ML17089A544

Fort Calhoun, Unit 1 - Response to Request for Additional Information Certified Fuel Handler Training Program

ML17089A544
Person / Time
Site:	Fort Calhoun
Issue date:	03/30/2017
From:	Fisher M J Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF8112, LlC-17 -0030
Download: ML17089A544 (78)

Text

Omaha Public Power District Ll C-17 -0030 March 30, 2017 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station (FCS), Unit 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

Response to Request for Additional Information, Fort Calhoun Station, Unit No. 1 -Request for Additional Information RE: Certified Fuel Handler Training Program (CAC NO. MF8112)

References:

1. Letter from OPPD (S. M. Marik) to USNRC (Document Control Desk), "Request for Approval of Certified Fuel Handler Training Program," dated July 7, 2016 (LIC-16-0049)(ML 16190A208) 2. Letter from NRC (C. F. Lyon) to OPPD (S.M. Marik), "Fort Calhoun Station, Unit No. 1 -Request for Additional Information Re: Certified Fuel Handler Training Program (CAC NO. MF8112)," dated September 20, 2016 (NRC-16-0084)(ML 16263A049) 3. Letter from OPPD (S. M. Marik) to USNRC (Document Control Desk), "Response to Request for Additional Information, Fort Calhoun Station, Unit No. 1 -Request for Additional Information RE: Certified Fuel Handler Training Program (CAC NO. MF8112)," dated October 7, 2016 (LIC-16-0090)(ML 16281A479) 4. Letter from OPPD (S. M. Marik) to USNRC (Document Control Desk), "License Amendment Request (LAR) 16-03; Revised Fort Calhoun Station Technical Specifications to align staffing requirements to those required for decommissioning." dated September 28, 2016 (LIC-16-0092)(ML 16273A502) 5. USNRC (J.S. Kim) to OPPD (M. J. Fisher) "Fort Calhoun Station, Unit No. 1 -Request for Additional Information Regarding Certified Fuel Handler Training Program (CAC NO. MF8112)," dated March 15, 2017 (NRC-17-0014)(ML 17067A386) In Reference 1, the Omaha Public Power District (OPPD) requested approval of a Certified Fuel Handler Training Program for the decommissioning facility. Reference 2 requested additional information to allow processing of the request from Reference 1. Reference 3 provided the information requested in Reference 2. On March 15, 2017 (Reference 5), the NRC provided OPPD with Requests for Additional Information (RAI) regarding the proposed Certified Fuel Handler Training Program (Reference 1 ). Attachment 1 of this letter provides the responses to the RAI. Attachment 2 of this letter provides the Revised Certified Fuel Handler Training Program resulting from the responses to the RAI. Attachment 3 of this letter provides the Fort Calhoun Station procedure, "SAFSTOR Systematic Approach to Training (SAT)", TQ-DC-FC-201. 444 SOUTH 16TH STREET MALL

• OMAHA, NE 68102-2247 U. S. Nuclear Regulatory Commission LIC-17 -0030 Page 2 This letter contains no regulatory commitments. If you should have any questions regarding this submittal or require additional information, please contact Mr. Bradley H. Blome at (402) 533-7270. Respectfully, Senior Director Decommissioning Fort Calhoun Station MJF/epm Attachments: 1. 2. 3. Response to Request for Additional Information Certified Fuel Handler Training and Retraining Program, Revision 0, TQ-DC-FC-1 01 SAFSTOR Systematic Approach to Training (SAT), TQ-DC-FC-201 c: K. M. Kennedy, NRC Regional Administrator, Region IV J. S. Kim, NRC Project Manager S. M. Schneider, NRC Senior Resident Inspector Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska LIC-17-0030 Attachment 1 Page 1 ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RE: CERTIFIED FUEL HANDLER TRAINING AND RETRAINING PROGRAM CAC NO. MF8112 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT N0.1 DOCKET NO. 50-285 By letter dated July 7, 2016 (Agencywide Documents Access and Management System (ADAMS} Accession No. ML 16190A208}, Omaha Public Power District (OPPD, the licensee) submitted a request for approval of the Certified Fuel Handler (CFH) Training and Retraining Program at Fort Calhoun Station, Unit No. 1 (FCS}. By letter dated October 7, 2016 (ADAMS Accession No. ML 16281A479), OPPD provided supplemental information, in response to a request for additional information (RAJ) from the U.S. Nuclear Regulatory Commission (NRC} staff dated September 20, 2016 (ADAMS Accession No. ML 16263A049). The NRC staff has reviewed the information provided in the licensee's submittal and supplemental information and determined that the following additional information is required in order to complete its formal review of OPPD's request: 1. Title 10 ofthe Code of Federal Regulations (10 CFR) Part 50, "Domestic Licensing of Production and Utilization Facilities," Section 50.2, "Definitions," provides the following definition for a Certified Fuel Handler: 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 OPPD CFH Training and Retraining Program for FCS was provided in the Attachment to OPPD's submittal. Section 2, "Terms and Definitions," of the OPPD CFH Training and Retraining Program, Subsection 2.4 defines "Inactive License" as "[t]he license held by an individual who attends and successfully completes the requirements of the LORT program but does not meet the on-shift hours requirement for maintaining an Active License. Refer to OP-AA-1 05-02, NRC Active License Maintenance, for additional guidance." a. Provide a definition of the acronym "LORT," as used in Section 2 of the document. b. Provide a copy of procedure OP-AA-105-02 for the NRC staff's review. Provide replacement page(s) for the OPPD CFH Training and Retraining Program reflecting any changes made to the document, in response to this RAJ, as necessary. OPPD Response The term/definition "Inactive License" was removed from the documentation. This eliminates the need to define LORT (Licensed Operator Requalification Training) or provide a copy of OP-AA-105-02, NRC Active License Maintenance. OP-AA-105-02 is no longer applicable and will be deleted once the Certified Fuel Handler program is approved.

LIC-17 -0030 Attachment 1 Page 2 General comment-Updates to FCS proposed Certified Fuel Handler Training and Retraining Program, Revision 0, have been made to (1) correct minor typographical errors, (2) update reference material, and (3) respond to requests made by this RAI. Attachment 2 to this RAI response is the updated FCS Certified Fuel Handler Training and Retraining Program, Revision 0. Revision bars have been added to track changes made as a result of the RAI response requested by the NRC. 2. 10 CFR 50.120, "Training and qualification of nuclear power plant personnel," paragraph (b)(3) states, in part: "The training program must be periodically evaluated and revised as appropriate ... 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." Section 3.5, "Program Evaluation," of the OPPD CFH Training and Retraining Program states, in part: "Any required changes to the program determined by the station oversight board, shall be incorporated into the program." Section 3.1, "General Guidelines," of the OPPD CFH Training and Retraining Program, Subsection 3.1. 7 states, in part: "Changes to the Certified Fuel Handler Training and Retraining Program may be made without NRC approval provided the changes are appropriately evaluated in accordance with applicable change processes ... " By letter dated October 7, 2016, OPPD provided supplemental information in response to an RAI from the NRC staff. The PRA [Probabilistic Risk Assessment] Operations and Human Factors Branch staff reviewed OPPD's responses to the staff's request for additional information and determined that additional information is required to complete the review. Provide information regarding what "applicable change processes" are being referred to in the abovementioned statement. In your response, clarify if evaluation of changes to the OPPD CFH Training and Retraining Program will be conducted in such manner that ensures that: (1) suitable proficiency in the performance of the program's activities is maintained, and (2) changes are documented in an accessible manner that will allow the NRC to verify the adequacy of the program in accordance with 10 CFR 50.120. Provide replacement page(s) for the OPPD CFH Training and Retraining Program reflecting any changes made to the document, in response to this RAI, as necessary. OPPD Response Section 3.1. 7, of Attachment 2, was deleted and replaced with new Section 3.6, titled "Evaluating Changes to the Certified Fuel Handler Training and Retraining Program." (Section 3.6 was modeled from Vermont Yankee (Reference 1) and Fitzpatrick (Reference 2) Certified Fuel Handler Training Program Descriptions, as well as Exelon Nuclear Certified Fuel Handler Training Program (TQ-DC-150) (Reference 3)).

Ll C-17 -0030 Attachment 1 Page 3 Section 3.6.2 states: Changes to the Certified Fuel Handler Training and Retraining Program may be made without prior NRC approval provided the changes are appropriately evaluated in accordance with Attachment 3, SAFSTOR Certified Fuel Handler Training Program Description Change Description and Review Form, follow FCS change processes, and the program continues to comply with ANSI N 18.1-1971, Selection and Training of Nuclear Power Plant Personnel, consistent with the level of hazard at the facility and to ensure the facility is maintained in a safe and stable condition. Because the Certified Fuel Handler program is based on a SAT, FCS may change elements without NRC approval as long as the following are applicable: a. Suitable proficiency in the performance of the program's activities is maintained; and b. 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. Section 3.6.3.1 states: Based on the above discussion, changes to the Certified Fuel Handler Training Program as described specifically in this document, and in all applicable attachments, as well as the Certified Fuel Handler Training Program Description, may be made without prior NRC approval provided they do not make changes which would remove or alter: a. The Certified Fuel Handler experience requirements stated in ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel, as specifically enumerated in Section 3.2.1 of this document. b. The requirements to apply a Systematic Approach to Training as described in Section 2.4 of this document and TQ-DC-FC-201, SAFSTOR Systematic Approach to Training (SAT). Attachment 2 to this RAI response is the updated FCS Certified Fuel Handler Training and Retraining Program, Revision 0. Revision bars have been added to track changes made as a result of the RAI response requested by the NRC. TQ-DC-FC-201, SAFSTOR Systematic Approach to Training (SAT), has been provided as Attachment 3 to this RAI as a reference document.

LIC-17-0030 Attachment 1 Page4 3. 10 CFR Part 55, "Operators' Licenses," Section 55.4, "Definitions," provides the definition of a systems approach to training (SAT}, which states, in part: Systems approach to training means a training program that includes the following five elements: (4) Evaluation of trainee mastery of the objectives during training. NUREG-1220, Revision 1, "Training Review Criteria and Procedures," January 1993 (ADAMS Accession No. ML 102571869}, Section 3.D, "SAT Element Evaluation," Subsection "SAT Element 4 (Trainee Evaluation)" states, in part, that trainees should be evaluated during all aspects of training to determine their progress toward mastery of job performance requirements. It further provides review guidance for each of the applicable program characteristics, including the following: "4.5 Training and task performance exemptions are objectively based." Section 3.3.3.1 of the OPPD CFH Training and Retraining Program states: "To maintain the Certified Fuel Handler qualification, the following requirements must be satisfied or they may be exempted per Step 3.1.8." Section 3.1.8, "Exemption of Training Requirements," Subsection 3.1.8.3 of the OPPD CFH Training and Retraining Program states: "No individual may be exempted from any two consecutive annual operating or two consecutive biennial written examinations." Provide information regarding what criteria can be used to exempt an individual from any single annual operating or biennial written examination (for example, if an individual who prepared the examination may be exempted from such a requirement). Further, clarify if exemptions may be granted from any of the requirements of Section 3.3.3.1. For example, clarify whether an individual may be exempted from the requirements of Subsection 3.3.3.1.2 ("Score -80 percent on the biennial written examination"), or Subsection 3.3.3.1.5 ("Stand the designated Certified Fuel Handler watch for a minimum of eight (8) hours per calendar quarter ... "). Provide replacement page(s) for the OPPD CFH Training and Retraining Program reflecting any changes made to the document, in response to this RAJ, as necessary. OPPD Response Exemptions from specific training requirements shall be administered in accordance with the process defined in TQ-DC-FC-201, SAFSTOR Systematic Approach to Training (SAT). Attachment 1 of TQ-FC-DC-201 provides the basis for training exemption (e.g. equivalent training, education, work experience, demonstrated proficiency), method used (e.g. review of training records, technical interview, proficiency examination) and description of rationale. Note: Section 3.1. 7 now discusses "Exemption of Training Requirements" in the updated TQ-FC-DC-1 01 submittal.

LIC-17-0030 Attachment 1 Page 5 Section 3.1.8.3 (section 3.1. 7.3 in the updated TQ-DC-FC-1 01 submittal) was incorrect. Revised Section 3.1.7.3 now reads, "An individual shall not be exempted from the annual operating or biennial written examinations unless that individual prepared the exam. No individual may be exempted from any two consecutive annual operating exams. No individual may be exempted from any two consecutive biennial written examinations." (Modeled from Vermont Yankee and Fitzpatrick Certified Fuel Handler Training Program Descriptions.) The following clarification on exemptions from the requirements of Section 3.3.3.1, were added/modified: a. Section 3.1.7.4: "The requirement for a medical examination shall not be exempted." b. Section 3.1.7.5: "The requirement for a Certified Fuel Handler who failed to maintain proficiency (stand watch for a minimum of eight (8) hours per calendar quarter) to regain qualified status by serving eight (8) hours of watch under the instruction of a qualified Certified Fuel Handler shall not be exempted. c. Section 3.1.7.6: "In addition, the requirement to successfully pass a biennial written examination or annual operating examination shall not be exempted except as noted in Section 3.1.7.3 above." Attachment 2 to this RAI response is the updated FCS Certified Fuel Handler Training and Retraining Program, Revision 0. Revision bars have been added to track changes made as a result of the RAI response requested by the NRC. 4. 10 CFR 50.2, "Definitions," provides the following definition for a Certified Fuel Handler: Certified fuel handler means, for a nuclear power reactor facility, a licensed operator who has qualified in accordance with a fuel handler training program approved by the Commission. 10 CFR 50.120, "Training and qualification of nuclear power plant personnel," states, in part: (b)(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 nuclear power plant personnel: (i) Non-licensed operator. 10 CFR Part 55.4, "Definitions," provides the definition of a systems approach to training which states, in part: Systems approach to training means a training program that includes the following five elements: (2) learning objectives derived from the analysis which describe desired performance after training. (3} Training design and implementation based on the learning objectives.

LIC-17-0030 Attachment 1 Page6 It is not clear how elements (2) and (3) of the SAT -based approach are addressed in the OPPD CFH Training and Retraining Program. Provide additional information regarding how the OPPD CFH Training and Retraining Program, as described in Section 3.2, "Initial Training," addresses elements (2) and (3) ofthe SAT-based approach. Provide replacement page(s} for the OPPD CFH Training and Retraining Program reflecting any changes made to the document, in response to this RAJ, as necessary. OPPD Response Attachment 2, Section 3.1, General Guidelines, Section 3.1.1 states: "The Certified Fuel Handler Training and Retraining Program contained herein describes the training program to be implemented by Omaha Public Power District (OPPD) to ensure the monitoring, handling, storage, and cooling of spent nuclear fuel is performed in a manner consistent with ensuring the public health and safety for OPPD facilities that have transitioned to a permanently defueled status." This describes the desired performance after training. Section 3.1, General Guidelines, Section 3.1.6 has been revised to clearly describe that the Certified Fuel Handler Training and Retraining Program is developed using the SAT process as described in Section 2.4 and TQ-DC-FC-201, SAFSTOR Systematic Approach to Training (SAT). Rewording of Section 3.1.6 clarifies how OPPD Certified Fuel Handler Training and Retraining Program addresses all elements of the SAT-based approach. (Modeled from Exelon Nuclear Certified Fuel Handler Training Program (TQ-DC-150), which references back to TQ-DC-105, Exelon Nuclear Training and Qualification at a Decommissioning Facility, to define the SAT -based approach.) Section 3.2, Initial Training, Section 3.2.2.1 has been revised to add the following: " ... A review of the DIF ratings for each task will be performed by Operations and Training personnel and management. Learning objectives will be derived from the analysis to describe the desired performance after training. Training materials will be designed based on learning objectives." (Modeled from Fitzpatrick Certified Fuel Handler Training Program Description.) Attachment 2 to this RAJ response is the updated FCS Certified Fuel Handler Training and Retraining Program, Revision 0. Revision bars have been added to track changes made as a result of the RAJ response requested by the NRC. 5. 10 CFR 50.2, "Definitions," provides the following definition for a Certified Fuel Handler: Certified fuel handler means, for a nuclear power reactor facility, a licensed operator who has qualified in accordance with a fuel handler training program approved by the Commission. 10 CFR 50.120, "Training and qualification of nuclear power plant personnel," states, in part: (b)(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 nuclear power plant personnel: (i) Non-licensed operator.

LIC-17-0030 Attachment 1 Page 7 10 CFR Part 55, "Operators' Licenses," Section 55.4, "Definitions," provides the definition of a SAT, which states, in part: Systems approach to training means a training program that includes the following five elements: (4) Evaluation of trainee mastery of the objectives during training. Although 10 CFR 50.120 does not address the specifics of how a non-licensed operator becomes qualified as a CFH through the Commission-approved fuel handler training program, regarding the relationship between qualification and training, the Commission stated the following in the Final Rule, "Training and Qualification of Nuclear Power Plant Personnel," published in the Federal Register on April26, 1993 {58 FR 21904): As stated in the preamble for the proposed rule, qualification in the context of this rule means job task qualification. The proposed rule contained the requirement that licensees and applicants develop, implement, and maintain a SAT -based training program to ensure that nuclear power personnel are qualified to perform the tasks of their jobs. Because licensees and applicants must comply with all applicable regulations, there should be no ambiguity concerning the fact that successful completion of a training program does not obviate the need to comply with any other training or qualification requirements imposed by other regulations or license conditions. This means that nuclear power plant personnel must also meet the licensees' initial job qualification requirements imposed as part of initial employment. Section 3.2.4, "Candidate Evaluation," subsection 3.2.4.7 states, in part: uTraining of current NRC-licensed Operators ... may be evaluated to determine if they satisfy all of the requirements of this training program, or if they only need to complete portions of this program to qualify as a Certified Fuel Handler." Further, subsection 3.2.4.7.1 states: "This evaluation will focus on the differences between the requirements of a Certified Fuel Handler and an NRC-licensed Operator to identify any additional training required prior to becoming a Certified Fuel Handler." Subsection 3.2.4.9 states, in part: "In general, the training of holders of Senior Reactor Operator licenses who are also qualified as Fuel Handling Supervisors will meet the qualification requirements for a Certified Fuel Handler. However, it is expected that some additional training requirements may arise as the plant transitions to a permanently shutdown and defueled configuration. < ... > The training history of each currently licensed Senior Reactor Operator who is identified as a candidate for a Certified Fuel Handler qualification will be separately evaluated to ensure that all the specific training requirements of the Certified Fuel Handler Training and Retraining Program are met." While Sections 3.2.4. 7 and 3.2.4.9 address the identification and evaluation of gaps between the training requirements for CFHs and the training of licensed Reactor Operators and Senior Reactor Operators, they do not describe how such gaps should be closed. Provide additional information regarding whether training to address any identified gaps between the individual's training history and the CFH training program requirements will be completed prior to certification of that individual as a Certified Fuel Handler.

LIC-17 -0030 Attachment 1 Page 8 Further, provide additional information identifying the position of the individual responsible for approving the basis for evaluations qualifying an individual as a Certified Fuel Handler. Provide replacement page(s) for the OPPD CFH Training and Retraining Program reflecting any changes made to the document, in response to this RAI, as necessary. OPPD Response The process for identifying training requirements for the Certified Fuel Handler Training and Retraining program, utilizing the SAT process, began in June, 2016 and was completed in December 2016. Referencing TQ-AA-221, Exelon Nuclear Training-Analysis Phase, and utilizing TQ-DC-FC-201, SAFSTOR Systematic Approach to Training (SAT), Attachment 3, Job Analysis Process Flowchart, and Attachment 4, Job Analysis Data Sheet, current accredited, SAT-based, Senior Reactor Operator/Licensed Operator job tasks were reviewed by a team of Licensed Operator Training personnel and Operations Senior Reactor Operator/Licensed Operators for applicability to the Certified Fuel Handler program. TQ-DC-FC-201, Attachment 3, Job Analysis Process Flowchart, was completed for each selected task, identifying the "Difficulty, Importance, and Frequency", recommended training setting, selection for training (initial/continuing), and evaluation if task was a "Must Perform" based on a decommissioned plant. Program Owner (Operations) approval was obtained in December 2016. Following completion of the Certified Fuel Handler Job Task Analysis, a "Task-to-Training Material Matrix" was completed, tying approved Certified Fuel Handler tasks, to existing Training Objectives, Lesson Plan material, and test questions. (Note, the Operations training programs developed for SAFSTOR, with the exception of Fire Brigade, were all based on accredited training programs with SAT developed objectives and are the baseline SAFSTOR training programs.) Gap (or "transition") analysis was completed between the existing accredited Licensed Operator programs for Senior Reactor Operators and Licensed Operators, and those required for Certified Fuel Handler. Gap (transition) training is unique to the individual based on their qualifications and experience. For example, Gap (transition) analysis identified additional training for Licensed Operators on Emergency Plan implementation and execution. This training is required to be qualified as a Certified Fuel Handler, but currently not required to be trained and evaluated on as a Licensed Operator. Gap (transition) training for all individuals qualifying to a SAFSTOR position is scheduled to be completed by the end of April, 2017. Section 3.2.4.1 0 states "Training to address any identified gaps between the individual's training history and the Certified Fuel Handler training program requirements will be completed prior to certification as a Certified Fuel Handler. TQ-DC-FC-101-1000, Attachment 4, FCS Certified Fuel Handler Certification Guide, approved by the Operations Manager, documents completion of training and certification as a Certified Fuel Handler." (Modeled from Fitzpatrick Certified Fuel Handler Training Program Description.)

LIC-17-0030 Attachment 1 Page 9 Section 3.1.7.1 states The Decommissioning Plant Manager (or designee) may exempt an individual from a specific training requirement based upon the individual's depth of experience and previous training. Such exemptions, including the basis, shall be documented." TC-DC-FC-201, Attachment 1, Training Exemption Form, requires an exemption to be approved by the Discipline Lead Instructor, Training Manager SAFSTOR, and the Decommissioning Plant Manager (or Designee). Attachment 2 to this RAI response is the updated FCS Certified Fuel Handler Training and Retraining Program, Revision 0. Revision bars have been added to track changes made as a result of the RAI response requested by the NRC. 6. Section 3.3.2, "Course Schedule," Subsection 3.3.2.5, of the OPPD CFH Training and Retraining Program states, in part: "Areas examined are described in Appendices A and B for the written and operating examinations, respectively." The OPPD CFH Training and Retraining Program does not contain Appendices A and B. Clarify if the abovementioned statement should instead refer to Attachments 1 and 2, instead of Appendices A and B. Provide replacement page(s) for the OPPD CFH Training and Retraining Program reflecting any changes made to the document, in response to this RAI, as necessary. OPPD Response Appendices A and B discussed in Section 3.3.2.5 was written in error. Section 3.3.2.5 has been corrected and now states "Areas examined are described in Attachments 1 and 2 for the written and operating examinations, respectively." Attachment 2 to this RAI response is the updated FCS Certified Fuel Handler Training and Retraining Program, Revision 0. Revision bars have been added to track changes made as a result of the RAI response requested by the NRC. 7. 10 CFR 50.120, "Training and qualification of nuclear power plant personnel," states, in part: "(b)(3) ... 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." Section 3.5, "Program Evaluation," of the OPPD CFH Training and Retraining Program states, in part: "These assessments will also evaluate applicability of industry operating experience, regulations, and quality assurance requirements." Provide additional information regarding whether changes to the facility, procedures, regulations, and quality assurance requirements will be included in the periodic evaluation of the OPPD CFH Training and Retraining Program at FCS and revision thereof, as appropriate. Provide replacement page(s) for the OPPD CFH Training and Retraining Program reflecting any changes made to the document, in response to this RAI, as necessary.

LIC-17-0030 Attachment 1 Page 10 OPPD Response Section 3.5 was revised and now states: "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. As part of the training process, routine assessments of the effectiveness and accuracy of the training program are conducted by appropriate management personnel at the facility in a permanently defueled condition during and at the end of each two (2) year training cycle. These routine assessments ensure that the FCS Certified Fuel Handler Training and Retraining Program: 1) contains the guidance necessary to ensure compliance with the requirements of the Systematic Approach to Training process as defined in 10 CFR 50.120, and 2) is revised to incorporate changes to the program, as appropriate, to reflect industry experience, changes to the facility, procedures, regulations, and quality assurance requirements. Evaluation results shall be reviewed by the FCS Training Oversight Committee (TOC) as defined in TC-DC-FC-201, SAFSTOR Systematic Approach to Training. The FCS Training Oversight Committee will verify the resolution of any discrepancies identified by the evaluation. Any required changes to the program determined by the FCS Training Oversight Committee shall be incorporated into the program." (Section 3.5 was modeled from Vermont Yankee Certified Fuel Handler Training Program Description, as well as Exelon Nuclear Certified Fuel Handler Training Program (TQ-DC-150)) Attachment 2 to this RAI response is the updated FCS Certified Fuel Handler Training and Retraining Program, Revision 0. Revision bars have been added to track changes made as a result of the RAI response requested by the NRC.

LIC-17-0030 Attachment 1 Page 11

References:

1. U.S.NRC (J. S. Kim) to Entergy Nuclear (Site Vice President) "Vermont Yankee Nuclear Power Station-Review of Certified Fuel Handler Training and Retraining Program (TAC NO. MF2988), dated October 1, 2014(ML14162A209} 2. U.S.NRC (D. L. Render) to Entergy Nuclear Operations (Vice President, Operations) "James A. Fitzpatrick Nuclear Power Plant -Approval of the Certified Fuel Handler Training and Retraining Program (CAC NO. MF7282)," dated October 17, 2016 (ML 16259A347) 3. U.S. NRC (J. G. Lamb) to Exelon Nuclear (B. C. Hanson) "Oyster Creek Nuclear Generating Station; Clinton Power Station, Unit No. 1; And Quad Cities Nuclear Power Station, Units 1 And 2 -Approval of Certified Fuel Handler Training and Retraining Program (CAC NOS. MF8109, MF8138, MF8139, AND MF8140)," dated September 6, 2016 (ML 16222A787)

LIC-17 -0030 Attachment 2 Page 1 ATTACHMENT 2 CERTIFIED FUEL HANDLER TRAINING AND RETRAINING PROGRAM, REVISION 0 TQ-DC-FC-101 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT N0.1 DOCKET NO. 50-285 FCS TQ-DC-FC-1 01 Revision 0 Page 1 of 18 CERTIFIED FUEL HANDLER TRAINING AND RETRAINiNG PROGRAM 1. PURPOSE To outline development of a Certified Fuel Handler training and qualification program for the Omaha Public Power District's Fort Calhoun Station (FCS) nuclear facility that is permanently shutdown and defueled. 2. TERMS AND DEFINITIONS 2.1. Certified Fuel Handler-As defined in 10 CFR 50.2, (Reference 5.1 ), 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 U.S. Nuclear Regulatory Commission (NRC). 2.2. Non-Licensed Operator-An operator who works in the plant under the direction and supervision of control room and/or operations management personnel in support of plant operations. Non-Licensed Operators operate, control, and monitor plant equipment outside the control room and may also be assigned auxiliary duties such as fire brigade member, medical response team member, or radiological emergency team member. 2.3. NRC-Licensed Operator-An individual who possesses an active or inactive NRC operator license or Senior Reactor Operator license pursuant to 10 CFR 55, "Operators' Licenses." 2.4. Svstems Approach to Training (SAT)-The SAT process contains the following elements: 2.4.1. Systematic analysis of the jobs to be performed. 2.4.2. Learning objectives derived from the analyses which describe desired performance after training. 2.4.3. Training design and implementation based on the learning objectives. 2.4.4. Evaluation of trainee mastery of the objectives during training. 2.4.5. Evaluation and revision of the training based on the performance of trained personnel in the job setting.

3. MAIN BODY 3.1. General Guidelines TQ-DC-FC-1 01 Revision 0 Page 2 of 18 3.1.1. The Certified Fuel Handler Training and Retraining Program contained herein describes the training program to be implemented by Omaha Public Power District (OPPD) to ensure the monitoring, handling, storage, and cooling of spent nuclear fuel is performed in a manner consistent with ensuring the public health and safety for OPPD facilities that have transitioned to a permanently defueled status. 3.1.2. The Certified Fuel Handler Training and Retraining 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 qualification (e.g., medical). The program shall comply with ANSI N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel" (Reference 5.7), as specified in Technical Specifications Section 5.3.1 and be consistent with level of hazard at the facility and to ensure the facility is maintained in a safe and stable condition. Based on the permanently defueled status, as committed to under 10 CFR 50.82(a)(1), the Certified Fuel Handlers will not be trained as NRC-Licensed Operators; however, candidates in the training program will meet minimum operator experience requirements of the applicable ANSI/ANS standards as specified in the facility's Technical Specifications. 3.1.3. The Certified Fuel Handler Training and Retraining Program will become effective upon: 3.1.3.1 Approval of the Certified Fuel Handler Training and Retraining Program by the NRC; and 3.1.3.2 NRC approval of an amendment to the facility operating license eliminating requirements for NRC Licensed Senior Reactor Operators and Reactor Operators, and the requirement for the associated 10 CFR 55 Training Program. 3.1.4 Training of personnel can be conducted prior to the Certified Fuel Handler Training and Retraining Program being approved by the NRC or prior to the training program effective date. 3.1.5 The Certified Fuel Handler Training and Retraining Program is not accredited with the National Academy for Nuclear Training in accordance with ACAD 02-002, "The Process for Accreditation of Training in the Nuclear Power Industry" (Reference 5.13). Although the program is not accredited, a SAT process will be applied to the Certified Fuel Handler Training and Retraining Program. The program utilizes applicable guidelines of NUREG-1220, "Training Review Criteria and Procedures," Revision 1 (Reference 5.5) as applicable to a permanently defueled plant.

TQ-DC-FC-1 01 Revision 0 Page 3 of 18 3.1.6 The Certified Fuel Handler Training and Retraining Program is developed using the SAT process as described in Section 2.4 and TQ-DC-FC-201, SAFSTOR Systematic Approach to Training (SAT), (Reference 5.17). 3.1.7 Exemption of Training Requirements 3.1.7.1 The Decommissioning Plant Manager (or designee) may exempt an individual from a specific training requirement based upon the individual's depth of experience and previous equivalent training. Such exemptions, including the basis, shall be documented. 3.1.7.2 Exemptions from specific training requirements shall be administered in accordance with the process defined in TQ-DC-FC-201, SAFSTOR Systematic Approach to Training (SAT), (Reference 5.17). 3.1.7.3 An individual shall not be exempted from the annual operating or biennial written examinations unless that individual prepared the exam. No individual may be exempted from any two consecutive annual operating exams. No individual may be exempted from any two consecutive biennial written examinations. 3.1.7.4 The requirement for a medical examination shall not be exempted. 3.1.7.5 The requirement for a Certified Fuel Handler who failed to maintain proficiency (stand watch for a minimum of eight (8) hours per calendar quarter) to regain qualified status by serving eight (8) hours of watch under the instruction of a qualified Certified Fuel Handler shall not be exempted. 3.1. 7.6 In addition, the requirement to successfully pass a biennial written examination or annual operating examination shall not be exempted except as noted in Section 3.1. 7.3 above. 3.1.8 The Certified Fuel Handler Training and Retraining Program consists of an initial training program and a requalification training program. 3.2 Initial Training 3.2.1 Eligibility Requirements 3.2.1.1 Candidates for enrollment in the Certified Fuel Handler Initial Training program shall meet ANSI N18.1-1971 (Reference 5. 7) requirements for the qualification and training of plant personnel, as specified in Technical Specification 5.3.1. 3.2.1.2 Specifically, at the time of appointment to the Certified Fuel Handler position, the candidate shall have: 3.2.1.2.1 High school diploma or equivalent.

TQ-DC-FC-1 01 Revision 0 Page 4 of 18 3.2.1.2.2 A minimum of two years power plant experience, in which one year is nuclear power plant experience. At least 6 months of the nuclear experience shall be at the facility. 3.2.1.2.3 Possess a high degree of manual dexterity and mature judgment. 3.2.1.3 For the purposes of the Certified Fuel Handler Training program the definition of nuclear power plant experience listed in ANSI N18.1-1971 (Reference 5.7), as specified in Technical Specification 5.3.1, is amended to include nuclear power plant experience acquired at a defueled reactor site which has spent nuclear fuel stored in its Spent Fuel Pool (SFP). 3.2.2 Fundamentals Training 3.2.2.1 The fundamentals training phase of the initial Certified Fuel Handler Training Program consists of lecture, and/or self-study of topics appropriate to the monitoring, handling, storage, and cooling of spent nuclear fuel. The lecture method of instruction is the training of individual topics by classroom presentation. Self-study is training accomplished by the student through the independent study of texts, handouts, and other materials. Selection of topics will be based on a job analysis for the Certified Fuel Handler tasks and functions. The job analysis will be conducted by an incumbent Senior Reactor Operator/Certified Fuel Handler, training Subject Matter Expert and Site Decommissioning Transition Planning Organization Operations Lead, in accordance with the requirements of TQ-DC-FC-201, SAFSTOR Systematic Approach to Training (SAn (Reference 5.17). The procedure outlines a graded approach to evaluating job tasks and includes Difficulty, Importance, and Frequency (DIF) ratings for each new job task. A review of the DIF ratings for each task will be performed by Operations and Training personnel and management. Learning objectives will be derived from the analysis to describe the desired performance after training. Training materials will be designed based on learning objectives. Depending on an analysis of the candidate's background, study may be used for up to 100% of the course material. A comprehensive exam at the end of the course will provide assurance of mastery of the skills, knowledge, and abilities required for successful performance of Certified Fuel Handler job and associated tasks. 3.2.2.2 Fundamental topics will include thermodynamics, heat transfer, fluid mechanics, radiological safety principles and monitoring, electrical theory, mechanical components operation, facility/system design and function, and facility administrative and safety procedures, as appropriate for the current plant status. 3.2.3 On-The-Job Training (OJT) 3.2.3.1 The On-The-Job training phase of the initial Certified Fuel Handler Training Program includes hands-on training of shift operations such as shift turnover, shift record keeping, removal and return of equipment to service, and specified watch standing activities. Watch standing activities include on-the-job training in operation of systems/components used to provide handling, storage, cooling, and TQ-DC-FC-1 01 Revision 0 Page 5 of 18 monitoring of the fuel; normal, abnormal, and emergency procedures; accident analysis; Emergency Plan; facility license; and the content, bases, and importance of Technical Specifications. On-The-Job training will be conducted in accordance with the requirements of TQ-AA-203, "On-The-Job Training and Task Performance Evaluations" (Reference 5.15), or Fort Calhoun Station equivalent procedures, which provides the requirements for the development, implementation, and evaluation of, and qualification requirements for, OJT, Task Performance Evaluation (TPE), and Job Performance Measure (JPM) administration. 3.2.3.2 A minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of on-shift watches under the instruction of a Certified Fuel Handler must be completed as part of the qualification process. 3.2.4 Candidate Evaluation 3.2.4.1 A comprehensive final examination shall be administered at the end of the initial training program. Areas examined are described in Attachments 1 and 2 for the written and operating examinations respectively. 3.2.4.2 The written examination requires a minimum score of 80 percent to pass. 3.2.4.3 The operating examination will consist of JPMs. Passing criteria for an individual JPM is that the examinee successfully completes the assigned task in accordance with the governing procedure without missing any critical steps. Missed or incorrectly performed critical steps are the bases for JPM failure. Critical tasks for a JPM will be as defined in NUREG-1 021, "Operator Licensing Examination Standards for Power Reactors" Revision 11 (Reference 5.6) as applicable to permanently defueled facility. 3.2.4.4 Each JPM will be scored on a pass/fail basis. The candidate must pass at least 80 percent of the administered JPMs to successfully pass the operating examination. 3.2.4.5 An individual who fails to pass either the written or operating examination shall not perform Certified Fuel Handler duties until the individual has completed a remedial training program and passes an appropriate re-examination. Only those portions of the original examination that were failed need to be re-examined (i.e., written or operating exam). 3.2.4.6 Any exemption for an individual from specific training requirements will be in accordance with Section 3.1.7 of this procedure and approved per the Decommissioning Plant Manager (or designee). 3.2.4.7 Training of current NRC-Licensed Operators (i.e., individuals who hold a current NRC issued Reactor Operator or Senior Reactor Operator License) may be evaluated to determine if they satisfy all of the requirements of this training program, or if they only need to complete portions of this program, to qualify as a Certified Fuel Handler.

TQ-DC-FC-1 01 Revision 0 Page 6 of 18 3.2.4.7.1 This evaluation will focus on the differences between the requirements of a Certified Fuel Handler and a NRC-Licensed Operator to identify any additional training required prior to becoming a Certified Fuel Handler. 3.2.4.7.2 Examples may include an examination on Technical Specifications, fuel handling, and administrative controls required to perform the Certified Fuel Handler function. 3.2.4.7.3 Any exemption for current NRC-Licensed Operators from specific training requirements will be in accordance with Section 3.1. 7 of this procedure and approved per the Decommissioning Plant Manager (or designee). 3.2.4.8 The Certified Fuel Handler Training and Retraining Program allows for the evaluation of other facility personnel to determine if portions of the required training have already been completed and therefore may be exempted. The evaluation will concentrate on required areas to determine if the previous training and qualification/examination were equivalent to that required for a Certified Fuel Handler. 3.2.4.9 In general, the training of individuals who hold a Senior Reactor Operator license, and who are also qualified as Fuel Handling Supervisors, will meet the qualification requirements for a Certified Fuel Handler. However, it is expected that some additional training requirements may arise as the plant transitions to a permanently shutdown and defueled configuration. These additional training requirements may arise from changes to plant systems or procedures associated with Spent Fuel Pool operations. Therefore, the training requirements will be specifically identified and enumerated using the SAT process as described in Section 3.1.6. The training history of each currently licensed Senior Reactor Operator who is identified as a candidate for a Certified Fuel Handler qualification will be separately evaluated to ensure that all the specific training requirements of the Certified Fuel Handler Training and Retraining Program are met. 3.2.4.1 0 Training to address any identified gaps between the individual's training history and the Certified Fuel Handler training program requirements will be completed prior to certification as a Certified Fuel Handler. TQ-DC-FC-1 01-1 000, Attachment 4, FCS Certified Fuel Handler Certification Guide (Reference 5.18), approved by the Operations Manager, documents completion of training and certification as a Certified Fuel Handler." 3.2.4.11 Any missed training or examination must be made up within 90 days of the missed training activity. Remediation for identified performance deficiencies, or exam failures, will be conducted in accordance with TQ-DC-FC-201, SAFSTOR Systematic Approach to Training (SAT) (Reference 5.17).

3.2.5 Qualifications 3.2.5.1 All candidates shall satisfy the following requirements: TQ-DC-FC-1 01 Revision 0 Page 7 of 18 3.2.5.1.1 Complete the initial Certified Fuel Handler Training Program or have the requirement exempted per Section 3.1. 7. 3.2.5.1.2 80 percent on a written examination. 3.2.5.1.3 80 percent of the administered JPMs on the operating examination. 3.2.5.1.4 Pass a medical examination by a physician to determine that the candidate's medical condition is not such that it might cause operational errors that could endanger other plant personnel or the public health and safety. 3.3 Retraining Program 3.3.1 Eligibility Requirements Candidates for enrollment in the Certified Fuel Handler Retraining Program (aka: Requalification Training Program) shall have successfully completed the initial Certified Fuel Handler Training Program. All qualified Certified Fuel Handlers will participate in the retraining program. 3.3.2 Course Schedule 3.3.2.1 The retraining phase of the Certified Fuel Handler Training and Retraining Program shall be administered in a biennial training cycle. This cycle includes annual operating examinations and biennial written examination. 3.3.2.2 The Certified Fuel Handler retraining phase consists of lecture 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. 3.3.2.3 A retraining plan will be developed by a training committee, chaired by the Decommissioning Plant Manager (or designee). 3.3.2.4 The training plan will be developed utilizing the SAT process described in Section 2.4. Retraining will typically include a review of changes associated with the facility and procedures, regulations, and quality assurance requirements, as well as problem areas associated with the monitoring, handling, storage, and cooling of nuclear fuel, and selected topics from the initial training program. 3.3.2.5 Participants in the Certified Fuel Handler retraining phase of the program must pass a biennial written examination and an annual operating examination to maintain their TQ-DC-FC-1 01 Revision 0 Page 8 of 18 qualification. Areas examined are described in Attachments 1 and 2 for the written and operating examinations, respectively. 3.3.2.6 The written examination requires a minimum score of 80 percent to pass. 3.3.2.7 The operating examination will consist of JPMs and each JPM will be scored on a pass/fail basis. Passing criteria will be 2: 80 percent of the administered JPMs on the examination. 3.3.2.8 Passing criteria for an individual JPM is that the examinee successfully completes the assigned task in accordance with the governing procedure without missing any critical steps. Missed or incorrectly performed critical steps are the bases for JPM failure. Critical tasks for a JPM will be as defined in NUREG-1021, "Operator Licensing Examination Standards for Power Reactors" Revision 11 (Reference 5.6) as applicable to permanently defueled facility. 3.3.2.9 Periodic written and/or operating exams may be administered during the retraining cycle to assess student knowledge and training effectiveness. 3.3.2.1 0 An individual who fails to pass either the comprehensive biennial written or annual operating examination shall not perform Certified Fuel Handler duties until a remedial training program is completed and an appropriate re-examination is passed. Only those portions of the examination that were originally failed need to be successfully re-examined prior to restoring qualifications (i.e., written or operating exam). 3.3.3 Maintenance of Certified Fuel Handler Qualifications 3.3.3.1 To maintain the Certified Fuel Handler qualification, the following requirements must be satisfied or they may be exempted per Section 3.1. 7. 3.3.3.1.1 Complete all required Certified Fuel Handler retraining. 3.3.3.1.2 Score.:::. 80 percent on the biennial written examination. 3.3.3.1.3 Pass.:::. 80 percent of the administered JPMs on the annual operating examination. 3.3.3.1.4 Pass a biennial medical examination by a physician to determine that the Certified Fuel Handler's medical condition is not such that it might cause operational errors that could endanger other plant personnel or the public health and safety. 3.3.3.1.5 Stand the designated Certified Fuel Handler watch for a minimum of eight (8) hours per calendar quarter. A Certified Fuel Handler who fails to meet this time requirement can regain qualified status by serving eight (8) hours of watch under the instruction of a qualified Certified Fuel Handler. The time under instruction should include a review of the spent fuel pool cooling system and shift turnover procedures.

TQ-DC-FC-1 01 Revision 0 Page 9 of 18 3.3.3.2 An individual who fails to meet any of the requirements for maintaining the Certified Fuel Handler qualification shall be removed from all duties associated with that position until such time as the discrepancies can be resolved. Manager-Operations shall be notified of the individual's removal and subsequent status. 3.4 Missed Training Any missed training or examination must be made up within 90 days of the missed training activity. Remediation for identified performance deficiencies, or exam failures, will be conducted in accordance with TQ-DC-FC-201, SAFSTOR Systematic Approach to Training (SAT) (Reference 5.17). If required training or examination is not completed within the specified makeup period, the Certified Fuel Handler shall be suspended from Certified Fuel Handler duties, pending successful completion of the missed training or examination. 3.5 Program Evaluation 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. As part of the training process, routine assessments of the effectiveness and accuracy of the training program are conducted by appropriate management personnel at the facility in a permanently defueled condition during and at the end of each two (2) year training cycle. These routine assessments ensure that the FCS Certified Fuel Handler Training and Retraining Program: 1) contains the guidance necessary to ensure compliance with the requirements of the Systematic Approach to Training process as defined in 10 CFR 50.120 (Reference 5.2), and 2) is revised to incorporate changes to the program, as appropriate, to reflect industry experience, changes to the facility, procedures, regulations, and quality assurance requirements. Evaluation results shall be reviewed by the FCS Training Oversight Committee (TOG) as defined in TC-DC-FC-201, SAFSTOR Systematic Approach to Training (SAT) (Reference 5.17). The FCS Training Oversight Committee will verify the resolution of any discrepancies identified by the evaluation. Any required changes to the program determined by the FCS Training Oversight Committee shall be incorporated into the program.

TQ-DC-FC-1 01 Revision 0 Page 10 of 18 3.6 Evaluating Changes to the Certified Fuel Handler Training and Retraining Program 3.6.1 Section 10 CFR 50.2 requires Certified Fuel Handlers to be qualified in accordance with a NRC approved training program. In addition, the Certified Fuel Handler Training and Retraining Program is based on a SAT as required by 10 CFR 50.120 (References 5.1 and 5.2). 3.6.2 Changes to the Certified Fuel Handler Training and Retraining Program may be made without prior NRC approval provided the changes are appropriately evaluated in accordance with Attachment 3, SAFSTOR Certified Fuel Handler Training Program Description Change Description and Review Form, follow FCS change processes, and the program continues to comply with ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel (Reference 5.7) consistent with the level of hazard at the facility and to ensure the facility is maintained in a safe and stable condition. Because the Certified Fuel Handler program is based on a SAT, FCS may change elements without NRC approval as long as the following are applicable: 3.6.2.1 Suitable proficiency in the performance of the program's activities is maintained; and 3.6.2.2 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. 3.6.3 Permissible Changes 3.6.3.1 Based on the above discussion, changes to the Certified Fuel Handler Training Program as described specifically in this document, and in all applicable attachments, as well as the Certified Fuel Handler Training Program Description, may be made without prior NRC approval provided they do not make changes which would remove or alter: 3.6.3.1.1 The Certified Fuel Handler experience requirements stated in ANSI N 18.1-1971, Selection and Training of Nuclear Power Plant Personnel (Reference 5.7), as specifically enumerated in Section 3.2.1 of this document. 3.6.3.1.2 The requirements to apply a Systematic Approach to Training as described in Section 2.4 of this document and TQ-DC-FC-201, SAFSTOR Systematic Approach to Training (SAT) (Reference 5.17). 3.6.3.2 Attachment 3 -SAFSTOR Certified Fuel Handler Training Program Description Change Description and Review Form, will be used to document and justify any TQ-DC-FC-1 01 Revision 0 Page 11 of 18 changes made to the Certified Fuel Handler Training Program without prior NRC approval. 4 DOCUMENTATION Records associated with the Certified Fuel Handler Training and Retraining Program will be retained in retrievable format until there is no longer a need for a Certified Fuel Handler position at the facility (i.e., all fuel permanently transferred to a dry fuel storage facility).

5 REFERENCES 5.1 10 CFR 50.2, "Definitions". TQ-DC-FC-1 01 Revision 0 Page 12 of 18 5.2 10 CFR 50.120, "Training and qualification of nuclear power plant personnel". 5.3 SECY-00-145, "Integrated Rulemaking Plan for Nuclear Power Plant Decommissioning," dated June 28, 2000. 5.4 Statements of Consideration for the "Decommissioning of Nuclear Power Reactors," Proposed Rule (60FR37374, dated July 20, 1995) and Final Rule (61 FR39278, dated July 29, 1996). 5.5 NUREG-1220, "Training Review Criteria and Procedures" Revision 1. 5.6 NUREG-1 021, "Operator Licensing Examination Standards for Power Reactor" Revision 11 . 5.7 ANSI N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel". 5.8 Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants". 5.9 NRC Safety Evaluation, "Vermont Yankee Nuclear Power Station -Review of Certified Fuel Handler Training and Retraining Program," October 1, 2014 (ADAMS Accession No. ML 14162A209). 5.10 NRC Safety Evaluation for Amendment 160 to License DPR-36, Maine Yankee, November 26, 1997 (ADAMS Accession No. 9712040233). 5.11 NRC Safety Evaluation for Certified Fuel Handlers Training and Retraining Program for Zion Nuclear Power Station Units 1 and 2, July 20, 1998 (ADAMS Accession No. 9807240263). 5.12 NRC Safety Evaluation, "Oyster Creek Nuclear Generating Station, Proposed approval of Certified Fuel Handler Training Program," January 29, 2016. 5.13 ACAD 02-002, "The Process for Accreditation of Training in the Nuclear Power Industry". 5.14 NEI 15-04, Rev. 0, "Guidelines for a Certified Fuel Handler Training and Retraining Program" -(Draft).:. 5.15 TQ-AA-203, Exelon On-The-Job Training and Task Performance Evaluations 5.16 TQ-DC-150, Exelon Certified Fuel Handler Training Program 5.17 TQ-DC-FC-201, SAFSTOR Systematic Approach to Training (SAT)

TQ-DC-FC-1 01 Revision 0 Page 13 of 18 5.18 TQ-DC-FC-101-1000, FCS SAFSTOR Certified Fuel Handler Training Program Description 6 ATTACHMENTS 6.1 Attachment 1 -Written Examination Areas Certified Fuel Handler Training and Retraining Program 6.2 Attachment 2 -Operating Examination Areas Certified Fuel Handler Training and Retraining Program 6.3 Attachment 3-SAFSTOR Certified Fuel Handler Training Program Description Change Description and Review Form Written Examination Areas Certified Fuel Handler Training and Retraining Program Page 1 of 1 TQ-DC-FC-1 01 Revision 0 Page 14 of 18 The written examination shall include a sample of the following aspects of the Certified Fuel Handler position: (1) Design, function, and operation of systems used in handling, storage, cooling, monitoring of nuclear fuel, and auxiliary support systems. (2) Purpose and operation of the radiation monitoring systems. (3) Radiological safety principles and procedures including radiation hazards that may arise during normal, maintenance, and abnormal activities. (4) Principles of heat transfer, thermodynamics, and fluid mechanics as they apply to fuel handling, storage, cooling, and monitoring. (5) Conditions and limitations of facility license, including content, basis and importance of Technical Specifications. (6) Assessment of facility condition and selection of appropriate procedures during normal, abnormal and emergency situations. (7) Fuel handling facilities and procedures Operating Examination Areas Certified Fuel Handler Training and Retraining Program Page 1 of 1 TQ-DC-FC-1 01 Revision 0 Page 15 of 18 The operating examination will consist of Job Performance Measures and shall include a sample of the following aspects of the Certified Fuel Handler duties and tasks: (1) Evaluate annunciators; valve, pump, and breaker status indicators; and instrument readings as necessary to determine/perform appropriate remedial actions. (2) Evaluate the ability to manipulate the controls required to obtain desired operating results during normal, abnormal, and emergency conditions. This includes the spent fuel pool cooling system and those auxiliary and emergency systems that could affect the release of radioactive material to the environment. (3) Evaluate radiation monitoring system readings, including alarm conditions, to determine appropriate actions. Such actions may include setting an alarm setpoint to monitor a release or determine appropriate remedial actions for an alarm condition. (4) Evaluate abnormal or emergency conditions to determine if the Emergency Plan for the facility should be implemented and, if implemented, evaluate performance of duties as required by the Emergency Plan. TQ-DC-FC-1 01 Revision 0 Page 16 of 18 SAFSTOR Certified Fuel Handler Training Program Description Change Description and Review Form Page 1 of 3 Description of Change(s): (Provide sufficient description of the detail of the changes so they can be effectively evaluated using the criteria established in Section 3.6 of TC-DC-FC-1 01, Certified Fuel Handler Training and Retraining Program, for permissible changes which do not require NRC approval.} Reason for Change(s): (Provide sufficient justification for why the changes are being made so they can be effectively evaluated using the criteria established in Section 3.6 of TC-DC-FC-101, Certified Fuel Handler Training and Retraining Program, for permissible changes which do not require NRC approval.) TQ-DC-FC-1 01 Revision 0 Page 17 of 18 SAFSTOR Certified Fuel Handler Training Program Description Change Description and Review Form Page 2 of3 Evaluation of Proposed Change(s): (Review Section 3.6 of TC-DC-FC-1 01, Certified Fuel Handler Training and Retraining Program, and then evaluate proposed changes against the following screening criteria.) YES NO Screening Criteria Does the proposed change violate or change the Certified Fuel Handler experience requirements stated in ANSI N18.1-1971, as specifically enumerated in Section 3.2.1 of this document? Does the proposed change significantly diminish or degrade the skills, knowledge, or ability required by the Certified Fuel Handler to oversee the safe conduct of decommissioning of Fort Calhoun Station based on the scope of SAFSTOR work? Does the proposed change significantly diminish or degrade the skills, knowledge, or ability required by the Certified Fuel Handler to oversee the safe handling and storage of spent fuel? Does the proposed change significantly diminish or degrade the skills, knowledge, or ability required by the Certified Fuel Handler to appropriately respond to credible plant emergencies that are not responded to by other qualified organizations such as offsite mutual aid? Does the proposed change significantly diminish the proficiency or the ability of the Certified Fuel Handler in the performance of assigned tasks or duties? Does the proposed change remove the requirement to use a Systematic Approach to Training (SAT) as described in Section 2.4 of this document and TQ-DC-FC-201, SAFSTOR Systematic Approach to Training (SAT)? 0 If ANY of the six screening questions above are answered "YES" then these proposed changes cannot be made without prior NRC approval. In this situation, contact Licensing to determine the process for soliciting NRC review and approval prior to implementing the proposed change(s). 0 If ALL of the six screening questions above are answered UNO" then these proposed changes may be made without prior NRC approval provided all of the below reviews are completed and approved. TQ-DC-FC-1 01 Revision 0 Page 18 of 18 SAFSTOR Certified Fuel Handler Training Program Description Change Description and Review Form Page 3 of 3 Justification: (Justify the selected response to the screening criteria questions. Attach additional sheets if needed.) Prepared By:------------------Date: _____ _ Required Reviews and Approvals: (Print, sign and date to indicate approval of change(s)). Manager -Operations Training (or designee) Date: Manager-Operations (or designee) Date: Licensing Manager (or designee) Date: (Completed forms shall be retained and stored in the plant's records management system.)

LIC-17-0030 Attachment 3 Page 1 ATTACHMENT 3 SAFSTOR SYSTEMATIC APPROACH TO TRAINING (SAT), TQ-DC-FC-201 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO. 1 DOCKET NO. 50-285 FCS TQ-DC-FC-201 Revision 0 Page 1 of45 SAFSTOR SYSTEMATIC APPROACH TO TRAINING (SAT) 1. PURPOSE 1.1. This procedure establishes the process for implementing a Systematic Approach to Training (SAT) during the SAFSTOR period. Implementation of this directive will help ensure that qualified personnel perform assigned tasks safely and efficiently while maintaining dose ALARA. The systematic approach will also help ensure work is performed within the bounds of all applicable regulations. 1.2. Implementation of this procedure is the responsibility of the Training Manager SAFSTOR (or designee), who will assign training duties to select members of the SAFSTOR organization. 1.3. Task level information is documented in Vision as needed to support program needs. 1.4. The SAFSTOR training programs are not accredited training programs. 2. TERMS AND DEFINITIONS 2.1 . Systematic Approach to Training: A systematic approach to training is used to determine a training need. Once the need has been determined, the SAT process is used to design and develop the objectives and supporting Jesson material. Lesson material is implemented using good instructional techniques and trainees are evaluated using valid evaluation methods to ensure that knowledge and skills are achieved. The SAT process is also used to maintain training programs current assuring that personnel are trained as needed to protect nuclear fuel and minimize station risk. SAT consists of the following elements: 2.1.1. Systematic analysis of the jobs to be performed. 2.1.2. Derivation of learning objectives that describe desired performance after training or knowledge or skills necessary to perform a task. Note: the training programs developed for SAFSTOR were all (Except Fire Brigade) based on accredited training programs with SAT developed objectives and are the baseline SAFSTOR training programs. 2.1.3. Design and delivery of training based on the learning objectives. 2.1.4. Evaluation process to verify that mastery of the learning objectives was achieved.

TQ-DC-FC-201 Revision 0 Page 2 of45 2.1.5. Evaluation and revision of the training program based on the job performance of the training personnel working in the specified job setting. 2.2. Graded Approach: Process by which the level of analysis, documentation, and actions needed to comply with a requirement are tempered by factors such as the relative importance to nuclear safety, station risk, the complexity of the job performance requirements and the value to business (cost-effectiveness). A graded approach to training encourages the application of techniques that allow the most efficient use of personnel and resources in training activities. 2.3. Individualized Instruction: A script of learning activities established for an individual or small group of individuals based on specific learning needs. Individualized instruction may be self-administered or may be a series of formal and/or informal training activities identified for the specific individual based on his/her needs to achieve specific learning activities. Following these activities may be a period of formal evaluation to verify learning objective achievement. 2.4. Exemption: The process of granting credit for previous training, education, work experience or demonstrated proficiency. 2.5. Job Performance Measure (JPM): A performance test containing one or more Critical Steps used to evaluate an individual's knowledge and proficiency for selected tasks. 2.6. Just In Time Training (JITT): Training provided to individuals or teams to prepare them for upcoming evolutions or to address emergent performance issues. 2.7. On-The-Job Training (QJT): A training method conducted at the job site, in the simulator or in the laboratory through which trainees accomplish job or task-related learning objectives. 2.8. Qualification: The skill, ability and knowledge required to be demonstrated before independently performing a specific activity. 2.9. qualified: An individual is considered qualified to work independently once they have completed all the requirements including training, evaluation, management authorization associated with a specified activity, and documentation of the qualification in the authorized qualification tracking system. 2.1 0. Qualification Assignment Template: A set of baseline qualifications for a work group. The template is a list of recommended personnel qualification by job assignment.

TQ-DC-FC-201 Revision 0 Page 3 of45 2.11. Subject Matter Expert (SMEl: A person who has attained a level of expertise by education, experience, or planVvendor task qualification. Subject matter experts are designated by line management and may provide training to others. 2.12. Task: A particular work assignment. In the terminology of training programs, the term "task" typically denotes a specific, narrowly defined activity that falls within the scope of a job category. However, since related tasks are often grouped for work assignment qualification, the term "task" may refer to one task, or a grouping of several related tasks. 2.13. Task Performance Evaluation (TPE): A formal evaluation conducted at the job site, in the simulator or in the laboratory, based on performance standards, to determine a trainee's ability to independently perform a task. 2.14. Training Requirement: Training (either one time or periodic) or other orientation activities that are required by specific procedural direction, regulatory requirements, directive, policy, or expectation that can be completed concurrently with fulfilling a function. That is, no qualification or qualification requirements exist for this training, and the training is not required to be completed before performing the work; yet formal tracking of completion is needed for compliance purposes or management expectations. 2.15. Training Program Descriptions (TPD): A document that describes the specific training requirements for both initial and continuing training. SAFSTOR programs share a generic TPD but maintain discipline specific supplements. 2.15.1. Addendums to the TPD include: 1. The initial training program content 2. The task-to-training matrix that includes the difficulty, importance and frequency (DIF) ratings and required periodicity requirements for re-training of each task. NOTE The Engineering training program is topic based therefore may use a systematic method other than DJF to determine training requirements. 3. The qualification matrix used by the discipline to determine qualification status of workers (maintained currently in PQD). 2.15.2. The TPD is a living document reflecting the changing dynamics of the site organization, Structures, Systems & Components (SSC), and processes.

2.15.3. 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 2.15.4. 2.16. 2.17. Addendums are maintained for the following programs: Chemistry SAFSTOR Program (Chern) Engineering SAFSTOR Program (Eng) Electrical Maintenance SAFSTOR Program (EM) TQ-DC-FC-201 Revision 0 Page 4 of45 Instrumentation and Controls Maintenance SAFSTOR Program (IC) Mechanical Maintenance SAFSTOR Program (MM) Radiation Protection SAFSTOR Program (RP) Shift Supervisor SAFSTOR Program (SS) Non Certified Operator SAFSTOR Program (NCO) Fuel Handler SAFSTOR Program (FH) Fire Brigade Certified Fuel Handler SAFSTOR Program (CFH) [NRC Approved-Standalone TPD] Training Request: A method used to communicate an identified or potential training need to the line or training organization (See 4.4.1). Topic List: Those qualifications adopted for use by engineering. The topics take the form of qualifications cards and are assigned at the discretion of engineering management. 3. RESPONSIBILITIES 3.1. Plant Manager Decommissioning (PMD) 3.1.1. Oversee implementation of site wide training programs, including supervisory training requirements. 3.1.2. Maintain organizational focus on using training to prepare workers for upcoming station work and to address performance shortfalls. The goal is to minimize risk to the organization and individual. 3.1.3. Determine the need to hold Training Oversight Committee (TOC) meetings. 3.1.4. Direct collateral training duty assignments of 'Assigned Discipline Training Providers' to personnel within the SAFSTOR organization.

3.1.5. 3.2. 3.2.1. 3.2.2. 3.2.3. 3.2.4. 3.2.5. 3.2.6. 3.2.7. 3.2.8. 3.3. 3.3.1. 3.3.2. 3.3.3. 3.3.4. 3.3.5. 3.3.6. 3.3.7. TQ-DC-FC-201 Revision 0 Page 5 of45 Review and approve the training budget request for the following year. Discipline Manager Oversee day to day implementation of 1 OCFR50.120 training programs and determine supervisory training requirements. Select the Discipline Lead Instructor for each 1 OCFR50.120 positional training program associated with their department. Assign discipline training providers for training needs analysis, design, development, and implementation. Determine the need for a Curriculum Review Committee (CRC) and acting as, or designating, a chairperson for the CRC, determine any changes to the discipline training content. Select resources to provide training to meet training program description requirements. Direct resources to attend training to meet training program description requirements. Represents their discipline during training audits and assessments with the help of the Training Manager. Direct the review of their training program task lists at least every two years until the fuel has been moved, and then every six years. Discipline Lead Instructor Review assigned discipline's planned work and ensure personnel assigned to do the work have the skill and knowledge to perform task safely. Consider risk to: industrial, radiological, hazardous material, financial and spent fuel safety. Review I Approve Task Lists. Review I Approve Training Requests. Determine training actions based on the graded approach to training. Maintain assigned Training Program Description (TPD) document. Conduct annual review of the training program backbone schedule. Review and approve exemptions and alternate qualifications.

TQ-DC-FC-201 Revision 0 Page 6 of 45 3.3.8. Verify qualifications prior to assigning work utilizing an approved qualification database or document. 3.3.9. Select Subject Matter Experts to develop and provide task specific training for personnel within assigned discipline. 3.3.1 0. Observe job incumbent activities to identify potential performance problems, evaluate the effectiveness of delivered training, and determine if additional training is needed. 3.3.11. Assign OJT/TPE providers for tasks requiring formal qualification. Ensure those assigned complete a read-and-sign lesson or CST on OJT/TPE implementation. 3.3.12. Assists the manager of the discipline during training audits and assessments with the help of the Training Manager. 3.4. Training Manager 3.4.1. Provide direct support to the operations manager to address operations and site training needs. 3.4.2. Provide direct support to the PMD to address cross-cutting site training needs. 3.4.3. Manage and oversee the implementation of the SAT process. 3.4.4. Monitor student and management feedback on implemented training. 3.4.5. Review and approve changes to training program descriptions. 3.4.6. Work with SAFSTOR directors, managers, and superintendents to identify SAFSTOR project performance gaps where training may be a solution. 3.4.7. Work with SAFSTOR directors, managers, and superintendents to identify future SAFSTOR project tasks of significant risk where training can be used to reduce risk. 3.4.8. Oversee and coordinate cross-cutting training program topics and qualifications in areas such as material handling, industrial safety, general radiation protection, tagging, OSHA regulations, fire watch, fire brigade, first aid/CPR, codes and standards, etc. 3.4.9. Oversee and mentor personnel assigned Discipline Lead Instructor, SME, or instructor duties. 3.4.1 0. Ensure performance of OJT/TPE providers is adequate. 3.4.11. Review and approve exemptions and alternate qualifications.

TQ-DC-FC-201 Revision 0 Page 7 of45 3.4.12. Perform periodic field observations to determine if skill or knowledge gaps exist, and take appropriate action to close identified gaps. 3.4.13. Represent training on root cause and apparent cause evaluation teams. 3.4.14. Assist disciplines during training audits and assessments. 3.5. SAFSTOR Instructor Staff 3.5.1. Perform duties of a Discipline Lead Instructor. 3.5.2. Assist the SAFSTOR organization in providing training based on application of SAT. 3.5.3. Conduct training as assigned. 3.5.4. Implement duties as described in the SAFSTOR instructor position job description. 3.5.5. SAFSTOR Instructor should have been qualified as instructor at some time in their career. If not, then implement an individual development plan to close any gaps. 3.6. SAFSTOR Supervisors/Superintendents 3.6.1. Verify qualifications prior to assigning work using a SAFSTOR approved qualification data source. At least one qualified worker will be assigned to jobs that require a qualification. Other workers on the job must be overseen by the qualified worker or a supervisor with a direct line of sight of the job when qualified work is being performed. 3.6.2. Select Subject Matter Experts to develop and provide job specific training for personnel within their organization. 3.6.3. Observe job incumbent activities to identify potential performance problems, evaluate the effectiveness of delivered training and determining if additional training is needed. 4. MAIN BODY 4.1. Program Oversight 4.1.1. FCS Training Oversight Committee (TOC) is chaired by the PMD and held at least once per calendar year and more often as determined by the PMD. The PMD determines the quorum. The agenda will contain at least the following: 1. Evaluation of past SAFSTOR performance to determine if training is needed to close performance gaps. Consider all levels of the organization.

TQ-DC-FC-201 Revision 0 Page 8 of 45 2. Evaluation of future SAFSTOR project tasks with medium to high risk to determine if timely training could reduce risk. Consider all levels of the organization. 3. Evaluation of training and job performance feedback from incumbents and management to determine if training is meeting the needs of the station. 4. Monitor the performance of supplemental workers to determine if contract providers are providing skilled and knowledgeable workers and supervisors. 5. Review changes in operating philosophy and regulatory requirements and their impact on training programs. A. NRC B. NEI C. OSHA D. ANI E. Others F. Assess demographics to identify long-term training needs. G. Assign resources (instructors and students) to complete training needed. 4.2. Training Administration 4.2.1. Entry Level Knowledge and Experience 1. Applicants or new hires must meet the entry level knowledge and experience requirements for any job classification specified in the American National Standard (ANSI) (e.g. Radiation Protection Manager). 2. Individuals not meeting the ANSI entry level requirements must have their independent work assignments restricted until the portion of their Individual Training Plan, or equivalent document, addressing that gap is completed. 4.2.2. Initial Training Requirements: Initial job specific training as described in the discipline-specific Training Program Description (TPD). 4.2.3. Verification of Qualification (Line Organization) 4.3. 4.3.1. 4.3.2. TQ-DC-FC-201 Revision 0 Page 9 of45 1. Workers will ensure training and qualifications requirements are met prior to performing a job task or an evolution by using PQD. At least one qualified worker will be assigned to jobs that require a qualification. Other workers on the job must be overseen by the qualified worker or a supervisor with a direct line of sight of the job when qualified work is being performed. 2. Supervisors shall only assign qualified individuals to independently perform tasks or functions. 3. If a worker who is not qualified to perform independent work has been assigned work that requires qualification, he/she should not perform the work and shall notify their supervisor immediately. 4. 1. 2. 3. For qualifications with an expiration date, ensure appropriate measures are taken to confirm worker qualification through the completion of the assigned task. Exemption/Alternate Qualification Review the following information to determine exemptions and alternate qualifications: Previous training, education, and experience records Knowledge based examination Skill based examinations (e.g., completion of TPE) Document exemption or alternate qualification on Attachment 1, Training Exemption Approval (or equivalent). 4.4. ANALYSIS 4.4.1. Training Requests 1. Training Requests are created electronically through the Training Center website using the Training Request form. 2. A paper version may be submitted using Attachment 9, Training Request Form -Paper Submittal, and shall be submitted to the training program owner. 3. The training program owner will work with the person requesting the training to accurately evaluate the request and determine if the request is in the discipline's job scope. Use Attachment 5, Graded Approach to SAT. 4. If the training request is in scope, then the training program owner will create a Training Request using ActionWay.

A. In Actionway, Select "New Action & Info Mgmt". TQ-DC-FC-201 Revision 0 Page 10 of 45 B. In the Action Type drop down menu, Select "Request for Training". 5. If training is not in scope for the discipline then determine if alternate action should be taken. 6. Training needs may come from the following sources: A. Changes in management expectations B. New tasks not already embedded in the TPD C. Human performance trending D. Management Feedback E. New or revised procedures or processes F. New or revised regulatory and industry documents G. New tools or equipment H. Operating experience I. Performance deficiencies J. Plant or equipment modifications K. Incumbent feedback L. Site corrective action process 7. The training program owner analyzes training requests to determine if there is a gap in required skills or knowledge and, if a gap exists, takes the appropriate action to close the gap. Actions taken are documented in a Training Request using ActionWay. 8. Attachments 2, 3, 4, and 5 are available to assist with this determination as necessary. 4.4.2. Maintaining the Task List 1. Maintain the Task List TQ-DC-FC-201 Revision 0 Page 11 of 45 A. The Training Program Description (TPD) contains discipline specific task list document. B. The list will include all tasks (including task number, task title, DIF analysis and training status: No Train, Train, Retrain, or Just In Time Train, and the associated training material. Refer to attachments 3 and 4, Job and Task Analysis Process, respectively. C. The list will include those topics chosen by management as qualifications in the SAFSTOR organization. D. REVIEW the task list and qualification structure at least every two years until the fuel has been moved, and then every six years to ensure the list contains the following: 1. All tasks performed by job incumbents. 2. Tasks selected for training, based on current training documents. E. Revise the task list as needed for changes such as: 1. Identification of new tasks(s) 2. Modification of existing tasks 3. Selection or de-selection of task(s) for training F. DOCUMENT changes to task lists on Attachment 3, Job Analysis Data Sheet. G. UPDATE as needed the VISION and qualification databases with the changes and justification for the changes. H. Approve the task list by approving the RA tracking the task list change or obtaining signatures on Attachment 3, Job Analysis Data Sheet. I. Update lesson material, JPM/TPE documents, exam items, long range training plans, qualification matrices, and curriculum affected by the task list change 4.5. DESIGN AND DEVELOPMENT 4.5.1. Use existing training material to meet training needs whenever possible.

TQ-DC-FC-201 Revision 0 Page 12 of 45 4.5.2. Modify existing training material as tasks change. 4.5.3. If no site training material exists for a new or modified task, then look outside the site for existing material. 4.5.4. Design and develop training materials if no existing material can be found. 4.5.5. 1. Consider the need for the following: 2. 3. 1. 2. 3. A. Job Performance Measures (JPM) B. Task Performance Evaluations (TPE) C. Modified or new objectives D. Exam items E. Appropriate training methods F. Supporting lesson material based on training method to be used Obtain lesson material approval from the line owner (Attachment 12, Lesson Plan Cover Sheet). Update the task to training list in the TPD and Vision as new material is developed and old material is retired. Creating Exam Items and Exams Test items shall support knowledge-based objectives and shall be updated to match SSC configuration and process controls prior to developing a new exam. Test items may be written, oral, or imbedded in CBT Test items may be in the following formats A. Multiple choice B. True/False C. Matching D. Short answer 4. Test items and exams are maintained in a secure location A. Limited access to exam bank computer TQ-DC-FC-201 Revision 0 Page 13 of 45 B. Limited access to the exam bank development area C. Use a security agreement process (see Attachment 8, Exam Security Agreement) for exam versions that will be used multiple times during an examination phase; such as bi-annual and annual exams. D. Exams shall be controlled by the proctor when not locked in the exam bank area. 5. Exams will ensure the student has mastered the topic NOTE: The Certified Fuel Handler TPD requires a complete reevaluation exam if a failure occurs. Refer to the CFH TPD for details. 6. Remedial exams must test the knowledge area that was failed using different exam items than those used in the original exam 4.5.6. Training Material Development Specifics 1. Determine best training method, such as: A Lecture B. CBT c. Demonstration/practice D. Guided discussion/case study E. Self-paced F. Walk through G. Dynamic Learning Activity H. Read and sign I. Shop brief 2. Develop material to support method selected, such as: A. Create learning objectives B. Sequence the objectives C. Determine prerequisites D. Select an evaluation method E. Include operational experience TQ-DC-FC-201 Revision 0 Page 14 of 45 F. Create lesson content that supports the objectives. G. Develop lesson support materials, such as: Handouts, Activities, PowerPoint, CBT, etc. H. Summarize the lesson I. Revise training material if necessary. Create a RA to track the revision process and make the change permanent. J. Obtain approval of the lesson material by line owner 4.6. IMPLEMENTATION 4.6.1. Scheduling training 1. Discipline-specific training will be scheduled by the line owner 2. Multi-discipline (cross cutting) training will be scheduled by the line owner responsible for the training topic and coordinated with the managers of affected groups. For example, material handling courses apply to multiple disciplines. 3. Designated instructor(s), SME(s), or Training Manager schedules the classroom/lab/equipment and other support items necessary to implement the training. 4. Vendor training is scheduled by the line organization that needs the training and controls the student resources. The Discipline Manager is responsible for implementation of the contract, is responsible for communication of time, date, location, and prerequisites for selected students, and will assign a mentor to the contract or vendor instructors to review site training expectations, site-specific procedure requirements, and other pertinent information. 4.6.2. Allocating Instructional and Student resources 1. Line owners allocate instructional resources to implement training specific to their discipline.

TQ-DC-FC-201 Revision 0 Page 15 of 45 A. Subject Matter Experts (SME) 1. Have expertise in the task or duty area to be trained 2. Maintain high standard of performance 3. Demonstrate solid SAFSTOR worker behaviors 2. Line owners allocate student time to scheduled training sessions 4.6.3. Implementing examination 1. Maintain examination security (required for exams that support qualification, licenses, or certifications) by performing the following actions: A. Maintain possession of the examination material at all times. 1. When not in use, ensure the written/oral examinations are secured (e.g., an envelope marked CONFIDENTIAL, placed into a secured, locked exam bag or store in a locked desk drawer or locked office) until all applicable personnel have completed the evaluation. 2. When the examination material is transferred from one individual to another, delivery by hand is the preferred method. 3. If examination material is sent through the mail, ensure the following requirements are met: 4.6.3.1 .A.3.1 . The examination material is in a sealed envelope identified as examination material (with the sender's signature covered by transparent tape across the seal). 4.6.3.1.A.3.2. The sealed envelope is placed in a mailing envelope marked PERSONAL and CONFIDENTIAL (DO NOT IDENTIFY THE MAILING ENVELOPE AS CONTAINING EXAM MATERIAL). 4.6.3.1.A.3.3. Electronic examinations are protected by using password-protected files or restricted folders. Passwords shall be sent via a message separate from the exam file message.

TQ-DC-FC-201 Revision 0 Page 16 of 45 B. MAINTAIN security requirements during examination process by establishing examination boundaries and controlling access to the exam area. C. ADMINISTER examinations in accordance with the following: 1. PROVIDE the same exam directions to all trainees (e.g., how to select a response, time limits, acceptable reference materials, etc.). 2. ADMINISTER the exam to all trainees under the same conditions (e.g., one exam per trainee, standard time limits, same references, etc.). 3. PROCTOR the examination to the extent necessary to ensure the exam is not compromised. (also refer to 4.5.5.4 'Test items and exams are .. .') 4.6.3.1.C.3.1. When answering trainee's questions regarding test items, PROVIDE only information that clarifies the test item and PROVIDE the clarifying information to all trainees. 4.6.3.1.C.3.2. If administering an oral exam, SCRIPT questions and answers and DOCUMENT trainee's response to each question. 4.6.3.1.C.3.3. COLLECT all copies of exams (including supporting material and scratch paper) that were distributed. 4.6.3.1.C.3.4. GRADE all exams using the examination key. 4.6.3.1.C.3.5. ENSURE all trainees are given the opportunity to review their examinations to ensure the correct answers to all questions are understood. D. DOCUMENT the trainees grade/total points on the exam cover sheet. 1. If the trainee fails to achieve a passing score, follow the guidance prescribed in 4.6.6, Remediation.

TQ-DC-FC-201 Revision 0 Page 17 of 45 4.6.4. Documenting training 4.6.5. 4.6.6. 1. For classroom, laboratory, and self-study training, DOCUMENT completion of training using a training attendance form (Attachment 7, SAFSTOR Training Attendance or similar). 2. For OJT, TPE, Mentoring, Job Performance Measures or other skill based session, DOCUMENT completion on the appropriate qualification document. 3. FORWARD all completed documentation of training/evaluations to the responsible Lead instructor for filing and data entry into POD. Examples of training documentation include, but are NOT limited to, the following items: 1. 2. 3. 1. A. Signed and implemented Lesson Plans B. Attendance forms C. Completed OJT/ TPE guides, Mentoring guides, Job Familiarization Guides, Qualification Standards and Job Performance Measures D. Written or Oral Examination results Collecting feedback INVITE training feedback from each trainee during formal training. DOCUMENT trainee feedback that requires action in a RA associated with the training program. ASSIGN the RA action to the program owner who will sub assign the action to the appropriate discipline training provider. Remediation Remediate identified performance deficiencies or exam failures using Attachment 6, Remedial Training Notification and Action Plan: A. Analyze why the standard was not met (e.g., knowledge, skill, behavior). B. Describe the performance gap (delta between desired v. demonstrated).

NOTE: TQ-DC-FC-201 Revision 0 Page 18 of 45 The Certified Fuel Handler TPD has specific requirements for when qualifications must be C. Determine if qualifications should be removed. D. Specify actions to close the performance gap (self-study; supervised practice, additional instruction, assignment of a mentor, etc.). E. Obtain line management approval for action items. 2. Track individual's progress in the completion of the action items (timelines met). 3. Validate that the performance standard is now being met. 4. IF qualifications were removed, THEN Restore the qualifications. 4.7. EVALUATION 4. 7 .1. Training effectiveness 1. Post-Training Feedback A. COLLECT post-training feedback on selected, designated Initial and Continuing Training following completion of training (Attachment 11, Performance Evaluation after Training). Document in a RA associated with the training program. B. SUMMARIZE post-trainee feedback. C. EVALUATE feedback and DOCUMENT necessary actions in a RA. 2. Monitoring Training Programs (Line Organization) A. Create a corrective action associated with the RA for the discipline to ensure the following is completed per timelines. B. CONDUCT an annual review of training programs. DOCUMENT and REPORT results to Senior Management. The review should include, but is not limited to, the following: 1. Progression of job incumbents enrolled in training courses 4.8. RECORDS 2. Task list review status TQ-DC-FC-201 Revision 0 Page 19 of 45 3. Training materials alignment to site configuration 4. Written and oral examinations 5. Training Feedback/Post Training Feedback 6. Actions taken to resolve training issues, including revisions made to training materials based on job performance of trained personnel C. CONDUCT and DOCUMENT training self-assessments. Training self-assessments can be either structured like a shot assessment or ongoing based on documented observation data, or a combination of both. D. REVISE training programs, materials or processes whenever a self-assessment identifies gaps in the performance of trained personnel working in their job setting. 4.8.1. The following documents are quality records when completed. Submit to Site Document Control. 1. Attachment 1, Training Exemption Form 2. Attachment 6, Remedial Training Notification and Action Plan 5. REFERENCES 5.1. TDD-1.0, Vermont Yankee SAFSTOR Training Department Directive (TDD), Rev 3 12/2015 5.2. SAFSTORTPD, Vermont Yankee SAFSTOR Training Program Description (TPD), Rev 3 12/2015 5.3. NEI EB 16-07, Training Task List Reviews 6. ATTACHMENTS 6.1. Attachment 1, Training Exemption Form 6.2. Attachment 2, Needs Analysis Process Flowchart 6.3. Attachment 3, Job Analysis Process 6.4. Attachment 4, Task Analysis Process 6.5. Attachment 5, Graded Approach to SAT documentation Form 6.6. Attachment 6, Remedial Training Notification and Action Plan 6.7. Attachment 7, SAFSTOR Training Attendance 6.8. Attachment 8, Exam Security Agreement 6.9. Attachment 9, Training Request Form-Paper Submittal 6.1 0. Attachment 10, Training Funding Request Form 6.11. Attachment 11, Performance Evaluation after Training 6.12. Attachment 12, Lesson Plan Cover Sheet TQ-DC-FC-201 Revision 0 Page 20 of45 FCS T .. E F rammg xempt10n . orm Originator: Originator Date: Name: Employee ID#: Department/Title: Training Program: Date to grant credit if different than approval date or N/A: Module(s), Unit(s), and/or Topics to be Exempted TQ-DC-FC-201 Attachment 1 Revision 0 Component 10 Basis for Training Exemption Method Utilized (Check all items which apply) (Check all items which apply) D Equivalent Training D Review of Training Records D Education D Technical Interview* D Work Experience D Proficiency Examination

• D Demonstrated Proficiency

• Attach Documentation Description of Rationale (Describe the basis and justification for granting credit. Attach documentation as necessary.) Approved By: I I Date: I Discipline Lead Instructor Approved By: Date: Training Manager SAFSTOR Approved By: I ** I Date: I (**for CFH only) Plant Manager Decommissioning (or Designee) Documented in appropriate database ----------Date: _______ _

FCS Operating Experience Performance Improvement Training Att.5 Procedures & Process changes Needs Anal sis Process Flowchart Plant Modification 1 Regulatory Changes TQ-DC-FC-201 Attachment 2 Revision 0 Page 22 of45 I""T---..... .., Strategic Goals Training performance Gaps Notify originator IDENTIFY the workgroup(s) that require training 2 DEFINE the specific training need 3 COMPLETE Training funding request 4 UPDATE Job Analysis & Update Vision Att. 3 5 UPDATE Task Analysis & Update Vision Att4 FCS NO YES TQ-DC-FC-201 Attachment 3 Revision 0 Page 23 of 45 Job Analysis Process Flowchart 3 __ _._.Determine which methods to use to identify tasks 4 Identify tasks for job positions OR Identify tasks for process or equipment 7 Collect DIF ratings data through SME consensus meetings, surveys, or interviews B Determine final DIF ratings by averaging all responses received 9 Determine final setting by use of most frequent response from all responses received 10 Determine training requirement recommendations using DIF training selection matrix 11 Identify "Must Perform* tasks 12 Document results on job analysis data sheet 13 SAFSTOR Line management reviews and approves training requirements and frequency Alternative methods for identifying !asks ---f--_s_ME_ ..... I ...... I r--+JL.. .. I __ J_o_b_D_e_s_c"-*p-ti-on _ _..l ...... l I I Procedures I technical documentation Alternative methods for developing training requirements and frequency recommendations Similar task training requirements and frequency data Line management I CRC determination Vision or other variations of the DIF process , I I 1 I I .. I J.-i I SME table top analysis 17 Determine which method to use ._ ____ .,. .. to develop training requirements and frequency recommendations 16 Develop training requirements and frequency recommendations 14 EP Manager SAFSTOR (or designee) reviews and approves EP tasks 15 Update Vision and POD as appropriate 16 Job Analysis complete -continue after step 4 of attachment 2 I I I -*

FCS Job A

• Data Sheet Training Program: Duty Area Code: t Tasks listed are: 0 New 0 Revised 0 Deleted Cas Analyze the Duty Area's Qual Groups in rows provided. (Add more pages as needed.) Qual Group Code: I Description: tas applicable) Job Analysis Method: 0DIF Oline Management/CRC OOther Ratings Selected for Suggested Training Task Code: Task Description: D I F Setting (No/Initial/ (C/USim/OJD Continuing/-JiTI) Comment: Comment: Comment: Comment: Program Owner or Program Manage( Approval: Date: Station EP Manager or Designee (As Applicable): Date: Vision Updated (As Applicable): Date: (This Form is not required to be retained after data and rationale for changes have been transferred to Vision) TQ-DC-FC-201 Attachment 3 Revision 0 -Reason "Must not Perfonn" selected Task for training (Optional)-D D D D I ! I I FCS Job A natvs

• Data Sheet Ratings Suggested Setting Task Code: Task Descriptton: 0 I F (CIUSfm/OJT) Comment: Comment: Comment: Comment: Comment: Comment: Comment: Comment: Comment: Comment: (This Form is not required to be retained after data and rationale for changes have been transferred to Vision) Selected for Training (Nollnitialf Continuing/-JITT) TQ-DC-FC-201 Attachment 3 Revision 0 Reason "Must not Perform" selected Task for training (Optional) D D D D D D D D D D FCS 1. 2. 3. 4. 5. JOB ANALYSIS DIF RATING FACTOR DEFINITIONS DIFFICULTY: Difficulty (D) is a measure of how difficult a task is to perform. TQ-DC-FC-201 Attachment 3 Revision 0 Page 26 of 45 This task is very easy to perform. Someone with no training and no knowledge of the job could perform it adequately. This task is somewhat easy to perform. Someone with basic job knowledge could perform it with no formal training or requires only a minimal briefing prior to performance. This task is moderately difficult to perform. Minimal classroom or on-the-job training is required to perform it to the required standard. This task is somewhat difficult to perform. A significant amount of training and experience is required to perform it to the required standard. This task is very difficult to perform. Extensive training and practice is required to perform it to the required standard. IMPORTANCE: Importance is a measure of the impact of improper task performance. When rating task importance {1), focus on the TASK, not on individual roles. The importance of a task should be rated considering the limiting context of performance. Extremely Low -This task is not important for safe and efficient onsite storage of spent fuel either in the Spent Fuel Pool or in Dry Cask Storage. Failure to perform this task 1. properly would have no effect on safe spent fuel storage operations. Improper performance of this task would not challenge any industrial safety, radiological safety, or environmental limits Low -This task is somewhat important for safe and efficient storage of spent fuel either in the Spent Fuel Pool or in Dry Cask Storage. Failure to perform this task might have an indirect impact on spent fuel pool cooling/level or dry cask storage which could be quickly 2. mitigated using established procedures. Improper performance of this task would not result in worker injury or exceeding RWP dose limits. Improper performance of this task would not result in a spill of hazardous material nor would it produce any onsite environmental challenge Average-This task is moderately important for safe and efficient onsite storage of spent fuel either in the Spent Fuel Pool or in Dry Casks. Improper performance of this task 3. would have a negative impact on spent fuel pool cooling/level or dry cask storage which could be mitigated in a short time period. Improper performance of this task would have minimal risk to onsite personnel with regards to nuclear, radiological, industrial, or environmental safety High -This task is very important for safe and efficient onsite storage of spent fuel either in the Spent Fuel Pool or in Dry Cask Storage. Failure to perform this task properly could result in: . Challenge spent fuel pool cooling or water level,

• damage to a transport cask but is not likely to cause a loss of cask integrity 4.

• Personnel injury

• Potential for an individual to receive an unplanned exposure exceeding 100 mRem

• Onsite release of hazardous material or challenge, but not exceed, environmental release limits unplanned release of radioactive material from the site

5. 1. 2. 3. 4. 5. TQ-DC-FC-201 Attachment 3 Revision 0 Page 27 of 45 Extremely High-This task is critical for safe and efficient onsite storage of spent fuel either in the Spent Fuel Pool or in Dry Cask Storage. Failure to perform this task properly would likely result in:

• Loss of spent fuel pool cooling or water level

• Loss integrity to a transport container . Significant personnel injury

• Potential overexposure of personnel (i.e. Beyond OPPD annual exposure limits)

• In the offsite release of hazardous material or exceed environmental release limits unplanned release of radioactive material from the site FREQUENCY Frequency (F) measures how often an individual performs the task. This task is performed about twice a year or less often. This task is performed approximately once per calendar quarter (once every 3-6 months). This task is performed about once a month (once every 3 to 5 weeks). This task is performed about once a week (once every 4 days to 2 weeks). This task is performed about once a day (more than once every 3 days).

FCS TQ-DC-FC-201 Attachment 3 Revision 0 Page 28 of 45 JOB ANALYSIS TRAINING SELECTION MATRIX-DIF RATINGS lfthe Average And the Average And the Frequency The Decision to Difficulty Rating is: Importance Rating is: Rating Is: Train/Not to Train is: .2: 3.5 Initial Training .2: 2.5 < 3.5 Initial And Continuing .2: 2.5 Training < 2.5 Initial And Continuing .2: 3.5 Training .2: 3.5 Initial Training < 2.5 .2: 2.5 < 3.5 Initial Training < 2.5 Initial Training .2: 3.5 Initial Training .2: 2.5 < 3.5 Initial And Continuing .2: 2.5 Training < 2.5 Initial And Continuing .2: 2.5 < 3.5 Training > 3.5 No Training Required -< 2.5 .2: 2.5 < 3.5 No Training Required < 2.5 Initial Training .2: 3.5 No Training Required .2: 2.5 :::_2.5 < 3.5 No Training Required < 2.5 Initial Training 1.0 < 2.5 .2: 3.5 No Training Required < 2.5 .2: 2.5 < 3.5 No Training Required < 2.5 No Training Required FCS TQ-DC-FC-201 Attachment 3 Revision 0 Page 29 of 45 N T 0 rammg R equ1re e ec 100 r1 er1a . d S I f C 't . CRITERIA TRAINING MATERIAL DETERMINATIONS 1. Task not currently performed at the Plant Update Task List in the applicable TPD by anyone. 2. Task Is not performed by department Provide notice to Individual responsible for considered but is performed by another other department task list!TPD. plant department. 3. Task can be satisfactorily accomplished on Update Task List in the applicable TPD the job without formal training. 4. Skills and knowledge needed to perform Ensure all skills and knowledge necessary to the task are similar/identical to those perform the selected task are in the training required for another task in the same materials. Update Task List in the applicable department. TPD. 5. Training on the task is provided by Task remains on both task lists. It may be another department's training program. deselected on one. Update Task List in the The other training program is responsible applicable TPD,if necessary. Do not want to for the task analysis. Incumbents learn by duplicate training efforts. attending the other department's training session. 6. The task requires formal training but is Source of training is identified/determined performed so infrequently or by so few by the affected section manager CRC. incumbents that providing training is impractical. 7. Task statement is incorrect. An incorrect task statement will be treated either as a new task, a task title change, or a de-selection. Update Task List in the applicable TPD, if necessary.

c FCS TQ-DC-FC-201 Attachment 4 Revision 0 Page 30 of45 Task Analysis Process Flowchart 1 ) Start task Analysis 3 2 Will task analysis & NO NO objective development Do similar .-be combined using tasklobjecHves procedure or exist? equipment based approach? YES YES 21 Modify existing 11 NO 12 objectives Are task Breakdown OR statements task into Copy and modify discreet and elements objectives to create detai:ed? new objectives YES 1 13 17 Analyze job global Identify unique knowledge tasks to identify generic requirements not addressed knowledge and skill by the objective stems and statements develop additional objectives 14 ' Write typical knowledge requirements as objective 18 stems Identify job task sequences in the procedures governing task performance j_ 15 Compare each task I element selected for training to the objective stems to determine 19 if knowledge required by Select most effective worker procedural task sequence for ' 16 20 Complete the objective stem Develop performance to accommodate each task objective statements for tied selected task sequence 22 Dele <mine objective frequency by f+-reviewing job analysis data for the tasks tied to the objective

• 23 Enter task to objective data into Vision l Alternative Methods for Task Analvsls 4 Determine Formal Analvsls Conduct detailed t which -r-completing all se use for task I ask analysis by ctions of the ta sheet analysis da analysis I I I I I I I I" I I I I I I. 5 Iter Expert lden!lfy task e:eme skill Information by in nts and knowledge I terviewing sample nd their supervisors of job incumbents a Model Pe !former Identify task eleme skill informat:on b nts and knowledge I y observing and killed employees questioning most s Procedural Analvsls Identify task elemen ts and knowledge I rranging procedure nd decision points skill information by a steps (elements) a into a flowchart o r in ouUine form Use Task data sheets to QUide analysis process .. 6 IdentifY task conditions and .. 7 Breakdown tasks Into elements + B Identify skills & knowledge required for task performance _!_ 9 Enter task analysis data into Vision t' 10 Task Analysis Complete-Continue after step 5 of attachment 2 FCS T kA as . D nalySIS ata Sh t ee Task Description Program: Task #/Title: Task Condition(s): [Prerequisite requirements to begin task] Initiating Cue(s): [Event(s) that signals the start of the task) Tenninating Cue(s): [Event(s) that signals the end of the task] Task Output: [End result(s) of satisfactory task performance] Task Standard(s): [Level of acceptable performance of the task] General

References:

[All references used in the task analysis] (Destroy at Option) TQ-DC-FC-201 Attachment 4 Revision 0 T kA as . D t Sh t nalySIS a a ee Task Description (Cont'd.) Consequence(s) of Inadequate Perfonnance Personnel Safety Considerations: Tools and Equipment Required: Human Interfaces: Impact on Plant Safety: 0High D Medium Olow Suggested Setting(s) for Training: D Classroom Olab D Simulator Comments: DIn-Plant TQ-DC-FC-201 Attachment 4 Revision 0 Use following page to list task elements and their associated skills and knowledge statements needed to accomplish the elements. (Add rows and pages needed.) Signature Closeout (sign and date) Analysis Preparer Discipline Lead Instructor review (Destroy at Option)

FCS Element Element Description Number Task A

• Data Sheet Task Knowledge & Skill Elements Knowledge and Skills Statement(s) (Destroy at Option) TQ-DC-FC-201 Attachment 4 Revision 0 FCS Training Request RA#: Topic: Driver /Input for Analysis: Graded Approach to SAT Documentation Form ------------Program: Analysis Decisions ! I Training Programs Affected (Check applicable blocks-consult w/ program leads) Technical Training Operations Training OMM Type or training 0NCO Type of training Other TQ-DC-FC-201 Attachment 5 Revision 0 Type of training (e.g. Cross ORP D Initial* 0 CFH/SM 0 Initial* OEM 0 Continuing D Continuing 0ENG 0 Workgroup OJITI 0CHEM SpecificCT 0 Other: OI&C OJITI 0 other: 0 Other: *If Initial Training is selected, document lesson plan number(s) affected: Training Solution Identified? D Yes 0 No Basis for decision to deliver training: 0 Preventative training based on scheduled work and associated risk 0 Management discretion D Fundamental refresher (retrain task, etc.) D Performance improvement D Operating Experience 0 Changes in Job performance requirements 0 other, e.g., new tasks, new knowledge, benchmarking, information only (specify) Description of training I non-training solution(s): Cutting S/K program) 0 Initial* 0 Continuing OJITI 0 Other: (If the training solution improves a knowledge/skill validate that no gap exits in the Initial training program.) Training setting: D Classroorn/CBT D Shop/Lab 0 Simulator/Mock-up 0 OJT 0 JITT D Other: (Destroy at Option) Page 1 of2 Graded Approach to SAT Documentation Form Training Request RA#: -------------------------Program: Topic: VI/hen using the graded approach, complete the following sections Design Decisions TQ-DC-FC-201 Attachment 5 Revision 0 Evaluation of trainees: How do you plan to assess learning outcomes or competencies to determine whether students have met the objectives of the course? 0 Written Exam D TPE/JPM Learning objectives to be covered: D Simulator/Mock-up D OBE D Other: Development Decisions Lesson Plan Number D New D Revised Review and Approval of materials is required Approved materials will be saved in program folder for future reference Implementation Decisions 0 Classroom/CBT 0 DLA/Lab 0 Simulator/Mock-up OOJT RA assignment may be used for tracking purposes Evaluation Decisions Initiate a Post Training Evaluation (PTE) RA assignment, if a PTE is to be completed (Destroy at Option) Page 2 of2 0 Vendor FCS erne 1a ra1mng Otl ICa 10n an R d" IT . . N "f f dA f PI CIOn Trainee: Instructor/Evaluator: Program: Course: Date of Test/Evaluation: I Test/Evaluation Description (Include if J:\' or 'B' I Exam, etc.): ldentifv Qertinent 0 Failure of a written/oral examination circumstance: 0 Failure of a performance evaluation 0 Other (Describe) DEFICIENCIES IDENTIFIED I BACKGROUND INFORMATION: SPECIFIC QUALIFICATION(S) AFFECTED BY THIS FAILURE: Additional Instructor/Evaluator Comments: FAILURE NOTIFICATION: 0 Training Management notified of failure 0 Line Management (trainee's department head) notified of failure Instructor/Evaluator Name I Signature I Date: Trainee Comments: Trainee Signature: Page 1 of3 an I I Date: TQ-DC-FC-201 Attachment 6 Revision 0 This Record is to be retained for life of plant (for RP Records) for life ofinsurance Policy+ I Yr.; RP records may be retained in department for two years, then forwarded to Records Management.

Remedial Training Notification and Action Plan NOTES: TQ-DC-FC-201 Attachment 6 Revision 0 1. Reference the applicable training program and process governance(s) to identify work the student CANNOT perform based on this failure. 2. If there is no remedial action, document justification below. 3. The information in this section can reflect a telephone conversation with the Department Head/ Superintendent (or designee). In the case of oral approval, the signature line below should be signed by the individual completing this section, followed by the phrase "for" then the approver's printed name. 4. If the failure is on an OBE, all failed tasks, competencies, and fundamentals should be remediated. 5. If the failure is a simulator dynamic evaluation, re-evaluation shall be conducted in the same role (i.e., shift manager, reactor operator, etc.) as the role played during the failed evaluation. Remedial Action Plan (Include if 'A' or 'B' Exam. etc.): Re-evaluation Action Plan: Action Tracking # (if required) I Line Management Approval Signature I Date: I Trainil}Q Management Approval Sjgnature I Date: I Page 2 of3 This Record is to be retained for life ofplant (for RP Records) for life oflnsurance Policy+ 1 Yr.; RP records may be retained in department for two years, then forwarded to Records Management.

R erne 1a rammg o 1 1ca 1on an d" IT . . N ffi f dA f PI CIOn Remediation results: 0 Complete 0 Incomplete Comments: (include IR number if applicable) Program Administrator Signature/Date: Re-evaluation results: 0 Successful D Unsuccessful Comments: Program Administrator Signature/Date: REINSTATEMENT NOTIFICATION: 0 Training Management notified of successful re-evaluation an TQ-DC-FC-201 Attachment 6 Revision 0 D Line Management (trainee's department head) notified of successful re-evaluation Program Administrator Signature/Date: I Where applicable, route this Form to the database administrator or other appropriate staff member for updating the appropriate database prior to filing in the trainee's personal training file. Page 3 of3 This Record is to be retained for life of plant (for RP Records) for life oflnsurance Policy+ I Yr.; RP records may be retained in department for two years, then forwarded to Records Management.

FCS rammg en SAFSTOR T . . Att d Component ID(s): Instructor Name I Employee ID#: a nee Page of Course Length: TQ-DC-FC-201 Attachment 7 Revision 0 Instructions: In ink, print your complete name, Employee ID number, today's date, your company, and site. Sign your name in the signature block. If known for Contract personnel, a PQD fD may be entered in the Employee Number location. Last: First: IMI: Employee 10# I PQO 10# I S.S.# Date: Jscore: or Grade: 0 P 0 F Signature: Last: First: IMI: Employee 10# I PQO 10# I S.S.# Date: I Score: or Grade: 0 P OF Signature: Last: First: IMI: Employee 10# I PQO 10# I S.S.# Date: I Score: or Grade: 0 PDF Signature: Last: First: IMt: Employee 10# I PQO 10# I S.S.# Date: I Score: or Grade: 0 P D F Signature: Last: First: IMI: Employee 10# I PQO 10# I S.S.# Date: I Score: or Grade: D P D F Signature: Last: First: IMI: Employee 10# I PQO 10# I S.S.# Date: I Score: or Grade: 0 P 0 F Signature: Last: First: IMI: Employee 10# I PQO 10# I S.S.# Date: I Score: or Grade: 0 PDF Signature: Last: First: IMI: Employee 10# I PQO ID# I S.S.# Date: I Score: or Grade: D P 0 F Signature: This Record is to be retained for life of plant (for RP Records) for life oflnsurance Policy+ 1 Yr.; RP records may be retained in department for two years, then forwarded to Records Management.

FCS Exam Security Agreement TQ-DC-FC-201 Attachment 8 Revision 0 As of the date of my signature, I acknowledge that I have acquired specialized knowledge about the 1 OCFR required requalification examinations scheduled for the week(s) of through . I agree that I will not knowingly divulge any information about these examinations to any persons who have not been authorized. I understand that I am not to instruct, perform evaluations other than those related to this exam, or provide performance feedback to those operators scheduled to be administered these examinations from this date until completion of examination administration, except as specifically noted below and authorized (e.g., acting as a simulator booth operator or communicator is acceptable if the individual does not select the training content or provide direct or indirect feedback). Furthermore, I am aware of the physical security measures and requirements and understand that violation of the conditions of this agreement may result in cancellation of the examinations and/or an enforcement action against the site or me. I will immediately report to site management any indications or suggestions that examination security may have been compromised. PRINTED NAME JOB TITLE I RESPONSIBILITY SIGNATURE DATE 1 2 **************************************************************** 3 **************************************************************** 4 **************************************************************** 5 **************************************************************** 6 **************************************************************** 7 **************************************************************** 8 **************************************************************** 9 **************************************************************** 10 This Record is to be retained for life of plant (for RP Records) for life oflnsurance Policy+ 1 Yr.; Non-RP records may be retained in department for two years, then forwarded to Records Management. PAGE of 11 **************************************************************** 12 **************************************************************** 13 **************************************************************** 14 **************************************************************** 15 ............................................................... . NOTES: Exam Security Agreement TQ-DC-FC-201 Attachment 8 Revision 0 This Record is to be retained for life of plant (for RP Records) for life oflnsurance Policy+ 1 Yr.; Non-RP records may be retained in department for two years, then forwarded to Records Management. PAGE of FCS Training Request Form -Paper Submittal For use by personnel without access to e-mail or when system is unavailable. Requestor Training Name: Program: Short Description I Title (60 characters): Request: Target Audience: Suggested Timeframe:

Reference:

What GAP in knowledge or performance is your request addressing? TQ-DC-FC-201 Attachment 9 Revision 0 In what setting should training be o Classroom o DLA (Dynamic Learning Activity) conducted? (Select any relevant o Lab o Shift Training notebook setting) D OJT/TPE o Other (specify below) o Simulator How should effectiveness be measured? (be specific) Upon completion, forward to applicable Discipline Training Manager. Attach additional documentation as needed to support your request. Destroy after Training Request AR is generated FCS Training Funding Request TOPIC: Check all 0 FCS/OPPD Initiative that apply: 0 Needed to obtain or maintain qualification TQ-DC-FC-201 Attachment 1 0 Revision 0 Page 43 of45 0 Needed address performance gap or improve performance (Attach copy of documentation) Tracking Number: Site: A. TRAINING DESCRIPTION 1. What business plan objective or site/department indicator does this funding request support? 2. Why is training needed? 3. What is target population for training? 4. Recommended target date for training to be completed: (Allow 20-26 week lead times to fit site-scheduling process, or provide justification for J+ Tor earlier training need.) 5. What is the recommended method of supporting needed training? (vendor, modify or use existing materials) 6. Vendor Information-Contact Tel#:---------Co. Name: Address:Will Trng. Be on Site? 0 Off Site 0 Accept Pcard? Y 0 N 0 -----------B. COST ANALYSIS 1. What is the Total Cost of Training? 2. What is the Training Department's component of the Total Cost? 3. What is the Return on Investment? 4. Additional Comments: Initiator: C. APPROVAL FCS/OPPD Initiatives: Training Manager Printed Name Signature Date SAFSTOR Approval: ---=-:--:---:-::-:------t-----=-:---:--------ir----:--:----Printed Name Signature Date Plant Manager Decommissioning: Signature I Date FCS Performance Evaluation After Training TQ-DC-FC-201 Attachment 11 Revision 0 Page 44 of 45 Management and incumbents participate in post-training assessments to gauge training effectiveness. Training effectiveness measures -such as job performance, management observations, trend indicators, and feedback from supervisors, the trained personnel, and job incumbent peers -support these assessments. Program/Course Title: Date Training Was Completed: I PEAT Action Tracking # # of personnel trained: # of personnel surveyed/observed/evaluated: Selected Tasks or Topics: I. 2. 3. 4. Graduates to be participate: Name Observe (0) Interview (I) Survey (S) 1. E.G. Sample X X 2. D D D 3. [] D D 4. D D D 5. D D [1 Personnel to provide performance feedback: Name Method(s) (O,I,S) Supervisor Peer Other 1. D. Boss 0,1 X 2. DOD IDS D D D 3. DODIDS D D D 4. DOOIDS D [ J D 5. DODIDS D D [] Performance data coUection plan: Name How When Who Stop if ... 1. X department clock resets Regular report Monthly SMo >2 by class 2. 3. 4. 5. All data wilJ be reviewed by (training committee). Summary and Analysis due:

FCS Course I Program; '* . -, Title: '. ,; Author. *,:_. * :' *_ *>: *. ,., Prerequisites: .. Qualified Nuclear ..

• Engineer (If * . _,: *. ,,

• I Name /s/ or N/A Applicable) su,le..Vision " Review

• Program Owner Approval / Name Is/ Name Is/ Lesson Plan Cover Sheet Lesson ID: . '*""' LMS Component Revision I Date: . *. Revision By: Approvals : .. ' .... Date: , :.* .. . < Date: :,,,, TQ-DC-FC-201 Attachment 12 Revision 0