ML13263A186

Response to Request for Additional Information Regarding Request for Approval of Shift Manager/Certified Fuel Handler Training Program

ML13263A186
Person / Time
Site:	Kewaunee
Issue date:	09/17/2013
From:	Blasioli P Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
13-278A
Download: ML13263A186 (31)

Text

-DominionEnergy Kewaunee, Inc. 0Do 5000 Dominion Boulevard, Glen Allen, VA 23060 minion Web Address: www.dom.com September 17, 2013 U. S. Nuclear Regulatory Commission Serial No. 13-278A Attention: Document Control Desk LIC/CDS/RO Washington, DC 20555-0001 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR APPROVAL OF SHIFT MANAGER / CERTIFIED FUEL HANDLER TRAINING PROGRAM By letter dated June 17, 2013 (Reference 1), Dominion Energy Kewaunee, Inc. (DEK),

requested approval of the Kewaunee Power Station (KPS) Shift Manager / Certified Fuel Handler (CFH) Training Program. As stated in that letter, approval of the KPS CFH Training Program is needed to facilitate activities associated with decommissioning and irradiated fuel management as documented in DEK's Post-Shutdown Decommissioning Activities Report and Updated Irradiated Fuel Management Plan.

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the CFH Training Program (Reference 2). The RAI questions and associated DEK response are provided in Attachment 1 to this letter.

The November 4, 2013, requested approval date for the submittal remains unchanged.

Please contact Mr. Jack Gadzala at 920-388-8604 if you have any questions or require additional information.

Sincerely, Paul A. Blasioli Director - Nuclear Protective Services and Emergency Preparedness for Dominion Energy Kewaunee, Inc.

Acof

Serial No. 13-278A CFH Training Program RAI Response Page 2 of 2

Attachment:

1. Response to Request for Additional Information Enclosure

1. Procedure TR-KW-101, "Conduct of Training"

References:

1. Letter from Paul A. Blasioli (DEK) to NRC Document Control Desk, "Request for Approval of Shift Manager / Certified Fuel Handler Training Program," dated June 17, 2013 (ADAMS Accession No. ML13176A117)

2. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK), "MF1952 (Defueled License and TS), MF2370 (Cert Fuel Handler Training Program) RAIs are being prepared - see attached drafts," dated August 8, 2013 cc: Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Mr. K. D. Feintuch Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-D15 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Kewaunee Power Station Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707

Serial No. 13-278A ATTACHMENT I RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

REQUEST FOR APPROVAL OF SHIFT MANAGER / CERTIFIED FUEL HANDLER TRAINING PROGRAM KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 13-278A Attachment 1 Page 1 of 6 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

REQUEST FOR APPROVAL OF SHIFT MANAGER / CERTIFIED FUEL HANDLER TRAINING PROGRAM By letter dated June 17, 2013 (Reference 1), Dominion Energy Kewaunee, Inc. (DEK),

requested approval of the Kewaunee Power Station (KPS) Shift Manager I Certified Fuel Handler (CFH) Training Program. As stated in that letter, approval of the KPS CFH Training Program is needed to facilitate activities associated with decommissioning and irradiated fuel management as documented in DEK's Post-Shutdown Decommissioning Activities Report and Updated Irradiated Fuel Management Plan.

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the CFH Training Program (Reference 2). The RAI questions and associated DEK response are provided below.

NRC Question MF2370-RAII-AHPB-Lapinsky-001 When fully implemented, will the Kewaunee CFH training program meet the guidelines of Regulatory Guide 1.8, Revision 3, "Qualification and Training of Personnel for Nuclear Power Plants" that are relevant to a defueled nuclear power plant?

Response

When fully implemented, the KPS CFH training program will meet the qualification requirements provided in KPS TS 5.3.1 (as approved by NRC in Amendment 207).

KPS is not committed to Regulatory Guide 1.8, Revision 3. Rather, TS 5.3.1 requires that each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971, except for the radiation protection manager, who shall meet or exceed the recommendation of Regulatory Guide 1.8, Revision 1-R, September 1975.

NRC Question MF2370-RAII-AHPB-Lapinsky-002 In Sections 5.1 of the submittal, the licensee refers to a document, "TR-KW-101, Conduct of Training", for a listing of responsibilities. Sections 4.1 "Definitions", 6.3.5.d.1 "written examinations", 6.7.1 "exemptions", and 6.8.1 "remediation" also make the same reference. Submit the current revision of the document," TR-KW-101, "Conduct of Training".

Response

The current revision of Procedure, TR-KW-101, "Conduct of Training," is provided as to this letter. This procedure describes the process for administering and

Serial No. 13-278A Attachment 1 Page 2 of 6 maintaining the training programs at KPS, including the Shift Manager / Certified Fuel Handler Program.

NRC Question MF2370-RAII-AHPB-Lapinsk¥-003 In Section 1.4.3, the licensee concludes that "This program satisfies all requirements for the Certified Fuel Handler Training Program (also referred to as the CFH)". This statement provides no practical information. The licensee should submit a table with all of the current CFH training requirements, the source document for each requirement, and a description of how the requirement is satisfied by the proposed program. Such a table will reflect how the requirements are satisfied so that, in the future, personnel will know whether a certain aspect of CFH training must be retained or may be deleted.

This table will also be more useful and less misleading if, in the future, requirements are added or changed by the NRC.

Response

Procedure TR-KW-101, "Conduct of Training" (discussed in the previous question),

references use of 10 CFR 50.120, "Training and Qualification of Nuclear Power Plant Personnel," which requires a systems approach to training. The table below contains the current CFH training requirements, the source document for each requirement, and a description of how the requirement is satisfied by the proposed program. The term "TPG" refers to the Shift Manager / Certified Fuel Handler Training Program Guide.

Documentation of training, evaluation, and qualification activities are controlled via the Shift Manager / Certified Fuel Handler Qualification Manual.

CFH Training Requirement Source Implementation Document/Method Document Prerequisites (high school ANSI N18.1-1971 e TPG Section 6.1.1, Prerequisites.

diploma, required experience) o TPG Section 6.1.2, Entry level experience requirements.

• Job Descriptions.

Systematic analysis of job 10 CFR 50.120 o TR-KW-101, Section 3.2, Maintain Total Task List.

(requirements analysis)

• TPG Approved Task List.

e Shift Manager/Certified Fuel Handler Training Program implements the requirements.

Learning objectives 10 CFR 50.120 e TR-KW-101, Section 3.7, Developing/Revising Training Materials.

e Each individual lesson plan.

Training design and 10 CFR 50.120 a TR-KW-101, Section 3.1, Maintaining Training implementation (program Program Guide.

design)

• Shift Manager/Certified Fuel Handler Training Program implements the requirements.

Serial No. 13-278A Attachment 1 Page 3 of 6 CFH Training Requirement Source Implementation Document/Method Document Trainee evaluation 10 CFR 50.120

• TR-KW-101, Section 3.9, Developing/Revising Written/Oral Examination; Section 3.14, Conducting Examinations.

9 Shift Manager/Certified Fuel Handler Training Program implements the requirements.

Program evaluation (including 10 CFR 50.120 e Procedure TR-KW-101, Section 3.3, Determining operating experience and Training Requirements; Section 3.4, Request for process changes) Training Submittal and Review; Section 3.17, Monitoring Training Programs.

Program content 10 CFR 50.120

• TR-KW-101, Section 3.1, Maintaining Training Program Guide.

e Shift Manager/Certified Fuel Handler Training Program implements the requirements.

Management effectiveness 10 CFR 50.120 e Procedure TR-KW-101, Section 3.15, End-of-review Course Training Feedback; Section 3.17, Monitoring Training Programs.

Record retention 10 CFR 50.120 e Requirements implemented by Shift Manager/Certified Fuel Handler Training Program (Section 7.0).

Requalification 10 CFR 50.120 a Shift Manager/Certified Fuel Handler Training Program implements the requirements in Sections 6.4, Continuing/Refresher Training; and 6.5, Maintenance of Qualification.

Medical requirements N/A

• TPG Section 6.1.3, Candidate Physical Examination.

Trainer qualifications N/A

• Note: CFH instruction is an ancillary job function performed by subject matter experts and qualified mentors who meet the qualification requirements established in either TS 5.3.1 or TS 3.5.2 depending upon their particular role within this job function.

NRC Question MF2370-RAII-AHPB-Lapinsky-004 Although the cover letter of the June 17, 2013 submittal states that its CFH training program aligns with the requirements of 10 CFR 50.120, the program description does not include some of the fundamental elements of a Systems Approach to Training required by 10 CFR 50.120 as defined in 10 CFR 55.4. These elements were listed in the cover letter but, except for trainee evaluation, were not included in the actual submittal. As stated in the licensee's cover letter: "The five key elements of the program are: (1) analysis of job performance requirements and training needs, (2) derivation of learning objectives based on the preceding analysis, (3) design and implementation of the training program based upon learning objectives, (4) trainee

Serial No. 13-278A Attachment 1 Page 4 of 6 evaluation, and (5) program evaluation and revision." Clarify this discrepancy by describing how the CFH program implements all five elements of SAT.

Response

The KPS Certified Fuel Handler Program was developed using the systems approach to training discussed in 10 CFR 50.120, "Training and qualification of nuclear power plant personnel."

The program was developed by Training and Operations personnel using an approved task list and creating a task training work matrix. The task training work matrix was used to determine the initial and continuing training required for each task based on the Difficulty, Importance, Frequency (DIF) process (analysis), which determines if initial and continuing training are required. Learning objectives were determined from the task list based on the required knowledge and skills for each task (derivation of learning objectives). The training materials (lesson plans/exams) and the Shift Manager /

Certified Fuel Handler Qualification Manual were then developed from the learning objectives (design of the training program). The Shift Manager / Certified Fuel Handler Training Program Guide was issued, which established the program (implementation of the training program). KPS Procedure TR-KW-101, "Conduct of Training," ensures that the systems approach to training is used for trainee evaluation and for maintaining and evaluating the Shift Manager / Certified Fuel Handler Program, including an annual review of the program which is documented and reported to senior management (program evaluation and revision).

NRC Question MF2370-RAII-AHPB-Lapinsky-005 Section 5.3.2 requires that the CFH training program be maintained. Who manages the CFH training program? Will that person be a CFH or have equivalent qualifications?

Response

The Manager Nuclear Operations is responsible for maintaining and implementing the CFH training program. The Manager Nuclear Operations assigns a Department Training Coordinator, who is typically a Certified Fuel Handler, to assist in the implementation of the program.

The proposed TS 5.3.2 is identical to the requirement approved by NRC in the currently existing TS 5.4.1 for Millstone 1.

Serial No. 13-278A Attachment 1 Page 5 of 6 NRC Question MF2370-RAII-AHIPB-Lapinsky-006 In Section 6.2.1, the licensee requires that Shift Managers complete the Plant Operator (PO) Training Program. Describe the PO training program or submit the procedure(s) that control it. Does this program have any relationship to 10 CFR 55, Operator Licenses? Does the PO training use a Systems Approach to Training?

Response

The Plant Operator Training Program is designed to train the Plant Operator on the knowledge and technical skills necessary to safely and efficiently monitor and control the operations of the KPS spent fuel pool and its support systems during normal and abnormal situations. The program was developed and is being maintained per the elements of the Systems Approach to Training (SAT) process. The program does not have any relationship to 10 CFR 55, as it is not intended to provide individuals with an NRC operator license.

NRC Question MF2370-RAII-AHPB-Lapinsky-007 In its May 29, 2013 letter, Dominion Energy Kewaunee (DEK) submitted a license amendment request (LAR) (ADAMS Accession No. ML13156A037) proposing revisions to its Technical Specifications (TSs). Proposed TS 5.2.2.d states that shift managers will be CFH-trained. However, the note on page 5 of 23 of the CFH training program submitted to the NRC on June 13, 2013 allows personnel to be trained for the Shift Manager position only. Clarify which submittal is correct.

Response

Both submittals are correct.

Proposed TS 5.2.2.d states that the Shift Manager shall be a CFH. To comply with this requirement, the Shift Manager who is used to satisfy the on-shift compliment for the Shift Manager position must also be qualified as a CFH.

Although the note on page 5 of 23 of the CFH training program submitted to the NRC on June 13, 2013 allows personnel to be trained for the Shift Manager position only, such an individual could not be used to fulfill the TS 5.2.2.d requirement. Only a Shift Manager qualified as a CFH could fulfill the TS 5.2.2.d requirement. Shift Managers who are not qualified as CFHs are used at KPS for other administrative functions that are not required by TS. In effect, there are two classes of Shift Managers. Only those who are qualified as a CFH would be used to fulfill the TS 5.2.2.d requirement.

Serial No. 13-278A Attachment 1 Page 6 of 6 References

1. Letter from Paul A. Blasioli (DEK) to NRC Document Control Desk, "Request for Approval of Shift Manager / Certified Fuel Handler Training Program," dated June 17, 2013 (ADAMS Accession No. ML13176A117)

2. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK), "MF1952 (Defueled License and TS), MF2370 (Cert Fuel Handler Training Program) RAIs are being prepared - see attached drafts," dated August 8, 2013.

Serial No. 13-278A ENCLOSURE I RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

REQUEST FOR APPROVAL OF SHIFT MANAGER I CERTIFIED FUEL HANDLER TRAINING PROGRAM PROCEDURE TR-KW-101, "CONDUCT OF TRAINING" KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, GNC.

Kewaunee Power Station V-7W nAdministrative Procedure Title: Conduct of Training Procedure Number Revision Number Effective Date and TR-KW-101 1 Approvals On File Revision Summary This revision 1 procedure includes the following changes:

" Per FIP, changed 1.2 and 5.4.1 .a to reference 10 CFR 50.120 and 10 CFR 55.4 instead of the Decommissioning Position Paper; and added 5.4.1.b

" Made the following format changes (per writer's guide/template):

• Changed the word "Section" to "Subsection" in 3.4.3.a & b; and split both into substeps

" Split 3.6.1, 3.15.5, and 3.16.3 into substeps

" Split 3.7.5 into a note and substep

" Reworded 3.14.2.k.3 and split into a substep

" Split 3.15.1 into two steps

" Reworded 3.17.1 and split into two steps

" Updated 5.2 responsibilities section to proper format INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 2 of 21 TABLE OF CONTENTS Section Page 1.0 PU RPO S E ............................................ .... ...... 3 2.0 S C O P E .............................................. . . . . . . . . . . . . . . . . . . . . . . . . .3 3.0 INSTRUCTIO NS ....................................... . . . . . . . . . . . . . . . . . . . . . . . . .3 3.1 Maintaining Training Program Guide (TPG) ............ . . . . . . . . . . . . . . . . . . . . . . . . .3 3.2 Maintaining the Total Task List ...................... . . . . . . . . . . . . . . . . . . . . . . . . .4 3.3 Determining Training Requirements ................... .. 4 3.4 Request for Training Submittal and Review ............ .15 3.5 Initiating Alternative Solutions to Training Actions ....... .. 6 3.6 Initiating Training Solutions .......................... . .7 3.7 Developing/Revising Training Material ................. .. °8 3.8 Determining Training Methods ....................... . .9 3.9 Developing/Revising Written/Oral Examination .......... .10 3.10 Allocating Instructional Resources .................... .11 3.11 Scheduling Training ................................ .11 3.12 Presenting Training ................................ .12 3.13 Documentation of Training .......................... .12 3.14 Conducting Examinations ........................... .13 3.15 End-of-Course Training Feedback .................... ...... 15 3.16 Post-Training Feedback ............................. ...... 15 3.17 Monitoring Training Programs ........................ ...... 16 3.18 Exemption/Alternate Qualifications (Ref. 5.4.1.c, 5.4.1 .d) . ...... 16 3.19 Verification of Qualifications ......................... ...... 17 4.0 REC O RDS ............................................ . . . . . . . . . .. . . . 18 4.1 QA Records ...................................... .............. 18 4.2 Non-QA Records .................................. ... ........... 18 5.0 ADMINISTRATIVE INFORMATION ........................ ......... ..... 19 5.1 Com mitm ents ..................................... ... ...... ..... 19 5.2 Responsibilities .................................... . .. ..... ...... 19 5.3 Definitions ........................................ .............. 20 5.4 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2 1 INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 3 of 21 1.0 PURPOSE 1.1 This procedure describes the basic process in administering and maintaining SAFSTOR training programs at the Kewaunee Power Station.

1.2 This procedure provides a systems approach to training, as discussed in 10 CFR 50.120, Training and Qualification of Nuclear Power Plant Personnel and defined in 10 CFR 55.4, Definitions. (Ref. 5.4.1 .a and 5.4.1 .b) 2.0 SCOPE 2.1 This procedure applies to all SAFSTOR Training Programs.

2.2 Subsections and steps within this procedure, which describe separate or unique activities, are NOT required to be performed in sequence and may be selected and performed independently, as needed, to accomplish specific tasks.

3.0 INSTRUCTIONS TrainingProgram 3.1 Maintaining Training Program Guide (TPG)

Owner 3.1.1 DEVELOP and MAINTAIN Training Program guides for each appropriate department. As a minimum, the following items should be included in the Training Program Guide (TPG):

" PURPOSE

" APPLICABILITY

• REFERENCES

" DEFINITIONS

" RESPONSIBILITIES

" ENTRY LEVEL/EXPERIENCE REQUIREMENTS

" INITIAL TRAINING REQUIREMENTS

" CONTINUING TRAINING REQUIREMENTS

• STANDARDS

" REMEDIATION REQUIREMENTS 3.1.2 CONDUCT annual review of the TPG and DOCUMENT results.

3.1.3 ENSURE all information is correct.

INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 4 of 21 3.1.4 REVISE TPG as necessary.

Department 3.2 Maintaining the Total Task List Training Coordinator 3.2.1 MAINTAIN Total Task List that, as a minimum, identifies the following:

" Program title

" A list of all tasks or topics (including task number and titles)

• Identification of training documents and evaluation instruments for those tasks selected for training 3.2.2 CONDUCT a biennial review to ensure the Total Task List accurately reflects the following:

" All tasks/topics performed by job incumbents

" Tasks/topics selected for training reflect current training documents and evaluation method 3.2.3 REVISE the Total Task List as needed for changes, such as:

" Identification of new task(s) (i.e., new equipment, modifications)

" Modification of existing tasks

• Selection or de-selection of task(s) for training 3.2.4 DOCUMENT Total Task List changes, including comments and rationale.

3.2.5 REVISE the training program description and associated training documents, as appropriate.

Training Program 3.2.6 APPROVE Total Task List.

Owner 3.3 Determining Training Requirements 3.3.1 REFER to the appropriate Training Program Guide for information on determining Initial and Continuing Training Requirements.

3.3.2 CONDUCT an annual training needs survey by Training Program to determine additional continuing training requirements.

INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 5 of 21 3.4 Request for Training Submittal and Review NOTE: Just-in-Time Training (JITT) should be requested using the following process.

All Personnel 3.4.1 IDENTIFY training needs or recommendations from the following sources:

" Changes in management expectations

" Human performance trending

" Management feedback

" New or revised procedures or processes

• New or revised regulatory and industry documents

" New tools or test equipment

" Operating experience

" Performance indicators

" Equipment reliability issues

" Personnel performance deficiencies

" Self-assessments

" Plant or equipment modifications

" Student feedback

" Trending reports and audits

" Site Corrective Action Process 3.4.2 FORWARD a request for training to the Training Program Owner.

INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 6 of 21 TrainingProgram 3.4.3 REVIEW training request.

Owner

a. IF the training request duplicates another training request or is NOT a training issue, THEN INFORM the initiator of the status of the previous training request or the justification for NO training.

1. GO TO Subsection 3.5, as appropriate.

b. IF the training request is valid, THEN ASSIGN to the appropriate Department Training Coordinator/Instructor to determine if training materials need to be developed.

1. TRACK actions through CRS or other appropriate tracking processes.

2. GO TO Subsection 3.6.

3.5 Initiating Alternative Solutions to Training Actions 3.5.1 IF training is NOT selected, THEN INITIATE any of the following methods, as appropriate:

" Procedure change request

" Information sharing

" Job aid

" Human performance review

" Other applicable station processes to address the issue 3.5.2 NOTIFY initiator of any actions to be taken and status of training request.

INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 7 of 21 3.6 Initiating Training Solutions 3.6.1 DETERMINE if training is based on a new or modified task.

a. IF training is based on a new or modified task, THEN PERFORM the following actions:

1. REVISE Training Program Guide, as appropriate.

2. REVISE Total Task List, as appropriate.

3.6.2 DETERMINE if current training documents exist, including documents at other Dominion fleet sites and training programs.

a. IF current training documents exist and are in need of revision, THEN REVISE training documents before implementation of training.

b. IF current training documents exist that meet the requested action and are acceptable to the Program Owner, THEN SCHEDULE training.

c. IF NO training documents exist, THEN DEVELOP training materials for Training Program Owner approval.

INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 8 of 21 Department 3.7 Developing/Revising Training Material Training Coordinatoror 3.7.1 DEVELOP lesson plans containing the following:

Instructor

" Goal of Training

" Learning Objectives

" Prerequisites

" Training Resources

" References

" Commitments

• Evaluation Method

" Operating Experience

" Tasks Associated with Lesson Plan

" Lesson Plan Content

" Summary 3.7.2 DEVELOP lesson plans in any of the following formats:

- Single column

- Two column

- Self-Study Guide

- Power Point Lesson 3.7.3 ORGANIZE lesson plan content using the following techniques:

" Job Performance Order: The learning sequence is the same as the job sequence

" Simple to Complex: Content may be sequenced in terms of increasing complexity

• Critical Sequence: Content is ordered in terms of relative importance

" Known to Unknown: Familiar topics are considered before unfamiliar topics INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 9 of 21 3.7.4 DEVELOP handouts, exercises, Power Point presentations, and other activities to support the training session.

NOTE: Pen and ink changes are acceptable.

3.7.5 REVISE training material as appropriate.

a. INITIAL and DATE all pen and ink changes incorporated into the lesson plan prior to conducting training.

Training Program 3.7.6 APPROVE lesson plan.

Owner Department 3.8 Determining Training Methods Training Coordinatoror 3.8.1 CONSIDER the following training methods when developing Lesson Instructor/Trainer Plans/Training Materials:

" Lecture

• Demonstration/practice

" Guided discussion

• Self-paced

" Walk through

" Role-playing

" Dynamic learning activities 3.8.2 DETERMINE which training method(s) would be most suitable for the training being conducted. More than one training method may be incorporated into any one training session.

INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 10 of 21 3.9 Developing/Revising Written/Oral Examination 3.9.1 DEVELOP, REVISE, or DELETE written test questions which support specific learning objectives. Test questions shall support the learning objective being evaluated.

3.9.2 DEVELOP, REVISE, or DELETE oral test questions which support specific learning objectives. Oral questions administered for qualification purposes shall be written down with the answer to ensure reliable and valid oral boards are conducted.

3.9.3 DEVELOP written or oral examinations in any one of the following formats or combinations, as appropriate:

" Multiple choice

• True/False

" Matching

" Short answer 3.9.4 WHEN multiple sessions of the training are conducted, THEN DEVELOP a minimum of two different exams by varying multiple versions of the same exam by at least 30 percent.

3.9.5 ROTATE versions of the exam for multiple training sessions.

3.9.6 IF developing a remedial exam, THEN ENSURE the following:

a. Remedial exam differs from the previous exam by at least 30 percent.

b. Areas failed on the previous exam are included.

c. Areas which the trainee previously passed may be included.

Training Program 3.9.7 APPROVE written or oral examination.

Owner INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 11 of 21 3.10 Allocating Instructional Resources 3.10.1 ALLOCATE instructional resources for the purpose of instruction.

a. SELECT instructor/trainer or subject matter expert to conduct training based on the following:

" Has documented technical expertise on the specific tasks or duty areas for which trainees will be trained and evaluated (task qualified)

• Has overall job knowledge

" Maintains high standards of performance and commitment to quality

" Displays expected professionalism and judgment

• Supports a conservative approach to nuclear safety

" Practices expected observation and communication skills 3.11 Scheduling Training All Personnel 3.11.1 CONTACT Department Training Coordinators to schedule training.

Department 3.11.2 SCHEDULE and COORDINATE resources to support training request Training to include, but NOT limited to, the following:

Coordinator

" Classroom/laboratory space

" Training equipment, as appropriate

" SME support, as appropriate

" Trainees 3.11.3 SCHEDULE off-site training support personnel (e.g., instructors for First Aid Training) far enough in advance to ensure NO delays occur in implementing the training session.

INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 12 of 21 Instructor, Trainer, 3.12 Presenting Training or SME 3.12.1 REVIEW lesson plans to ensure familiarity with lesson content, equipment and tools, and the use of media, text material, references, and tests.

3.12.2 PREPARE to ensure consistent and effective delivery of lessons and time management.

3.12.3 PRESENT the training in accordance with the approved lesson plan/training material.

3.13 Documentation of Training 3.13.1 DOCUMENT completion of training using site Record of Attendance Form for the following settings:

- Classroom or Laboratory

. Self-Study 3.13.2 DOCUMENT training or performance evaluation for OJT, TPE, Mentoring, Job Familiarization Guide (JFG), Activity Performance Measure (APM), or other skill based session on the appropriate qualification document.

3.13.3 FORWARD all completed documentation of training or evaluation to Records for filing. Examples of training documentation include, but NOT limited to, the following items:

" Signed and implemented Lesson Plans

" Record of Attendance forms

" Completed OJT and TPE guides, Mentoring guides, JFGs, and APMs

" Written or Oral Examination results INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 13 of 21 3.14 Conducting Examinations 3.14.1 MAINTAIN examination security by performing one of the following:

a. MAINTAIN possession of the examination material at all times.

b. WHEN NOT in use, THEN KEEP written/oral examinations in a secure location (e.g., an envelope marked CONFIDENTIAL, placed into a secured, locked exam bag, locked in a desk drawer or in a locked office) until all applicable personnel have completed the evaluation.

c. WHEN examination material is transferred from one individual to another, THEN DELIVER by hand, which is the preferred method.

d. IF examination material is sent through the mail, THEN ENSURE the following requirements are met:

" The examination material is in a sealed envelope identified as examination material (with the sender's signature covered by transparent tape across the seal).

" The sealed envelope is placed in an unmarked mailing envelope marked PERSONAL and CONFIDENTIAL.

e. PROTECT examinations in electronic form using password protected files or access restricted folders.

f. MAINTAIN security requirements during examination process (e.g., establishing examination boundaries and controlling access to the exam area).

INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 14 of 21 3.14.2 ADMINISTER examinations in accordance with the following:

a. PROVIDE the same exam directions to all trainees (e.g., how to select a response, time limits, acceptable reference materials, etc.).

b. ADMINISTER the exam to all trainees under the same conditions (e.g., one exam per trainee, standard time limits, same references, etc.).

c. PROCTOR the examination to the extent necessary to ensure the exam is NOT compromised.

d. WHEN answering trainee's questions regarding test items, THEN PROVIDE only information that clarifies the test item.

e. PROVIDE clarifying information to all trainees.

f. IF administering an oral exam, THEN PRESCRIPT questions and answers and DOCUMENT trainee's response to each question.

g. COLLECT all copies of exams (including supporting material and scratch paper) that were distributed.

h. GRADE all exams using the examination key.

i. ENSURE all trainees are given the opportunity to review their examinations to ensure the correct answers to any questions answered incorrectly are understood.

j. DOCUMENT the trainees grade/total points on the exam cover sheet.

k. IF the trainee fails to achieve a passing score, THEN TAKE the following action:

1. DETERMINE impact on qualifications.

2. IMPLEMENT remedial training.

3. ADMINISTER remedial exam, which shall be 30% different than the initial exam.

(a) IF the trainee fails the remedial examination, THEN CONFER with the appropriate Training Program Owner to determine actions to be taken.

4. REINSTATE qualifications, if appropriate.

INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 15 of 21 I. For performance based evaluation failures, TAKE the following actions:

1. DETERMINE impact on qualifications.

2. IMPLEMENT remedial training.

3. CONDUCT reevaluation.

4. REINSTATE qualifications, if appropriate.

3.15 End-of-Course Training Feedback 3.15.1 PROVIDE each trainee a Trainee Feedback Form at the completion of each training session.

3.15.2 FORWARD completed Trainee Feedback forms to the Department Training Coordinator.

Department 3.15.3 DOCUMENT trainee feedback on the Trainee Feedback Training Coordinator Summary Form.

3.15.4 FORWARD Trainee Feedback Summary to the appropriate Training Program Owner.

Training Program 3.15.5 REVIEW trainee feedback.

Owner

a. DOCUMENT and TRACK actions taken.

3.16 Post-Training Feedback Department 3.16.1 COLLECT post-training feedback on Initial and Continuing Training Training within six months after completion of training.

Coordinator 3.16.2 SUMMARIZE post-training feedback using Post-Training Summary Form.

Training Program 3.16.3 EVALUATE feedback.

Owner/Training Supervisor a. DOCUMENT necessary actions.

b. TRACK actions taken.

INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 16 of 21 3.17 Monitoring Training Programs 3.17.1 CONDUCT an annual review of training programs, including, but NOT limited to, the following:

• Progression of job incumbents enrolled in training courses

" Training Program Guide

" Total Task List

" Lesson Plans

• Training Materials

" Written and Oral Examinations

• Training Feedback

" Actions taken to resolve training issues 3.17.2 DOCUMENT and REPORT results to Senior Management.

3.18 Exemption/Alternate Qualifications (Ref. 5.4.1.c, 5.4.1.d)

NOTE: Exemption and Alternate Qualifications shall be reviewed on a case-by-case basis.

TrainingProgram 3.18.1 REVIEW the following information to determine exemptions and Owner alternate qualifications:

" Review of previous training, education, and experience records

" Knowledge based examination

• Skill based examination (e.g., TPE/APM/JFG) 3.18.2 DOCUMENT exemption or alternate qualification on the current qualifying training document and FORWARD completed documentation to Records.

INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 17 of 21 Line Supervisor! 3.19 Verification of Qualifications Individuals Directing Work 3.19.1 ENSURE training and qualifications are satisfied prior to assigning an individual a task or an evolution by checking the Training and Qualification Matrix.

3.19.2 IF a work assignment extends beyond a shift, THEN PERFORM verification daily.

3.19.3 Do NOT assign individuals to perform tasks or functions independently for which they are NOT indicated to be qualified.

3.19.4 For qualifications with an expiration date, ENSURE appropriate measures are taken to confirm worker qualification throughout the conduct of the assigned task.

All Personnel 3.19.5 KNOW and MAINTAIN qualifications.

3.19.6 ENSURE training and qualifications are satisfied prior to performing a task or an evolution by using one of the following, as applicable:

" On-line database

• Training/Qualification report matrix hard copy (with the time and date of report generation) less than or equal to seven days old

" Automatically generated qualification reports

" As approved by the Manager Nuclear Training, in hand paperwork for the task and all day components or ancillary tasks needed to perform the task 3.19.7 IF a work assignment extends beyond the shift, THEN PERFORM verification daily.

3.19.8 IF NOT qualified to perform a task independently, THEN NOTIFY supervisor upon assignment of task.

INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 18 of 21 4.0 RECORDS The following QA records and non-QA records are generated by or created according to this document and are listed on the KPS Records Retention Schedule. These records shall be maintained according to the KPS Records Management Program.

4.1 QA Records None 4.2 Non-QA Records None 4.3 The following item(s) completed as a result of this procedure SHALL be records for retention transmitted to QA records.

" Record of Attendance

• Written or Oral Examination results

" OJT and TPE completions

" Mentoring Guides

" Job Familiarization Guides

" Qualification Manuals

" Activity Performance Measures INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 19 of 21 5.0 ADMINISTRATIVE INFORMATION 5.1 Commitments None 5.2 Responsibilities 5.2.1 Training Program Owners Training Program Owners are responsible for the following:

a. Maintaining the Training Program Guide.

b. Approving Total Task List.

c. Reviewing/approving Request for Training.

d. Approving Training Materials and examinations.

e. Reviewing and Tracking trainee feedback.

f. Conducting annual review of Training Program.

g. Reviewing and approving exemptions and alternate qualifications.

h. Verifying qualifications when work is assigned.

5.2.2 Subject Matter Experts (SMEs)

Subject Matter Experts (SMEs) are responsible for conducting training when selected.

5.2.3 Training Supervisors Training Supervisors (when assigned) are responsible for monitoring Training Program implementation and evaluation.

5.2.4 Instructors/Trainers I Instructors/Trainers (when assigned) are responsible for:

a. Conducting training.

b. Administering written and oral examinations.

c. Administering performance evaluations.

INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 20 of 21 5.2.5 Line Personnel Line Personnel are responsible for:

a. Submitting Requests for Training.

b. Validating qualifications prior to conducting work.

5.2.6 Senior Management Senior Management is responsible for:

a. Overall implementation of Training Programs.

b. Determining supervisory training requirements.

5.2.7 Department Training Coordinator The Department Training Coordinator is responsible for:

a. Maintaining Total Task List

b. Developing/revising training material

c. Determining training methods

d. Developing/revising Written/Oral exams 5.3 Definitions 5.3.1 Request for Training A method used to communicate an identified or potential training need to the training organization. The training request is an input into the training organization work process and site action request process.

5.3.2 Subject Matter Expert (SME)

A person who has attained a level of expertise by education, experience, or plant/vendor task qualification.

5.3.3 Task A defined unit of work having an identifiable beginning and end, containing two or more elements.

INFORMATION USE

DOMINION TR-KW-101 Revision 1 Page 21 of 21 5.3.4 Topic A cluster of common skills and knowledge for training analysis and design purposes. This cluster is usually fundamental to many tasks as opposed to a unique knowledge or skill for a specific task.

5.3.5 Total Task List A list of tasks for a specific job or position. This list includes all tasks selected and non-selected for initial and continuing training.

5.3.6 Training Program Owner The line manager or supervisor who has direct responsibility for the determination and approval of the scope and content of a training program, for the scheduling of training, and for the qualification of their respective work group(s).

5.4 References 5.4.1 Other

a. 10 CFR 50.120, Training and Qualification of Nuclear Power Plant Personnel

b. 10 CFR 55.4, Definitions

c. DTO-7.22.B, Prepare exemption request for Operator Requal and Staffing

d. DTO-7.22.T, Prepare exemption request for training INFORMATION USE