ML22340A675
| ML22340A675 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/06/2023 |
| From: | Samson Lee NRC/NRR/DORL/LPL4 |
| To: | Gerfen P Pacific Gas & Electric Co |
| References | |
| EPID L-2022-LLL-0003 | |
| Download: ML22340A675 (1) | |
Text
March 6, 2023 Ms. Paula Gerfen Senior Vice President, Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 56, Mail Code 104/6 Avila Beach, CA 93424
SUBJECT:
DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 - APPROVAL OF CERTIFIED FUEL HANDLER TRAINING AND RETRAINING PROGRAM (EPID L-2022-LLL-0003)
Dear Ms. Gerfen:
By letter dated November 27, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18331A553), Pacific Gas and Electric Company (PG&E, the licensee) notified the U.S. Nuclear Regulatory Commission (NRC) that it would permanently cease power operations at Diablo Canyon Nuclear Power Plant (Diablo Canyon), Units 1 and 2, upon expiration of the facility operating licenses (FOLs). The FOL for Diablo Canyon, Unit 1, expires on November 2, 2024, and the FOL for Diablo Canyon, Unit 2, expires on August 26, 2025. However, the NRC staff notes that the actual license expiration dates are uncertain at this time because, by letter dated October 31, 2022, the licensee indicated that it is seeking to renew the Diablo Canyon licenses (ML22304A691).
By letter dated February 23, 2022 (ML22054A318), PG&E submitted its Certified Fuel Handler (CFH) Training and Retraining Program for Diablo Canyon, Units 1 and 2, to the NRC for approval.
After certifications of permanent cessation of power operations and permanent removal of fuel from the reactor vessels for Diablo Canyon, Units 1 and 2, are submitted in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 licenses will no longer authorize operation of the reactors or emplacement or retention of fuel in the reactor vessels. As a result, licensed reactor operators will no longer be required to support plant operating activities. Instead, approval of a CFH Training and Retraining Program is needed to facilitate activities associated with decommissioning and irradiated fuel handling and management.
The licensee requested NRC approval of the Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program to ensure that the monitoring, handling, storage, and cooling of irradiated fuel is performed in a safe manner. As defined in 10 CFR 50.2, the CFH is a non-licensed operator who has been qualified in accordance with a fuel handler training program approved by the NRC. Non-licensed personnel are trained in accordance with 10 CFR 50.120.
The NRC staff has reviewed the submittal and based on the enclosed safety evaluation, approves the Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program as requested.
If you have any questions, please contact me at 301-415-3168 or via email at Samson.Lee@nrc.gov.
Sincerely,
/RA/
Samson S. Lee, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323
Enclosure:
Safety Evaluation cc: Listserv
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION CERTIFIED FUEL HANDLER TRAINING AND RETRAINING PROGRAM PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323
1.0 INTRODUCTION
By letter dated November 27, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18331A553), Pacific Gas and Electric Company (PG&E, the licensee) notified the U.S. Nuclear Regulatory Commission (NRC, the Commission) that it would permanently cease power operations at Diablo Canyon Nuclear Power Plant (Diablo Canyon),
Units 1 and 2, upon expiration of the facility operating licenses (FOLs). The FOL for Diablo Canyon, Unit 1, expires on November 2, 2024, and the FOL for Diablo Canyon, Unit 2, expires on August 26, 2025. However, the NRC staff notes that the actual license expiration dates are uncertain at this time because, by letter dated October 31, 2022, the licensee indicated that it is seeking to renew the Diablo Canyon licenses (ML22304A691).
By letter dated February 23, 2022 (ML22054A318), PG&E submitted as an enclosure to the letter, its Certified Fuel Handler (CFH) Training and Retraining Program for Diablo Canyon, Units 1 and 2, to the NRC for approval.
After certifications of permanent cessation of operations and permanent removal of fuel from the reactor vessels for Diablo Canyon, Units 1 and 2, are submitted in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 licenses will no longer authorize operation of the reactors or emplacement or retention of fuel in the reactor vessels. As a result, licensed reactor operators will no longer be required to support plant operating activities. Instead, approval of a CFH Training and Retraining Program is needed to facilitate activities associated with decommissioning and irradiated fuel handling and management. In its 1996 final rule that, among other things, adopted the definition of CFH, the Commission acknowledged that permanently shutdown and defueled power reactors pose less risks compared to operating reactors (61 FR 39278; July 29, 1996).
The proposed CFH Training and Retraining Program is to be used to satisfy training requirements for the plant personnel responsible for supervising and directing the monitoring, storage, handling, and cooling of irradiated nuclear fuel in a manner consistent with ensuring the health and safety of the public. Section 50.2, Definitions, of 10 CFR requires that CFHs be qualified in accordance with an NRC-approved training program.
Section 1, Introduction, in the enclosure to PG&Es letter states:
The CFH Training and Retraining Program will become effective upon:
(1) approval of the CFH Training and Retraining Program by the NRC; and (2) implementation of the approved Permanently Defueled Technical Specifications License Amendment which eliminates the requirements for the NRC licensed Senior Reactor Operators and Reactor Operators, and the requirement for the associated 10 CFR 55 Training Program.
2.0 REGULATORY EVALUATION
2.1 Regulatory Requirements As stated in 10 CFR 50.2, Definitions, Certified fuel handler means, for a nuclear power reactor facility, a non-licensed operator who has qualified in accordance with a fuel handler training program approved by the Commission.
The regulations under 10 CFR 50.120, Training and qualification of nuclear power plant personnel, paragraph (b), Requirements, states, in part, that:
(2) The training program must be derived from a systems approach to training as defined in 10 CFR 55.4, and must provide for the training and qualification of the following categories of nuclear power plant personnel:
(i) Non-licensed operator.
(3) The training program must incorporate the instructional requirements necessary to provide qualified personnel to operate and maintain the facility in a safe manner in all modes of operation. The training program must be developed to be in compliance with the facility license, including all technical specifications and applicable regulations. The training program must be periodically evaluated and revised as appropriate to reflect industry experience as well as changes to the facility, procedures, regulations, and quality assurance requirements. The training program must be periodically reviewed by licensee management for effectiveness. Sufficient records must be maintained by the licensee to maintain program integrity and kept available for NRC inspection to verify the adequacy of the program.
As stated in 10 CFR 55.4, Definitions, Systems approach to training means a training program that includes the following five elements:
(1) Systematic analysis of the jobs to be performed.
(2) Learning objectives derived from the analysis which describe desired performance after training.
(3) Training design and implementation based on the learning objectives.
(4) Evaluation of trainee mastery of the objectives during training.
(5) Evaluation and revision of the training based on the performance of trained personnel in the job setting.
2.2 Regulatory Guidance Regulatory Guide 1.8, Qualification and Training of Personnel for Nuclear Power Plants, Revision 3, dated May 2000 (ML003706932).
NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 12 (ML21256A276), discusses job performance measures (JPMs) in operating examination.
NUREG-1220, Training Review Criteria and Procedures, Revision 1 (ML102571869),
discusses the systems approach to training (SAT) process.
3.0 TECHNICAL EVALUATION
The NRC staff reviewed the specific elements of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program against the regulatory requirements of 10 CFR 50.120, consistent with previous NRC staff reviews and approvals of decommissioning reactor CFH training programs, together with the elements of an SAT as defined in 10 CFR 55.4.
3.1 CFH Training Program Broad-Scope Objectives Based on the applicable regulatory requirements in section 2.1 of this safety evaluation, the NRC staff used the following three broad-scope objectives as criteria for an acceptable CFH Training and Retraining Program:
(1)
Safe conduct of decommissioning activities.
(2)
Safe handling and storage of spent fuel.
(3)
Appropriate response to plant emergencies.
The NRC staff reviewed the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program, as provided in the enclosure to PG&Es letter dated February 23, 2022.
The licensee states, in part, that the approval of a CFH Training and Retraining Program will ensure that the qualifications of personnel are commensurate with the tasks to be performed and the potential conditions requiring response.
Section 3, Initial Training Program, subsection 3.2, Fundamentals Training, of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program, states that the fundamentals training phase of the CFH Training and Retraining Program consists of lecture and/or self-study of several topics appropriate to the monitoring, handling, storage, and cooling of nuclear fuel. The selection of topics will be based on a job analysis for the CFH tasks and functions and will include, among others, thermodynamics, heat transfer and fluid mechanics, radiological safety principles and monitoring, facility/system design and function, and facility administrative and safety procedures, as appropriate for the current facility status.
Further, as described in section 3.3, On-the-Job Training (OJT), of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program, the OJT phase will include hands-on training of shift operations such as shift turnover, shift recordkeeping, removal and return of equipment to service, and specified watch standing activities. The OJT will also include training on the facility license, Emergency Plan, and the content, bases, and importance of the facilitys technical specifications. The NRC staff finds the inclusion of these topics in the initial training program to appropriately address the safe conduct of decommissioning activities, consistent with objective (1).
The proposed Diablo Canyon, Units 1 and 2, CFH initial training program also includes lectures and/or self-study of topics appropriate to the monitoring, handling, storage, and cooling of nuclear fuel, including topics on thermodynamics, heat transfer, fluid mechanics, electrical theory, and mechanical components operation. The OJT phase of the CFH Training and Retraining Program includes watch-standing activities, such as operation of systems/components used to provide handling, storage, cooling, and monitoring of fuel. The NRC staff finds the inclusion of this information to appropriately address the safe handling and storage of spent fuel, consistent with objective (2).
Further, the OJT phase of the proposed Diablo Canyon, Units 1 and 2, CFH initial training program includes training on normal, abnormal, and emergency procedures, accident analysis, and the facilitys emergency plan. The NRC staff finds the inclusion of this information adequately addresses the appropriate response to plant emergencies, consistent with objective (3).
Section 4, Retraining Program, of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states that the retraining program shall be administered in a biennial training cycle. This cycle will include annual operating examinations and biennial written examinations. This section also states that all CFHs will participate in the retraining program.
The CFH retraining phase will consist of lectures and/or self-study of topics appropriate to the monitoring, handling, storage, and cooling of nuclear fuel. The content of the retraining program will be based upon the tasks selected during program development for the retraining cycle.
Retraining will typically include a review of changes associated with the facility and procedures, as well as problem areas associated with the monitoring, handling, storage, and cooling of nuclear fuel, and selected topics from the initial training program. The NRC staff finds the inclusion of these topics in the retraining program to be consistent with the broad-scope objectives.
Based on the above, the NRC staff concludes that the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program addresses the safe conduct of decommissioning activities; safe handling and storage of spent fuel; and the appropriate response to plant emergencies.
3.2 CFH Training and Retraining Program Evaluation The NRC staff reviewed the specific elements of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program against the regulatory requirements of 10 CFR 50.120(b)(2) and (b)(3), consistent with previous NRC staff reviews and approvals of decommissioning reactor CFH training programs, and the results of this review are summarized below.
3.2.1 Use of an SAT Under 10 CFR 50.120(b)(2) [t]he training program must be derived from a systems approach to training as defined in 10 CFR 55.4[.] The licensee stated, in part, in section 3.2 of the proposed Diablo Canyon, Units 1 and 2 CFH Training and Retraining Program, that [t]he training plan will adhere to the guidelines of Revision 1 of NUREG-1220, Training Review Criteria and Procedures, that are applicable to a permanently defueled facility and be developed utilizing the SAT process.
Section 1, Introduction, of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states, in part, that:
The Certified Fuel Handler Training (CFH) and Retraining Training Program contained herein describes the training program to be implemented at the Diablo Canyon Power Plant to ensure the monitoring, handling, storage, and cooling of nuclear fuel is performed in a manner consistent with ensuring the public health and safety.
The program describes the personnel to whom the program applies, the areas in which training is provided, what constitutes certification, how certification is maintained, and required qualifications (e.g., medical).
The NRC staff reviewed the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program to ensure that it includes all five of the required elements of a SAT-based program. Section 3, Initial Training Program, of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states that the selection of topics for the fundamentals training phase of the program will be based on a job analysis for the CFH tasks and functions.
The job analysis will be conducted by an individual holding a Senior Reactor Operator (SRO) license. The procedure outlines a graded approach to evaluating job tasks and includes a Difficulty, Importance, and Frequency (DIF) rating for each new task. Training materials will be designed based on the learning objectives. The licensee states this DIF review will be performed by the Operations and Training personnel and management. The NRC staff finds the licensees plan to use these procedures to conduct a systematic analysis of jobs to be performed and to derive learning objectives from that analysis to be consistent with SAT elements 1 and 2.
Section 4, Retraining Program, of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states that all CFHs will participate in the retraining program. The content of the retraining program will be based upon the tasks selected during program development for the retraining cycle. A retraining plan will be developed and approved by the plant manager (or designee). The training plan will be developed utilizing the SAT process and will adhere to the guidelines of Revision 1 of NUREG-1220. The NRC staff finds this approach to be consistent with SAT elements 1 and 2.
Section 3.3 of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states that training materials will be designed based on the learning objectives. The NRC staff reviewed the licensees process to design and implement training based upon the learning objectives and finds it to be consistent with SAT element 3.
Section 3.4, Candidate Evaluation, of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states that a comprehensive final examination is to be administered at the end of the initial training program. The comprehensive examination will include a written and an operating examination. The written examination requires a minimum score of 80 percent to pass. The operating examination will consist of JPMs and passing criteria for each JPM is that the examinee successfully completes the assigned task in accordance with the governing procedures without missing any critical steps. The critical steps for each JPM will be pre-identified as defined in NUREG-1021, Revision 12 or later revision. The operating examination requires passing a minimum of 80 percent of the administered JPMs to pass. The licensee states that this examination will provide assurance of mastery of the skills, knowledge, and abilities required for successful performance of the CFH job and associated tasks.
Section 4.4.1, Examinations, of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states that participants in the CFH retraining program must pass a biennial written examination and an annual operating examination with a minimum score of 80 percent to maintain their qualification. The operating examination will consist of JPMs and each JPM will be scored on a pass/fail basis. The operating examination requires passing a minimum of 80 percent of the administered JPMs to pass. The NRC staff reviewed the licensees process to evaluate the trainee mastery of the objectives during training and retraining and finds it to be consistent with SAT element 4.
Section 5, Program Evaluation, of the Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states that routine assessments of the effectiveness and accuracy of the training are conducted by appropriate management personnel during and at the end of each 2-year training cycle. Evaluation results are reviewed by a station oversight board as defined in site procedures and any required changes, as determined by the station oversight board, are incorporated into the program. The NRC staff reviewed the licensees process to evaluate and revise the training based on the performance of trained personnel and finds it to be consistent with SAT element 5.
Based on the above, the NRC staff concludes that the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program includes the five elements of 10 CFR 55.4 and thus complies with 10 CFR 50.120(b)(2).
3.2.2 Compliance with the Requirements of 10 CFR 50.120(b)(3)
The NRC staff also verified that the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program meets the requirements of 10 CFR 50.120(b)(3). The NRC staff reviewed the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program and confirmed that each of the 10 CFR 50.120(b)(3) requirements is satisfied as discussed below.
Section 3.2, Fundamentals Training, of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states that the job analysis will be conducted by an individual holding an SRO license at Diablo Canyon, Units 1 and 2. Learning objectives will be derived from the analysis to describe the desired performance after training, and training materials will be designed based on the learning objectives. Section 3.4, Candidate Evaluation, of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states that a comprehensive final examination must be administered at the end of the initial training cycle consisting of a written examination and an operating examination described in Appendices A and B, respectively. Further, section 4.3.1 Course Schedule, of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states that the CFH Retraining Program
shall be administered in a biennial training cycle. This cycle includes annual operating examinations and biennial written examination. Biennial and annual are as defined in Revision 12 of NUREG-1021 or later revision. Appendices A and B of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program provide a compendium of instructional areas that the licensee has identified as required instructional areas necessary to ensure that the CFHs will be trained in all areas necessary to maintain the facility and operate equipment in a safe manner. The NRC staff finds that this satisfies the requirement to incorporate the instruction requirements necessary to provide qualified personnel to operate and maintain the facility in a safe manner in all modes of operation.
Section 1, Introduction, of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states, in part, that the program will adhere to the guidelines of Revision 1 of NUREG-1220. By letter dated May 13, 2021Property "Letter" (as page type) with input value "DCL-21-040, Responses to NRC Requests for Additional Information on LAR 20-03, Proposed Technical Specifications and Revised License Conditions for the Permanently Defueled Condition" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. (ML21133A300), the licensee provided its response to NRC staffs requests for additional information (RAIs) on the Permanently Defueled Technical Specification license amendment request. PG&Es response to RAI-3 specifically provides the American National Standards Institute/American Nuclear Society (ANSI/ANS) qualifications currently stipulated in the Quality Assurance Plan and how these would translate to a CFH position in decommissioning. Specifically, the licensees response states, in part:
The licensed Reactor Operators (ROs) and Senior Reactor Operators (SROs) shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1993
[Selection, Qualification and Training of Personnel for Nuclear Power Plants] as endorsed by Regulatory Guide 1.8, Revision 3, May 2000 with the exceptions clarified in the current revision to the Operator Licensing Examination Standards for Power Reactors, NUREG-1021, Section ES-202.
The NRC staff finds that this satisfies the requirement that the training program be developed to be in compliance with the facility license, including all technical specifications and applicable regulations.
Section 5, Program Evaluation, of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states that routine assessments of the effectiveness and accuracy of the training program are conducted by appropriate management personnel during and at the end of each 2-year training cycle. The evaluation results shall be reviewed by station oversight board as defined in site procedures. The station oversight board will verify the resolution of any discrepancies identified by the evaluation. Any required changes to the program determined by the station oversight board, shall be incorporated into the program. The NRC staff reviewed the provisions for evaluating and revising the CFH Training and Retraining Program and finds that they satisfy the program evaluation requirements that the training program be periodically evaluated and revised as appropriate to reflect industry experience as well as changes to the facility, procedures, regulations, and quality assurance requirements and be periodically reviewed by licensee management for effectiveness.
Section 6, Records Retention, of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states that records associated with the proposed CFH Training and Retraining Program will be retained in a retrievable format until there is no longer a need for the CFH position at the facility (i.e., when all fuel is permanently transferred to a dry fuel storage facility). Further, section 7, Evaluating Changes to the CFH Training and Retraining Program, of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program states that changes may be made to the training
program elements without NRC approval as long as the following are applicable: (1) the program continues to comply with Diablo Canyon, Units 1 and 2, Technical Specifications; and (2) the CFH Training and Retraining program will be revised to incorporate changes to the program, as appropriate, to reflect industry experience, changes to the facility, procedures, regulations, and quality assurance documents. The NRC staff finds that this is consistent with the requirement to maintain sufficient records to maintain program integrity and to have those records available for NRC inspection to verify the adequacy of the program.
4.0 CONCLUSION
The NRC staffs review of the proposed Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program determined that the program adequately addresses the safe conduct of decommissioning activities, the safe handling and storage of spent fuel, appropriate response to plant emergencies, and is consistent with the SAT processes defined by 10 CFR 55.4 and the requirements of 10 CFR 50.120(b)(2) and (b)(3). Based on the above findings, the NRC staff approves the Diablo Canyon, Units 1 and 2, CFH Training and Retraining Program pursuant to 10 CFR 50.2. Because the program is based on SAT, the licensee may change elements of the program without NRC approval as long as the following are applicable:
(1)
Suitable proficiency in the performance of the programs activities is maintained, and (2)
Changes are documented in an accessible manner that will allow the NRC to verify the adequacy of the program, in accordance with 10 CFR 50.120.
Principal Contributor: M. Keefe-Forsyth, NRR Date: March 6, 2023
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