handling operations.
9.3.3 ADMINISTRATION AND RECORDS The organization responsible for training programs and for maintaining
' up-to-date records on the status of personnel training is the existing Nuclear
)
Training Section at Calvert Cliffs.
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EXHIBIT 4 I
X or: 1ern S:a"es 3ower Comaany 3rairie s.anc.
Nuc. ear Genera:ing
? an':
L ni:s anc. 2
_icense A3'a.ica: ion
- or an
.ncecencen: S, en: :ue a
S:orage.ns:a a: ion 38A "288?! 848%
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION 1
IN THE MATTER OF NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR GENERATING PIANT, UNITS 1 AND 2 INDEPENDENT SPENT FUEL STORAGE INSTALLATION LICENSE APPLICATION UNDER 10 CFR PART 72 4
I CHAPTER 7 I
OPERATOR TRAINING The existing Prairie Island Nuclear Generating Plant training program will be modified to incorporate the training needed for operation of the
This program provides a systematic approach to training as described in the Prairie Island Nuclear Generating Plant USAR, Section 9.1.
The ISTSI training program will include training for operational, maintenance, radiation protection, and security personnel.
Section 9.3 of the SAR describes the training program for ISFSI.
i i
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ISTSI SAR 9.3 TRAINING PROGRAM The training program has the objective of providing and maintaining a well qualified work force for safe and efficient operation of the ISTSI.
The existing Prairie Island Nuclear Generating Plant training program will be used to provide this training and indoctrination. Additional sections to this program will be added as needed to include information pertinent to the ISFSI.
Training courses will be prepared by training center personnel in cooperation with engineering personnel qualified in the particular topical or functional area.
All personnel working in the fuel storage area will receive radiation and safety training and those actually performing cask and fuel handling functions will be given additional training in specific areas as required by the Radiation Protection program in effect at the Prairie Island Nuclear Generating Plant.
The retraining schedule will be consistent with retraining requirements in effect for personnel involved in fuel handling operations.
Training records will be maintained for 5 years.
Such records will include dates and hours of training and other documentation on training subjects, I
information on physical requirements, job performance statements, copies of written examinations, information pertaining to walk-through examinations, and rotesting particulars.
a 01026).wpf 9.3-1 REV. 0 8/90
F l
I EXHIBIT A-EXCERPTS FROM SER FOR CALVERT CLIFFS ISFSI I
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SAFETY EVALUATION REPORT FOR THE BALTIMORE GAS AND ELECTRIC COMPANY'S SAFETY ANALYSIS REPORT FOR AN INDEPENDENT SPENT FUEL STORAGE INSTALLATION AT CALVERT CLIFFS November 1992
t i
3.3 Training and Certification The SER is concerned with training and certification of personnel for operation of. equipment and controls that have been identified as important to safety, and direct supervisory personnel for such operation. The license applicant must establish a program of training, proficiency testing and certification of such personnel which must be submitted with the license application for approval (10 CFR 72.192).
The proposed training program is described in Section 9.3 of the SAR and the FSAR (Reference 14). The nature of the ISFSI is such that the proposed training, which is essentially an extension of the current Calvert Cliffs training and qualification program, is considered to be satisfactory. The existing BG&E employee personnel qualification requirements are considered to be appropriate for the " certification" of personnel.
General training is to be provided to operations, maintenance, and health physics personnel on the applicable regulations and standards, and in the engineering principles of cooling, radiological shielding, and structural characteristics of the DSC and HSM. BG&E plans to provida detailed training to its operators in the areas of the DSC preparation and handling; fuel loading; transfer cask preparation and handling; and transfer trailer loading.
The maintenance personnel will receive detailed training in the operation of the automatic welder for the DSC top end shield plug, the operation of the
' ransfer trailer, alignment of the cask skid with the HSM, and alignment and t
normal and off-normal operation of the hydraulic ran assembly.
Specific training is to be provided on cleaning of the HSM air inlets and outlets. The health physics personnel will receive training in the radiological shielding design, especially of the various ISFSI system shields.
The NRC staff finds that the existing training and certification program, supplemented to include the planned specific ISFSI training, meets the ISFSI training and certification requirements (10 CFR Part 72, Subpart I).
3-8
EXHIBIT B-EXCERPTS FROM SER FOR PRAIRIE ISLAND ISFSI
i:
SAFETY EVALUATION REPORT FOR THE PRAIRIE ISLASV INDEPENDENT SPENT FUEL STORAGE INSTALLATION U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards July,1993 i
l
~ Enclosure 2 )
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8 OPERATING PROCEDURES 8.1 Area of Review Operating procedures for the TN 40 cask are described in Chapter 5 and Section 7.1 of the TSSAR. This SER review is limited to the procedures as presented by NSP in this TSSAR.
8.2 -
Acceptance Criteria 10 CFR 72.24(h) requires the applicant to submit "...a plan for the conduct of operations including the planned managerial and controls system, and the applicant's organization, and program for training of personnel...." Although this provision applies pnmanly to the ISFSt.
the operations involved in loading, transporting, and storing of the spent fuel are closely associated with the design of the cask, to the extent that design features are incorporated to facilitate the conduct of these operations. Spent fuel loading and cask handling procedures in the auxiliary building are governed by the 10 CFR Part 50 license. Consequently, the review of the operating procedures is limited to the specific operations of handling the cask from the time it leaves the auxiliary building until it is placed on the storage pad. Managerial and administrative controls would only be relevant if the cask design were such that only administrative controls could ensure that the spent fuel could be safely handled and stored under.
- conditions that would not pose a hazard to operating personnel or the public.
10 CFR Part 20 covers the standards, for protection against radiation, that must be met duriag the operation of an ISFSI.
Regulatory Guides 8.8 and 8.10 (References 19 and 20) provide guidance to ensure that occupational radiation exposures will be "as low as is reasonably achievable" (ALARA).
8.3 Review 1
TSSAR Section 5.1.1 provides a general description of the operational procedures for loading the cask and preparing it for storage. More detailed procedures describing the receipt and loading of the TN-40 cask at the ISFSI are described in flowsheet form in Fig. 5.1-1.
Inspections and tests are described as part of the preparation for loading.
TSSAR Section 7.1 describes the general procedures to be followed to meet the requirements of 10 CFR Part 20, Regulatory Guide 8.8, and Regulatory Guide 8.10. These general procedures for radiation protection and meeting ALARA criteria for occupational exposure apply to the cask loading procedure.
NSD has an NRC approved physical protection program for the Prairie Island Nuclear Generating Plant. It has also developed an amendment to this program, to accommodate the j
needs of the ISFSI. The NRC staff reviewed and approved this amendment, concluding that the i
physical protection requirements for the ISFSI (10 CFR Part 72, Subpart H) will be met with j
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the incorporation of the amendment into the site physical protection plan.
NSP currently has a training program that has been approved, by NRC staff, for reactor operations. Additional sections will be added to this program, as needed, to include information pertinent to the ISFSI. All persor.nel performing cask and fuel handling functions will be given additional training in specific areas, as required by the radiation protection program in effect at Prairie Island. The NSP ISFSI training should address the following:
- a. TN-40 cask design;
- b. ISFSI Desiga-
- c. ISFSI Safety Analysis;
)
d, ISFSI Technical Specifications; and
- e. ISFSI Normal and Off-normal Procedures.
The NRC staff finds that the existing training program, when modified to include the ISFSI, will comply with the requirements of 10 CFR Pan 72, Subpart I.
The TN-40 Cask TSSAR addresses the cask receipt, loading, and some onsite transportation procedures at the ISFSI. Procedures for unloading the cask are not covered in the TSSAR, even though this operating procedure is inseparable from decommissioning. This review only covers the inspections, tests, and special preparations of the cask for loading spent fuel. Section 5.1.l' of the TSSAR addresses the loading procedures, whereas Section 7.1 of the TSSAR addresses the issue of ensuring that the occupational radiation doses are ALARA.
Detailed procedures for loading, draining and drying the cask, creating an inert environment for the spent fuel, ensuring the effectiveness of the seals at the bolted closure joints, transporting the loaded cask to the storage pad, and ensuring that occupational radiation exposures are maintained ALARA should be developed before NSP loads fuel into the first cask. This has been made a license condition.
8'4 Findings and Conclusions The operational procedures for loading the TN-40 cask are in compliance with the appropriate guidance and/or regulations. These procedures must be incorporated into the operational procedures for the reactor. The written procedures for onsite transportation, unloading, and preoperational testing must be added to the operational procedures for the ISFSI.
8-2
EXCERPTS FROM DEPOSITION OF MARVIN RESNIKOFF 1
I s
C,..
s.
1 1
IN THE UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 5
--- - -- - - - -- - - - - - -x 6
In Matter of:
- Docket No. 72-22 7
PRIVATE FUEL STORAGE, L.L.C ASLBP No.
8 (Private Fuel Storage Facility) 97-732-02-ISFI 9
-- - - - -- - -------- ' -x 10 11 Washington, D'.C.
12 Wednesday, May 19, 1999 13 14 Deposition of MARVIN RESNIKOFF, was called 15 for examination by counsel, commenced pursuant to 16 notice, at 10:10 a.m.,
at the offices of Shaw, 17 Pittman, Potts & Trowbridge, 2300 N Street, NW, 18 Washington, D.C.,
before Karen K. Brynteson, 19
. Registered Professional Reporter and Notary Public.
20 21 22 ANN RILEY & ASSOCIATES, LTD.
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l' PROCEEDINGS 2
Whereupon,
)
3 MARVIN RESNIKOFF 4
a witness, was called for examination and, having 5
been first duly sworn, was examined and testified as 6
follows:
7 EXAMINATION 8
BY MR. BLAKE:
9 Q
Dr. Resnikoff, my-name is Ernie Blake, and 10 I represent the Applicant in this proceeding, PFS.
11 Can you state your full name, please.
I 12 A
Marvin Resnikoff.
That's spelled 13 R-e-s-n-i-k-o-f-f, 14 Q
And can you tell me where you are employed 15 now?
16 A
Yes, Radioactive Waste Management 17 Associates, i
18 Q
I have a document that's dated the 21st of l
19
. April, a declaration with an attached resume, et 20 cetera, that I suspect you provided to your counsel 21 and, in turn, your counsel provided for the 12 2 proceeding, but if you would take a look at that, we i
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1 BY MR. BLAKE:
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2 Q
Let me turn to.F&P now.
3 MS. CURRAN:
Just a second.
Do you need a
.4 break, Marvin?
5 THE WITNESS:
No,.I am'okay.
6 BY MR. BLAKE:
7 Q
Let me start by asking a little bit more 1
8 about your background in the training area.
When we 9
went over the earlier resume and materials, I don't I
10.
think there were any references at all to training.
11 What exactly is your background in the 12 training regimen?
13 A
Well, I graduated a long time ago from the 14 University of Michigan.
15 Q
We are not going to talk about that kind 16 of thing.
17 A
But since 1975, actually since 1974 I have 18 worked on radioactive waste issues.
In '75 I worked i
19 on transportation issues for the state attorney 20 general, New York State attorney general, so that's 21 when I started working on transportation issues.
22 And of the three kind of issues that we i
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work on at WMA, one involves dose reconstruction, i
2 many have involved court cases or personal injury 3
cases where a person has cancer and we estimate the 4
exposures that a person received and whether it is 5
likely those exposures caused cancer.
That's one 6
type of case that I have worked on for the past ten 7
years.
8 And another involves low level waste 9
landfills, siting low level waste landfills and also 10 remediation of leaking low level waste landfills.
11 And the third issue involves, since
'75, 12 transportation issues where I have looked at 13 accident probabilities and consequences.
14 And increasingly in the last few years I
)
15 have worked on dry storage issues, Prairie Island, 16 Point Beach, Palisades.
17 Q
Oyster Creek?
I didn't really look at 18 A
I wouldn't 19 Oyster Creek extensively.
I have looked at some of 20 these issues as it concerns the Yankee-Rowe reactor.
21 Do you want me to focus then on F&P?
22 That's my general background.
And my general ANN RILEY & ASSOCIATES, LTD.
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background is training in physics.
And then over 2
the past 25 years I have examined numerous j
3 publications, thousands, I have read thousands of 4
publications and reports by the NRC and contractors 5
and performed calculations.
I don't know, but I
6 that's my general background, if that's helpful.
7 Q
The subject area of F&P are the adequacy 8
of the licensee's training programs.
And where I 9
don't see any background in your explicit resume and 10 in your expanded background which you have just 11 given us with regard to training in particular or 12 training at nuclear power plants or training more 13 particularly at dry storage facilities, I wanted to 14 know what your exposure, what your background, what 15 your knowledge is in this particular subject area, 16 the training of employees at these facilities.
17 A
Okay.
First of all, with regard to the 18 work on the contentions that were filed on F&P, 19 these were done jointly, myself and with Larry White 20 and an associate of Larry White named Ed Benz, who 21 particularly worked on training and quality 22 assurance.
So this was a joint effort among all of ANN RILEY & ASSOCIATES, LTD.
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us.
2 My primary role was to compare the 3
regulations with the application in that respect.
I 4
haven't had, other than reviewing reports and 5
training documents, I haven't directly been involved 6
in training workers or been involved in those 7
courses, other than reviewing their texts.
I 8
haven't actually, you know, been involved in the 9
training of those workers.
10 Q
What kind of -- I am sorry, i
11 A
The only other aspect'that I wanted to 12 mention is direct, in terms of direct experience, is 13 I toured these facilities.
I have toured dry 14 storage facilities and reactors and storage pools.
15 That's the extent of my background.
16 MS. CURRAN:
Is that the end of your 17 answer?
18 THE WITNESS:
Yes 19 MS. CURRAN:
Could I just have a minute, 20 please?
21 MR. BLAKE:
Yes.
22 (Counsel confers with the witness.)
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BY MR. BLAKE:
'2' O.
Now that you have been to.the woodshed 3
again,~what do you have to add?.
4 A
Well,. counsel has berated me for selling 5
myself short.
I just want to underline'that in 6
reviewing training manuals;and reviewing.the
,7 regulations and reviewing what the company has done, 8
I am familiar with the kind of training required, 9
and the company has not filed the kind of documents 10 that are required.
11 Q
Have you had occasion'in any other docket 12.
regarding any other plant to review the adequacy of 13 applicant's submittals to the NRC with regard to 14 training?
15 A
Well, a long time ago with regard to the 16 West Val, the West Valley plant.
No, in this
'17 particular case the answer is no.
18 Q
Okay.
19 A
But the answer is "no but."
And the but 20 is in this particular case it is our intention to 21 actually review training manuals and training at 22 reactor sites to compare it with what the company ANN RILEY & ASSOCIATES, LTD.
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has provided.
That's how we intend to pursue this 2
particular contention.
3 Q
'And do you intend to do that yourself?
4 A
We haven't decided whether I am going to 5
do it or whether we are going to bring in another 6
person, such as Ed Benz, who helped to write the 7
original contentions.
8 Q
You may not be aware, Mr. Resnikoff, but 9
we asked specifically earlier the State whether or 10 not Benz would be involved as an expert and were 11 told no.
12 A
And what?
13 Q
And we were told no.
14 MS. CURRAN:
Let me just note for, le 15 record that you are asking Dr. Resnikoff questions 16 about decisions the State is going to make and that 17 18 MR. BLAKE:
That's why I informed him 19
.about this, because I thought he might not know it.
20 MS. CURRAN:
Yeah.
21 THE WITNESS:
They can change their mind.
22 No?
I am not a lawyer.
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BY MR.-BLAKE:
2 Q
That's a fair observation on both parts, 3
_one that they can and, two, that you are not a 4
lawyer.
5 If'you have not looked at any others, what
)
6 standard do you use for determining whether or not I
7 the applicant has complied with the staff 8
requirements in training?
9 A
I think I mentioned what I did to file the 10 contention.
I reviewed the regulations and I 11 reviewed what the company has filed.
More recently 12 I looked at the Department of Transportation 13 requirements for locomotive engineers just to get an 14 understanding of how another agency, looking at the 15 requirements of another agency.
And I think some of 16 this was inserted in our response to your motion, 17 was it?
That's right, the answers to 18 interrogatories.
19 Q
And what applicability do you think those 20 have to your contention which is that we haven't 21 complied with a portion of part 72?
22 A
It is just to understand the kind of ANN RILEY & ASSOCIATES, LTD.
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. training and certification required by other 2
agencies, the depth and to compare it with what PFS 3
had filed, which in my view was minimal.
4 Q
Was the Department of. Transportation 5
material that you were looking at a description of 6
what needed to be filed in an application or how to 7
fully' develop a training program?
8 A
A training program.
And also 9
certification of personnel, and also when that 10 certification would be removed.
For instance, the 11 physical requirements of personnel.
12 Q
I have no more questions, thank you.
13 MR. TURK:
I have just a few questions on 14 this one.
15 EXAMINATION 16 BY MR. TURK:
17 Q
Are you aware of any staff guidance which 18 indicates to an applicant for ISFSI what is required 19 to be in the application with regard to training and 20 certification?
21 A
I didn't review any staff guidance.
22 Q
Are you aware of any?
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A I wasn't aware of any with regard to any 2
dry storage f acility.
Does such a document exist?
3 I know you are supposed to ask the questions.
4 Q
That's correct.
Have you ever reviewed 5
the adequacy of a training or certification program 6
for any other type of facility?
7 A
I have reviewed training programs, the 8
manuals, not specifically for this type of facility.
9 I didn't know if any existed.
10 Q
What training manuals have you reviewed, 11 for which facilities?
12 A
I think that I gave a list of some that we l
13 had, I think, in the office.
I don't have the 4
14 response to what we submitted.
15 MS. CURRAN:
What is it you are looking
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16 for?
The answer to the interrogatory?
17 THE WITNESS:
Yes.
18 MS. CURRAN:
Yeah, here.
Here is the 19
.first one.
20 THE WITNESS:
I listed this Appendix B, 21 transportation of hazardous materials, state and 22 local activities prepared by the Office of i
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Technology Assessment, and that has a list of 2
training programs.
3 BY MR. TURK:
4 Q
What are you looking at now?
5 A
I am looking at State of Utah's response 6
and objections to applicant's first set of formal 7
discovery requests.
4 8
Q That's the one dated April 14th, 1999?
9 A
Yes.
10 Q
Which page are you looking at there?
~
11 A
12.
12 Q
My question to you --
13 A
Then on page 13.
14 Q
My question to you didn't ask you about 15 that.
I asked you if you reviewed the training 16 programs for any facilities, not limited to ISFSI's.
~
17 And you are now referring, as I understand it, to 18 something prepared by the Department of 19 Transportation or is it -- I guess it is the 20 Department of Energy.
21 A
Yes.
But these relate -- yes, that's 22 right.
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Q But my question to you is which 2
facilities' training programs have you. reviewed?
3 A
Specific facilities?
4 Q-Yes.
5 A
For specific facilities, I looked at West 6
Valley many years ago.
7 Q
Was that back in approximately the 1972 8
time frame?
9 A
'75 time frame and I mentioned earlier 10 that it was our intention to review submittals for i
11 reactor sites.
12 Q
In the future?
13 A
In the future.
14 Q
And West Valley training manual, was it 15 the training manual you looked at?
l 16 A
Yes, the entire application.
17 Q
Including the training manual?
18 A
Yes.
19 Q
Was there some reason in particular that l
20 you looked at the training manual for West Valley?
l 21 A
I looked at all aspects of the facility I
I 22 and proposed application.
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Q And what was the paper filed?
2 A
These were affidavits that were filed in 3
that case on behalf of the intervenors.
4 MS. CURRAN:
If you should want any of 5
that material, I am sure I could get it for you.
6 MR. TURK:
That's all right.
If it is 7
files in a proceeding, I am sure we have access to i
8 it.
9 MS. CURRAN:
I could tell you where to 10 look in general.
I am representing the intervenor.
11 MR. TURK:
That's all I have.
Thank you.
~
12 EXAMINATION 1
13 BY MS. CURRAN:
14 Q
Dr. Resnikoff, are you generally familiar J
15 with the NRC safety requirements for transportation 16 and storage of spent nuclear fuel?
17 A
Yes.
18 Q
So is it fair to say that you are familiar 19
.with the kinds of activities that need to be 20 performed in transporting and storing spent nuclear 21 fuel?
22 A
Yes, yes, particularly in one case, ANN RILEY & ASSOCIATES, LTD.
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1 Prairie Island, we examined in great detail the 2
methodology for loading and unloading storage casks, i
3 what workers had to do at each particular stage.
4 Q
So is it fair to say that you are familiar 5
with the specific steps'that need to be taken in the 6
course of'a day or a week or a year at a spent fuel 7
storage facility by the employees there?
8 A
Yes.
9 MS. CURRAN:
That's all the questions I 10 have.
Now I really need a break.
11 MR. BLAKE:
That's fine.
Let's take a 12 break.
13 (Recess.)
14 EXAMINATION 15 BY MR. GAUKLER:
16 Q
Dr. Resnikoff, my name is Paul Gaukler.
I
_17 am going to be asking you some questions next.
I 18 thought we would first focus on Utah B, which 19
. concerns the intermodal transfer point.
20 What did you do, if anything, to 21 specifically prepare with respect to Utah B today?
22 A
Oh, I reviewed the petition to intervene, ANN RILEY & ASSOCIATES, LTD.
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