ML23110A070

EIP-ZZ-A0066, RERP Training Program Minor Revision 028

ML23110A070
Person / Time
Site:	Callaway
Issue date:	04/20/2023
From:	Ameren Missouri
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML23110A069	List: ML23110A070 ML23110A071
References
EIP-ZZ-A0066, Rev. 28
Download: ML23110A070 (1)

Text

EIP-ZZ-A0066 RERP TRAINING PROGRAM MINOR Revision 028 Page 1 of 12 INFORMATION USE

EIP-ZZ-A0066 Rev. 028 RERP TRAINING PROGRAM TABLE OF CONTENTS Section Page Number 1.0 PURPOSE ...................................................................................................................................... 3 2.0 SCOPE ........................................................................................................................................... 3 3.0 RESPONSIBILITIES .................................................................................................................... 3 4.0 PREREQUISITES ......................................................................................................................... 4 5.0 PROCEDURE INSTRUCTIONS ................................................................................................. 5 5.1. Overview of Program ........................................................................................................... 5 5.2. Initial Training ..................................................................................................................... 6 5.3. Qualification ........................................................................................................................ 7 5.4. Continuing Training ............................................................................................................. 8 5.5. Trainee Evaluation ............................................................................................................... 9 5.6. Program Evaluation ............................................................................................................. 9

6.0 REFERENCES

............................................................................................................................ 10 6.1. Implementing ..................................................................................................................... 10 6.2. Developmental ................................................................................................................... 10 7.0 RECORDS ................................................................................................................................... 10 8.0 DEFINITIONS ............................................................................................................................ 11 9.0

SUMMARY

OF CHANGES ....................................................................................................... 11 Page 2 of 12 INFORMATION USE

EIP-ZZ-A0066 Rev. 028 RERP TRAINING PROGRAM 1.0 PURPOSE 1.1. This procedure defines Radiological Emergency Response Plan (RERP) training provided to personnel who meet either of the following:

• Granted unescorted access to the Callaway Plant

• Members of the Callaway Plant Radiological Emergency Response Organization 1.2. The RERP training program ensures that designated personnel can successfully carry out their specific emergency response duties. The program is consistent with CTM-SAT, Callaway Training Manual - Systematic Approach to Training.

2.0 SCOPE 2.1. This procedure defines the Radiological Emergency Response Plan (RERP) training requirements for individuals who have unescorted access or are members of the Callaway RERP organization.

2.2. The following training topics are addressed by other procedures/programs and are NOT included in the scope of this procedure.

• Craft-specific training (i.e. electrician, machinist, non-licensed operator, etc.)

• Specialized task training (i.e. fire brigade, licensed operator, first aid, CPR, etc.)

• Emergency Preparedness Staff training 3.0 RESPONSIBILITIES 3.1. Director Training:

3.1.1. ENSURES the Training Department provides support for training activities and for necessary training and qualification programs required for safe, legal, and efficient operation and maintenance of Callaway Plant.

3.2. Manager, Emergency Preparedness:

3.2.1. Conduct of on-site RERP Training. [Ref: 6.2.6]

3.2.2. Review and approval of RERP training objectives and of content changes to RERP training material. [Ref: 6.2.7]

3.2.3. Review and approval of changes to the RERP training program requirements.

Page 3 of 12 INFORMATION USE

EIP-ZZ-A0066 Rev. 028 3.2.4. Notification of the Senior Training Supervisor or Program Lead of changes to the Emergency Response Organization (ERO), procedures, or equipment that affects their disciplines RERP training activities.

3.2.5. Review and approval of lesson plans, instructor guides, or other appropriate course material prior to conducting RERP training sessions. [Ref: 6.2.7]

3.2.6. Approve evaluation methodology for RERP training activities, including drills and exercises if used to meet training requirements. [Ref: 6.2.7]

3.3. Senior Training Supervisors and Program Leads within Training (Discipline Specific):

3.3.1. Maintain the RERP Training program and RERP courses in the Callaway Training Course Catalog using this procedure. [Ref: 6.2.7]

3.3.2. Coordinate completion of initial RERP training for newly identified candidates for emergency response positions.

3.3.3. Work with Emergency Preparedness (EP) Staff to identify and resolve ERO performance needs.

3.3.4. Conduct or coordinate assigned RERP retraining activities.

3.3.5. Notify Emergency Preparedness when lack of training completion results in changes to the Emergency Response Organization.

3.3.6. Evaluate the effectiveness of the training program.

3.4. Emergency Preparedness (EP) Staff:

3.4.1. Conduct or coordinate ERO facility retraining.

3.4.2. Provide assistance to other trainers as subject matter experts.

3.4.3. Coordinate with Training and Administration (Learning Management System (LMS) updates) when updating Emergency Response Organization qualifications.

4.0 PREREQUISITES None

-END OF SECTION-Page 4 of 12 INFORMATION USE

EIP-ZZ-A0066 Rev. 028 5.0 PROCEDURE INSTRUCTIONS 5.1. Overview of Program NOTE This training includes duties and responsibilities of Emergency Response and Non-Emergency Response Personnel, including emergency classifications, assembly areas, alarms, emergency response actions and accountability/evacuation. [Ref: 6.2.6]

5.1.1. Non-Emergency Response Personnel should complete General Employee Training (Plant Access Training - T68.0030.6/8).

5.1.2. Emergency Response Personnel Training

a. ERO Positions will have a review completed to determine the validity of the current Position Analysis.

b. Approximately once every six years, a comprehensive review of the ERO position list should be conducted to ensure it continues to accurately reflect job performance requirements. This can be done by following the process outlined below.

• Print a copy of the current position analysis survey.

• Distribute the survey to a sample group of the ERO personnel in the position.

• Request that ERO personnel mark suggested changes for procedures and/or responsibilities they feel should be added or deleted from those listed that they implement when manning the position and related questions relevant to the position such as difficulty performing ERO tasks, additional training needed to perform tasks, frequency of training meets needs, etc.

c. Satisfactory completion of initial and continuing training establishes and maintains the individual's qualification.

Page 5 of 12 INFORMATION USE

EIP-ZZ-A0066 Rev. 028 Step 5.1.2 Cont'd

d. To meet the objectives of the RERP training courses and to ensure familiarity with specific emergency response duties, training activities consist of any of the following, or a combination of one or more: [Ref: 6.2.7]

• Classroom Training

• Drill and exercise participation

• Practical exercises

• Specialized instruction

e. Training Waivers allow credit for previous experience and/or training.

Guidance on how to initiate and process a waiver is in CTM-SAT, Callaway Training Manual - Systematic Approach to Training.

5.2. Initial Training 5.2.1. ERO Members complete RERP Initial Training required for their designated position(s), as specified in the Learning Management System (LMS) [Ref: 6.2.6]

5.2.2. One of the following is completed within 30 days of being designated to an Emergency Response Organization position:

• RERP Fundamentals (T68.RERP.6)

• RERP Fundamentals-SRO (T68.1022.6) 5.2.3. Some positions require Drill Certification as part of initial training, as indicated in the Learning Management System (LMS).

5.2.4. Final qualification authorization is given to ERO members by the Manager, Emergency Preparedness (or designee) by approving the EP Endorsement code.

• For the following job codes evaluate the individual to ensure they have three years working experience in the appropriate craft. (See ANSI/ANS-3.1-1978 Section 4)

• OOME Mechanic

• OICT I&C Technician

• OOEL Electrician

• SICC On-shift I&C Technician

• E-Team Coordinator Mechanical and Electrical should have 6 months of maintenance supervision experience at the Callaway Energy Center prior to filling their position.

Page 6 of 12 INFORMATION USE

EIP-ZZ-A0066 Rev. 028 5.3. Qualification 5.3.1. Drill Certification/Participation may be obtained by either of the following:

a. For candidate not previously qualified in the position:

1. Fill a position in an exercise/drill/tabletop, observed by a Mentor.

a) The Mentor completes a Drill/Exercise Critique indicating if the candidate passed or failed the drill.

b) If the candidate passed, indicate on the CA0040 the Drill Certification and Drill Participation for which the candidate receives credit.

c) If the candidate failed, the candidate is not qualified and must complete another exercise/drill/tabletop.

b. For candidate that has previously served in the same position:

1. Fill a position in an exercise/drill/tabletop observed by a Mentor.

a) The Mentor completes a Drill/Exercise Critique indicating if the candidate passed or failed the drill.

b) If the candidate passed, indicate on the CA0040 the Drill Participation for which the candidate receives credit.

c) If the candidate failed, the candidate must be remediated using a CA200 before receiving Drill Participation credit.

2. Complete the position's initial training or makeup the missed continuing training.

5.3.2. Drill / Exercise Controller Qualifications

a. EP Staff provides a drill controller briefing to utility-provided controllers and evaluators prior to participation in a drill or exercise. [Ref: 6.2.6]

b. Continuing training credit for a drill or exercise may be granted to an evaluator or controller, provided the duties of the evaluated position(s) are equivalent to their designated position (the same position or a closely related position with similar training requirements). [Ref: 6.2.7]

Page 7 of 12 INFORMATION USE

EIP-ZZ-A0066 Rev. 028 5.3.3. Disqualification of Emergency Responders

a. When any of the following occurs, disqualify the affected Emergency Responder(s):

• Required RERP continuing training lapses.

• Performance determined by EP to be inadequate in a drill or exercise.

• Failure of continuing training session.

b. IF an Emergency Responder has been disqualified, remove the individual from ERO responsibilities until satisfactory remediation is completed and notify the Position Owner.

c. Generate a CR to document.

d. Inactivate the endorsement code using CTM-EP, Callaway Training Manual Emergency Preparedness for the steps to remove and restore qualifications.

5.4. Continuing Training NOTE RERP continuing training, including required RERP Computer Based Training (CBT), is expected to be completed in the month requalification is due. Evaluate a qualification lapse in accordance with APA-ZZ-00925 APPA.

5.4.1. The required continuing training for an assigned position should be completed on an annual basis, unless otherwise noted in the Learning Management System (LMS). [Ref: 6.2.6]

5.4.2. RERP continuing training content is established, to include:

a. Review of the original training topics.

b. Any of the following, as appropriate:

• Changes to RERP related procedures or processes

• Internal operating experience

• External operating experience

• Results of previous drills and exercises

• Facility and equipment changes

• Other topics as selected by EP Page 8 of 12 INFORMATION USE

EIP-ZZ-A0066 Rev. 028 NOTE A review of training material by EP prior to conducting a training session ensures that the training activity addresses the requirements of the specific position(s). [Ref: 6.2.7]

5.4.3. EP Staff should review training material (initial and requal) prior to conducting the training session. [Ref: 6.2.7]

5.4.4. Drills and exercises may be used as training activities, when familiarity with specific RERP duties and/or functions is demonstrated, and commitments are ensured. [Ref: 6.2.7]

5.5. Trainee Evaluation 5.5.1. A minimum of 80% correct responses is required to pass written examinations.

[Ref: 6.2.6]

5.5.2. IF drills or exercises are used to satisfy RERP continuing training requirements, the following provisions must be met: [Ref: 6.2.7]

• Objectives and evaluation methodology must be identified and approved by EP.

• A lesson plan, instructor guide, or other appropriate course material must be developed and reviewed by EP prior to conducting the training session.

• Evaluation objectives must be established for each position or functional group.

• To receive credit for annual requalification during a drill or exercise, an evaluator/controller must be evaluating his or her position or a closely related position.

5.6. Program Evaluation 5.6.1. Formal critiques for training, including drills and exercises, are conducted to identify weak or deficient areas that need corrections. [Ref: 6.2.6]

5.6.2. Weaknesses or deficiencies that are identified are corrected. [Ref: 6.2.6]

5.6.3. Drill Participation

a. Verify Drill participants are fully qualified or are under the guidance of a Mentor.

b. A person taking the role of the Mentor is the qualified participant.

-END OF SECTION-Page 9 of 12 INFORMATION USE

EIP-ZZ-A0066 Rev. 028

6.0 REFERENCES

6.1. Implementing 6.1.1. EIP-ZZ-A0001, Emergency Response Organization 6.1.2. CTM-SAT, Callaway Training Manual - Systematic Approach to Training 6.2. Developmental 6.2.1. APA-ZZ- 00925, Training and Qualification of Plant Personnel 6.2.2. EIP-ZZ-A0020, Maintaining Emergency Preparedness 6.2.3. 10 CFR 50, Appendix E 6.2.4. NUREG 0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants 6.2.5. Emergency Coordinator Supplemental Guideline 6.2.6. Callaway Plant Radiological Emergency Response Plan 6.2.7. NRC Inspection Report 98-010 Reactive Inspection 6.2.8. EIP-ZZ-A0066 Appendix 1, RERP Training Program Requirements 6.2.9. FPP-ZZ-00009 Appendix 1, Initial Training Course Agenda (Training requirements for Fire Brigade Leader and Fire Brigade Team Member.)

6.2.10. SDP-ZZ-00020, Medical Emergency Response Team Operation (Training requirements for MERT Team Leader and MERT Team Member.)

7.0 RECORDS 7.1. CA0040, K235.0001.

7.2. Drill/Exercise Critique, K235.0001 Page 10 of 12 INFORMATION USE

EIP-ZZ-A0066 Rev. 028 8.0 DEFINITIONS 8.1. Mentor - Personnel fully qualified for the position being evaluated or an EP staff member.

Can be the qualified person filling the position.

8.2. Emergency Response Personnel - Personnel assigned to a position in an emergency response organization.

8.3. Formal Critique - A review of objectives, overall performance, functional areas or position performance and facility and equipment readiness following a drill, exercise, seminar or training.

8.4. Non-Emergency Response Personnel - Personnel who are granted unescorted access to the Callaway Plant Protected Area, but who do NOT have designated responsibilities in the Callaway Plant Emergency Response Organization.

9.0

SUMMARY

OF CHANGES Section or Page(s) Description Step Number 4 3.4.3 Changed "Training Application" to "Learning Management System (LMS)" due to retirement of the Training Application. CR 202301165-001 6 5.2.1 Changed "Training Application" to "Learning Management System (LMS)" due to retirement of the Training Application. CR 202301165-001 6 5.2.3 Changed "Training Application" to "Learning Management System (LMS)" due to retirement of the Training Application. CR 202301165-001 8 NOTE Deleted "An adverse condition CAR is generated by the Training Application when Emergency Response Personnel lapse required RERP continuing training" as Training Application is being retired and replaced with "Evaluate a qualification lapse in accordance with APA-ZZ-00925 APPA."CR 202301165-001 8 5.4.1 Changed "Training Application" to "Learning Management System (LMS)" due to retirement of the Training Application. CR 202301165-001 8 5.4.1 Deleted "(12 months, +/- 3 a month grace period)" from step 5.4.1 following "annual basis" to read "The required continuing training for an assigned position should be completed on an annual basis, unless otherwise noted in the Learning Management System (LMS) as Training Application is being retired. CR 202301165-001 Page 11 of 12 INFORMATION USE

EIP-ZZ-A0066 Rev. 028 Section or Page(s) Description Step Number 10 6.1.3 Deleted reference to Training Application DTI-030 as Training Application is being retired. CR 202301165-001 Page 12 of 12 INFORMATION USE