ML21098A157

Response to RAI CFH Training and Requalification Program- 3/30/21

ML21098A157
Person / Time
Site:	Aerotest
Issue date:	03/31/2021
From:	Slaughter D Aerotest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML21098A157 (22)

Text

AEROTEST OPERATIONS, .INC.

3455 FOSTORIA WAY* SAN RAMON, CA 94583 * (925) 866-1212

• FAX (925) 866-1716 March 31, 2021

-AEROTEST RADIOGRAPHY AND RESEARCH REACTOR DOCKET NO. 50-228/LICENSE NO. R-98.

ATTENTION: Document Control Desk U.S. Nuclear Regulatory-Commission White Flint North 11555 Rockville Pike Rockville, MD 20852-2738

Subject:

CFH Ladies and Gentlemen:

This letter and attachments are a follow-up response from the NRC staff's communication ML20177A203 and ML2 l 034 A626 requesting supplemental information.

This document presents relevant changes to Certified Fuel Handling Training/Requalification program needed to prepare for fuel storage. The Licensee proposes relevant text alterations that are needed to ensure an adequate program. The requested supplemental information is provided in ~veral documents:

1. the list of explanations, changes and justifications is provided in Enclosure 1. 2. a mark-up version of the existing document is provided in enclosure 2, and 3. a clean copy of the revised CFH document is included in Enclosure 3.

Should you have any questions or require additional information regarding this submission, please contact AO President David M. Slaughter, Pli.D. at (801) 631 5919 or dmsraven@gmail.com.

I declare under penalty of perjury that the statements above are correct and truthful.

• strator, Manager Operations, Inc.

Enclosures:

1. List of Explanations, Changes, and Justifications

2. Mark-up Version

3. Clean copy CFH program/checklist

(

Enclosure 1 Response to RAI CFH Training and Requalification Program- 3/30/21 We've made a few changes to the CFH Training and Requalification Program that were not in your RAI's to future clarify things.

• Added the following information to 1.1 o The work responsibilities of the CFH are restricted to those outlined in Tech Spec

11. 0 Fuel Transfer and Storage. CFH must follow relevant and approved transfer procedures. The CFHs are obligated to know, practice, and follow when necessary the facility safety and security programs. When the fuel elements are located in the fuel storage racks as specified in Tech Spec 11.1, the CFH are to follow the direction of the president/reactor administrator and radiation safety officer in all other matters. *

• Changed 4.2 On the Job Training to the following (replaced evaluate with understand) 4.2.1 Understand annunciators; valve, pump, and breaker status indicators; and instrument readings as necessary to determine/perform appropriate remedial actions.

4.2.2 Manipulate the fuel handling tool to obtain desired results during normal, and emergency conditions.

4.2.3 Understand radiation monitoring system readings, including alarm conditions, to determine appropriate actions.

4.2.4Understand emergency conditions and remedial actions to be implemented according to the emergency plan for the facility.

• Added changed "Assessment" to "Review" and deleted "selection of appropriate" in front of procedures in 5.1.5. It now states:

5.1.5 Review of facility condition and procedures during normal and emergency situations.

• Changed 5.2 On the Job Training to the following (replaced evaluate with understand) 5.2.1 Understand annunciators; valve, pump, and breaker status indicators; and instrument readings as necessary to determine/perform appropriate remedial actions.

5.2.lManipulate the fuel handling tool to obtain desired results during normal, and emergency conditions.

5.2.3 Understand radiation monitoring system readings, including alarm conditions, to determine appropriate actions.

5.2.4 Understand emergency conditions and remedial actions to be implemented according to the emergency plan for the facility.

Page 1 of 5

Enclosure 1 Response to RAJ CFH Training and Requalification Program-3/30/21

1. The ARRR CFHTRP, Section 1.2 Changed to Section 1.3 which was changed to:

1.3 The CFH training/requalification program is to be reviewed biennially at the end of the training cycle by the Reactor Safeguards Committees. Aerotest Operations, Inc. (AO) may make changes to CFH Training/Requalification Program without NRC approval if the following are applicable:

1.3.1 Suitable proficiency in the performance of the program's activities is maintained; and 1.3.2 Changes are documented and will be available during an NRC inspection to verify the adequacy of the program.

The periodically" has been changed to biennially. Changed the wording to identify what changes did not need NRC approval.

2. The ARRR CFHTRP, Section 1.3 renumbered to 1.4 and changed to:

After Initial CFH training, the qualification program shall be conducted biennially over a period not to exceed 24 months, followed by successive 24-month periods. (Preference will be given to CFH candidates which maintained successfully an SRO license from an NRC Licensed research reactor or had 2 years fuel handling experience at Aerotest Operations Inc.)

The ARRR CFHTRP, Section 5 changed to:

All certified fuel handlers will participate in the biennial retraining program. The Certified Fuel Handler Retraining Program consists of lectures and/or self-study of topics appropriate to the monitoring, handling, storage, and cooling of nuclear fuel. The content of the retraining program will be based upon the tasks selected during program development for the retraining cycle. A retraining plan will be developed and will be approved by the President. The training plan will be developed utilizing the systematic approach to training (SAT). Certified Fuel Handlers (CFH) will spend a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> biennially on preplanned lectures and/or self-study.

5.3 A comprehensive.final examination shall be administered at the end of the retraining program to provide assurance of mastery of the skills, knowledge, and abilities required for successful performance of Certified Fuel Handler tasks.

The comprehensive examination shall include a written examination and an operating examination. Areas examined are described in 5.1 and 5.2.

Page 2 of 5

Enclosure I Response to RAJ CFH Training and Requali:fication Program - 3/30/21 Tue ARRR CFHTRP, Section 8 changed to:

Records of the training requalification program will be maintained to document each CFH in the program. A summary document (log) will be maintained for each CFH that includes entries to support the CFH active-duty status, attendance dates for biennial lectures, and references for any on-the-job training activities.

Records will also include copies of the written examination with the answers given by each CFH Also, any additional training given in areas where CFH exhibited deficiencies. Records will be maintained until all fuel is shipped out of the facility and CFHs/CFH Supervisor are no longer needed Biennial is the intended frequency and changes have been made. 26 months was a typo has been changed to 24 months.

3. The ARRR CFHTRP, Section 2, Experience/Qualifications," states, in part:

Successfully completed college-level work in the nuclear and radiation related fields ofstudy may be considered in lieu of the experience requirement. Maintain health/medical requirements required for the CFHjob. The biennial CFH Health Questionnaire will be used to assess health/medical requirements.

Changed "classroom education." to "successfully completed college-level work in the nuclear and radiation fields of study." Removed the requirements for "manual dexterity and mature judgment". Added Maintain health/medical requirements required for the CFH job. The biennial CFH Health Questionnaire will be used to assess health/medical requirements.

4. Tue ARRR CFHTRP, Section 3.1 and 3.2 changed to:

3.1 CFH Supervisor - The CFH Supervisor is a non-licensed operator who has qualified in accordance with a fuel handler training program approved by the NRC. They will supervise other CFHs and perform CFH duties.

3. 2 CFH - The certified fuel handl.er is a non-licensed operator who has qualified in accordance with a fuel handler training program approved by the NRC. CFH is intended to be the licensee representative who is present to ensure the safe handling, maintenance and storage ofspent fuel. Making sure fuel handing procedures are followed when performing periodic fuel inspections or putting the spent fuel in transportation caskets for fuel shipment from facility.

Added definition of a CFH as "a non-licensed operator who has qualified in accordance with a fuel handler training program approved by the [NRC]." To both 3.1 CFH supervisor and 3.2 CFH.

Page 3 of 5

Enclosure 1 Response to RAJ CFH Training and Requalification Program - 3/30/21

5. The ARRR CFHTRP, Section 3 .4 changed to:

Reactor Safeguards Committee - Designated member of committee who is not an Aerotest Operations Inc. member (employee) will oversee president's CFH training, testing and evaluate/scores on his Written Test and Job Performance Measures.

Revised language now precludes the president from being the member of the committee designated to oversee the president's CFH training, testing, and evaluating.

6. The ARRR CFHTRP, Section 5, "Retraining Program," states, in part, "The training plan will be developed utilizing the systematic approach to training (SAT)."

Added definition of SAT to added section 1.2 which states:

1.2 The CFH training/requalification program is based on systematic approach to training (SAT).

1.2.1 Systematic analysis of the jobs to be performed.

1.2.2 Learning objectives derived from the analysis which describe accepted performance after training.

1.2.3 Training design and implementation based on the learning objectives.

1.2.4 Evaluation oftrainee mastery of the objectives during training.

1. 2. 5 Evaluation and revision of the training based on the performance of trained personnel in the job setting.

7. The ARRR CFHTRP, Section 6.1 has been revised to:

To maintain active status, each CFH shall "actively" perform 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per year ofCFH activities. If a CFH does not perform 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of CFH activities per year he/she shall not perform Certified Fuel Handler duties independently until he/she has completed 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> ofsupervised CFH activities.

We've added what the CFH needs to do if they don't meet the hours. We based the hours on the following information: All of Aerotest Operations, Inc fuel elements are in long term storage, they are not in the core so they can never reach criticality. CFH do not stand watch. There are no systems in operations. CFH only handle fuel to perform maintenance, fuel inspections and to ship fuel from the facility.

We've clarified the duties of CFH in Section 3.2

3. 2 CFH - The certified fuel handler is a non-licensed operator who has qualified in accordance with a.fuel handler training program approved by the NRC.

3.2.1 The CFH does not make decisions on.fuel handing, decommissioning or radiation.

Those are made by the Reactor Administrator or Radiation Safety Officer (RSO)

3. 2. 2 They only handle fuel when need and only handle 1 fuel element at a time.

Page 4 of 5

Enclosure 1 Response to RAI CFH Training and Requalification Program- 3/30/21 3.2.3 Fuel handling obligations include maintenance, periodic.fuel inspections and/or putting the spent fuel in transportation caskets for fuel shipment from facility.

NRC concern that the CFH will complete his/her hours in the first month and then do no CFH activities for the remainder of the year. As part of the requalification process the CFH operating examination will consist of Job Performance Measures (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. This is the same to preforming the CFH duties as he would do at any other time the fuel element need to be handled. So even if the 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> were at the beginning of the year, he/she would still be performing CFH activities at the end of the year with this performance measure.

8. The ARRR CFHTRP, Section 7, Medical Examination," has been changed as follows:

7. Certified Fuel Handlers Heath Questionnaire and Review 7.1 All CFH applicants must fill out Aerotest Operations, Inc's CFH health questionnaire when they apply to become a CFH and biennially thereafter.

7 .2 The President or his designate, will review the Health Questionnaire 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.

Removed Medical Exam and replaced with CFH Health Questionnaire and Review.

Page 5 of 5

Enclosure 2 ARRR CFH TRAINING/REQUALIFICATION PROGRAM Revision 8/25/2020 Updated Version3/30/21 Deleted text , Added Text and Renumbered Items

1. PURPOSE 1.1. A permanently shut down and defueled reactor, no longer requires licensed reactor (RO) or senior reactor operators (SRO) and are replaced by the Certified Fuel Handler (CFH) and the Certified Fuel Handler Supervisor. The qualification, training and retraining of the CFHs and CFH Supervisor provides an appropriate level of oversight commensurate with the reduced risks and relative simplicity of the facility systems needed for safe storage of spent fuel, including the safe handling and storage of spent fuel, and response to plant emergencies. The work responsibilities of the CFH are restricted to those outlined in Tech Spec 11. 0 Fuel Transfer and Storage. CFH must follow relevant and approved transfer procedures. The CFHs are obligated to know, practice, and follow when necessary the facility safety and security programs. When the fuel elements are located in the fuel storage racks as specified in Tech Spec 11.1, the CFH is to follow the direction of the president/reactor administrator and radiation safety officer in all other matters.

1.2. The CFH traininglrequalification program is based on systematic approach to training (SAT).

1. 2.1. Systematic analysis of the jobs to be performed 1.2.2. Learning objectives derived from the analysis which describe accepted performance after training.

1.2.3. Training design and implementation based on the learning objectives.

1.2.4. Evaluation of trainee mastery of the objectives during training.

1.2.5. Evaluation and revision of the training based on the performance of trained personnel in the job setting.

Renumbered 1.2 to 1.3 and 1.3 to 1.4 1.3.The CFH tro.ining/requalifioation program requires approval by the Nuolear Regulatory Commission. The CFH training/requali:fication program is to be reviewed periodically biennially at the end of the training cycle by the Reactor Safeguards Committees and any substantial ohanges to CFH tmining/requalifiootion program shall be approv:ed by the NRG. *Minor and ola:r...fioation ohanges to the program shall require Reaotor Safeguards Committee approYal only .. Aerotest Operations, Inc. (AO) may make changes to CFH Training/Requalification Program without NRC approval if the following are applicable:

1.3.1 Suitable proficiency in the performance of the program's activities is maintained; and

1. 3. 2 Changes are documented and will be available during an NRC inspection to verify the adequacy of the program.

1.4. After Initial CFH training, a reooourring the qualification program shall be conducted biannually biennially not to exceed~ 24 months,followed by successive 24-month periods. (Preference will be given to CFH candidates which maintained successfully a Page 1 of 6

Enclosure 2 ARRR CFH TRAINING/REQUALIFICATION PROGRAM Revision 8/25/2020 Updated Version3/30/21 Deleted text , Added Text and Renumbered Items an SRO license from a an NRC Licensed research reactor or had 2 years fuel handling experience at Aerotest Operations Inc.)

2. EXPERENCE/QUALIFICATIONS 2.1. CFH Supervisor - shall have at least 5 years of experience in irradiated fuel movements and demonstrated knowledge of the relevant NRC regulations and ALARA principles.

Classroom edueation Successfully completed college-level work in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement.

Manual dexterity and matufe judgment. Maintain health/medical requirements required for the CFHjob. The biennial CFH Health Questionnaire will be used to assess health/medical requirements.

2. 2. CFH - shall have at least 2 years of experience in irradiated fuel movements and demonstrated knowledge of the relevant NRC regulations and ALARA principles.

Classroom edueation Successfully completed college-level work in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement.

Manual dexterity and mature judgment. Maintain health/medical requirements required for the CFH job. The biennial CFH Health Questionnaire will be used to assess health/medical requirements.

2. 3. President - shall have at least 7 years of experience in irradiated fuel movements and demonstrated knowledge of the relevant NRC regulations and ALARA principles.

Classroom edueation Successfully completed college-level work in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement.

Maintain health/medical requirements required for the CFH job. The biennial CFH Health Questionnaire will be used to assess health/medical requirements.

3. DUTIES 3 .1. CFH Supervisor - The CFH Supervisor is a non-licensed operator who has qualified in accordance with a.fuel handler training program approved by the NRC. They will supervise other CFHs and perform CFH duties.

3.2. CFH - The certified fuel handler is intended to be the lieensee representatiye v,ho is present to ensure the safe handling, maintenanee and storage of spent fuel. Making sure fuel handing proeedures are followed when performing periodie fuel inspeetions or putting the spent fuel in transportation easkets for fuel shipment from foeility. The certified.fuel handler is a non-licensed operator who has qualified in accordance with a fuel handler training program approved by the NRC.

3.2.1. The CFH does not make decisions on.fuel handing, decommissioning or radiation. Those are made by the Reactor Administrator or Radiation Safety Officer (RSO) 3.2.2. The CFH only handle fuel when need and only handle 1 fuel element at a time.

Page 2 of 6

Enclosure 2 ARRR CFH TRAINING/REQUALIFICATION PROGRAM Revision 8/25/2020 Updated Version3/30/21 Deleted text , Added Text and Renumbered Items

3. 2. 3. Fuel handling obligations include are maintenance, periodic fuel inspections and/or putting the spent fuel in transportation caskets for fuel shipment from facility.

3.3. President-He may hold the title CFH and/or CFH Supervisor. Will oversee CFH training, testing and evaluate/scores on Written Test and Job Performance Measures.

3.4. Reactor Safeguards Committee -Designated member of committee who is not an Aerotest Operations Inc. member (employee) will oversee president's CFH training, testing and evaluate/scores on his Written Test and Job Performance Measures.

4. INITIAL TRAINING PROGRAM The initial training phase of the Certified Fuel Handler Training Program consists oflecture, and/or self-study of topics appropriate to the monitoring, handling, storage, and cooling of nuclear fuel, and includes training on CFH tasks as well as required fundamental topics.

4.1. Lectures and Self Study Topics to be covered include:

4.1.1. Design, function, and operation of systems used in handling, storage, cooling, monitoring of nuclear fuel, and auxiliary support systems.

4.1.2. Purpose and operation of the radiation monitoring systems.

4.1.3. Radiological safety principles and procedures including radiation hazards that may arise during normal and maintenance activities ..

4.1.4. Conditions and limitations of facility license, including content, basis, and importance of Technical Specifications.

4.1.5. Assessment of facility condition and selection of appropriate procedures during normal, and emergency situations.

4.1.6. Fuel handling facilities and procedures.

4.2 On the Job CFH Training 4.2.1 E*1aluate Understand annunciators; valve, pump, and breaker status indicators; and instrument readings as necessary to determine/perform appropriate remedial actions.

4.2.2 Evaluate the ability to manipulate Manipulate the fuel handling tool to obtain desired results during normal, and emergency conditions.

4.2.3 E,-.1aluate Understand radiation monitoring system readings, including alarm conditions, to determine appropriate actions. Such aetions may include setting an alarn1 set point to monitor a release or determine appropriate remedial actions for an alarm oondition.

4.2.4 Evaluate Understand emergency conditions and remedial actions to be implemented according to the determine if the emergency plan for the facility.

should be implemented and, if implemented, e¥aluate performance of duties as required by the emergency plan.

Page 3 of 6

Enclosure 2 ARRR CFH TRAINING/REQUALIFICATION PROGRAM Revision 8/25/2020 Updated Version3/30/21 Deleted text , Added Text and Renumbered Items 4.3 A comprehensive final examination shall be administered at the end of the initial training program to provide assurance of mastery of the skills, knowledge, and abilities required for successful performance of Certified Fuel Handler tasks. The comprehensive examination shall include a written examination and an operating examination. Areas examined are described in 4.1 and 4.2 4.3.1 The written examination requires a minimum score of 80 percent to pass.

4.3.2 The operating examination will consist of Job Performance Measures (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.

4.3.3 An individual who fails to pass either the written or operating examination shall not perform Certified Fuel Handler duties independently until he/she has completed a remedial training program and passes an appropriate reexamination.

Only those portions of the original examination that were failed need to be re-examined (i.e., written, or operating exam).

5. RETRAININGPROGRAM All certified fuel handlers will participate in the biannual retraining program. The Certified Fuel Handler Retraining Program consists oflectures 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. A retraining plan will be developed and will be approved by the President. The training plan will be developed utilizing the systematic approach to training (SAT). Certified Fuel Handlers (CFH) will spend a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> biannual biennially on preplanned lectures and/or self-study.

5.1. Lectures and Self Study Topics to be covered include:

5.1.1. Design, function, and operation of systems used in handling, storage, cooling, monitoring of nuclear fuel, and auxiliary support systems.

5.1.2. Purpose and operation of the radiation monitoring systems.

5.1.3. Radiological safety principles and procedures including radiation haz.ards that may arise during normal and maintenance activities.

5.1.4. Conditions and limitations of facility license, including content, basis, and importance of Technical Specifications.

5 .1.5. ,<\.ssessment Review of facility condition and seleetion of appropriate procedures during normal and emergency situations.

5.1.6. Fuel handling facilities and procedures.

5.1.7.

Page 4 of 6

Enclosure 2 ARRR CFH TRAINING/REQUALIFICATION PROGRAM Revision 8/25/2020 Updated Version3/30/21 Deleted text , Added Text and Renumbered Items 5.2 On the Job CFH Training 5.2.1 Evaluate Understand annunciators; valve, pump, and breaker status indicators; and instrument readings as necessary to determine/perform appropriate remedial actions.

5.2.2 Evaluate the ability to manipulate Manipulate the fuel handling tool to obtain desired results during normal, and emergency conditions.

5.2.3 Ev:aluate Understand radiation monitoring system readings, including alarm conditions, to determine appropriate actions. Such actions may include setting an alarm set point to monitor a release or determine appropriate remedial actions for fill alarm condition.

5 .2.4 EYaluate Understand emergency conditions and remedial actions to be implemented according to the determine if the emergency plan for the facility.

should be implemented and, if implemented, eyaluate performance of duties as required by the emergency plan.

5.3 A comprehensive final examination shall be administered at the end of the initial retraining training program to provide assurance of mastery of the skills, knowledge, and abilities required for successful performance of Certified Fuel Handler tasks. The comprehensive examination shall include a written examination and an operating examination. Areas examined are described in 5 .1 and 5 .2 5 .3 .1 The written examination requires a minimum score of 80 percent to pass.

5.3.2 The operating examination will consist of Job Performance Measures (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.

5.3.3 An individual who fails to pass either the written or operating examination shall not perform Certified Fuel Handler duties independently until he/she has completed a remedial training program and passes an appropriate reexamination.

Only those portions of the original examination that were failed need to be re-examined (i.e., written, or operating exam).

6. ACTIVE/INACTIVE STATUS 6.1 To maintain active status, each CFH shall "actively" performs 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per year of CFH activities. If a CFH does not perform 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of CFH activities per year he/she shall not perform Certified Fuel Handler duties independently until he/she has completed 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> ofsupervised CFH activities.

6. 2 Maintain health/medical requirements required for the CFH job. The biennial CFH Health Questionnaire will be used to assess health/medical requirements Page 5 of 6

Enclosure 2 ARRR CFH TRAINING/REQUALIFICATION PROGRAM Revision 8/25/2020 Updated Version3/30/21 Deleted text , Added Text and Renumbered Items Renumbered 6.2 to 6.3 and 6.3 to 6.4 6.3 Each CFH shall be cognizant of any changes to any part of the requirements and obligations for safe and secure fuel handling. Changes made in procedures and the facility and shall be reviewed before any scheduled activity that fuel is to be handled.

6.4 Each CFH shall participate in the biennial emergency drill. The drill and applicable alterations to emergency procedures shall be reviewed with all CFH within 30 days of the completed drill.

7. :t,,{BDICAL EXAMJNATION Certified Fuel Handlers Heath Questionnaire and Review If requiied; a medieal examination shall be required for the eonfirmation of the general physical health of the CFH.

7.1. All CFH applicants must fill out Aerotest Operations, Inc's CFH health questionnaire when they apply to become a CFH and biennially thereafter.

7. 2. The President or his designate, will review the Health Questionnaire 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

8. RECORDS Records of the training requalification program will be maintained to document each CFH in the program. A summary document Oog) will be maintained for each CFH that includes entries to support the CFH aetive duty active-duty status, attendance dates for biannual biennial lectures, and references for any on-the-job training activities. Records will also include copies of the written examination with the answers given by each CFH. Also, any additional training given in areas where CFH exhibited deficiencies. Records will be maintained until all fuel is shipped out of the facility and CFHs/ & CFH Supervisor are no longer needed.

Page 6 of 6

Enclosure 3 ARRR CFH TRAINING/REQUALIFICATION PROGRAM Revision 3/30/21

1. PURPOSE 1.1. A permanently shut down and defueled reactor, no longer requires licensed reactor (RO) or senior reactor operators (SRO) and are replaced by the Certified Fuel Handler (CFH) and the Certified Fuel Handler Supervisor. The qualification, training and retraining of the CFH and CFH Supervisor provides an appropriate level of oversight commensurate with the reduced risks and relative simplicity of the facility systems needed for safe storage of spent fuel, including the safe handling and storage of spent fuel, and response to plant emergencies. The work responsibilities of the CFH are restricted to those outlined in Tech Spec 11.0 Fuel Transfer and Storage. CFH must follow relevant and approved transfer procedures. The CFHs are obligated to know, practice, and follow when necessary the facility safety and security programs. When the fuel elements are located in the fuel storage racks as specified in Tech Spec 11.1, the CFH are to follow the direction of the president/reactor administrator and radiation safety officer in all other matters.

1.2. The CFH training/requalification program is based on systematic approach to training (SAT).

1.2.1. Systematic analysis of the jobs to be performed.

1.2.2. Learning objectives derived from the analysis which describe accepted performance after training.

1.2.3. Training design and implementation based on the learning objectives.

1.2.4. Evaluation of trainee mastery of the objectives during training.

1.2.5. Evaluation and revision of the training based on the performance of trained personnel in the job setting.

1.3. The CFH training/requalification program is to be reviewed biennially at the end of the training cycle by the Reactor Safeguards Committee (RSC). Aerotest Operations, Inc.

(AO) may make changes to CFH Training/Requalification Program without NRC approval if the following are applicable:

1.3 .1 Suitable proficiency in the performance of the program's activities is maintained, and 1.3 .2 Changes are documented and will be available during an NRC inspection to verify the adequacy of the program.

1 A.After Initial CFH training, the qualification program shall be conducted biennially over a period not to exceed 24 months, followed by successive 24-month periods. (Preference will be given to CFH candidates which maintained successfully an SRO license from an NRC Licensed research reactor or had 2 years fuel handling experience at Aerotest Operations Inc.)

Page 1 of 6

Enclosure 3 ARRR CFH TRAINING/REQUALIFICATION PROGRAM Revision 3/30/21

2. EXPERENCE/QUALIFICATIONS 2.1. CFH Supervisor - shall have at least 5 years of experience in irradiated fuel movements and demonstrated knowledge of the relevant NRC regulations and ALARA principles.

Successfully completed college-level work in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement. Maintain health/medical requirements required for the CFH job. The biennial CFH Health Questionnaire will be used to assess health/medical requirements.

2.2. CFH - shall have at least 2 years of experience in irradiated fuel movements and -

demonstrated knowledge of the relevant NRC regulations and ALARA principles.

Successfully completed college-level work in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement. Maintain health/medical requirements required for the CFH job. The biennial CFH Health Questionnaire will be used to assess health/medical requirements.

2.3. President - shall have at least 7 years of experience in irradiated fuel movements and demonstrated knowledge of the relevant NRC regulations and ALARA principles.

Successfully completed college-level work in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement. Maintain health/medical requirements required for the CFH job. The biennial CFH Health Questionnaire will be used to assess health/medical requirements.

3. DUTIES 3 .1. CFH Supervisor - The CFH Supervisor is a non-licensed operator who has qualified in accordance with a fuel handler training program approved by the NRC. They will supervise other CFHs and perform CFH duties.

3.2. CFH-The certified fuel handler is a non-licensed operator who has qualified in accordance with a fuel handler training program approved by the NRC.

3 .2.1. The CFH does not make decisions on fuel handing, decommissioning or radiation.

Those are made by the Reactor Administrator or Radiation Safety Officer (RSO) 3.2.2. The CFH only handle fuel when need and only handle 1 fuel element at a time.

3.2.3. Fuel handling obligations include maintenance, periodic fuel inspections and/or putting the spent fuel in transportation caskets for fuel shipment from facility.

3.3. President-He may hold the title CFH and/or CFH Supervisor. Will oversee CFH training, testing and evaluate/scores on Written Test and Job Performance Measures.

3.4. Reactor Safeguards Committee-Designated member of committee who is not an Aerotest Operations Inc. member (employee) will oversee president's CFH training, testing and evaluate/scores on his Written Test and Job Performance Measures.

Page 2 of 6

Enclosure 3 ARRR CFH TRAINING/REQUALIFICATION PROGRAM Revision 3/30/21

4. INITIAL TRAINING PROGRAM The initial training phase of the Certified Fuel Handler Training Program consists of lecture, and/or self-study of topics appropriate to the monitoring, handling, storage, and cooling of nuclear fuel, and includes training on CFH tasks as well as required fundamental topics.

4.1. Lectures and Self Study Topics to be covered include.

4.1.1. Design, function, and operation of systems used in handling, storage, cooling, monitoring of nuclear fuel, and auxiliary support systems.

4.1.2. Purpose and operation of the radiation monitoring systems.

4.1.3. Radiological safety principles and procedures including radiation hazards that may arise during normal and maintenance activities ..

4.1.4. Conditions and limitations of facility license, including content, basis, and importance of Technical Specifications.

4.1.5. Assessment of facility condition and selection of appropriate procedures during normal, and emergency situations.

4.1.6. Fuel handling facilities and procedures.

4.2 On the Job CFH Training 4.2.1 Understand annunciators; valve, pump, and breaker status indicators; and instrument readings as necessary to determine/perform appropriate remedial actions.

4.2.2 Manipulate the fuel handling tool to obtain desired results during normal, and emergency conditions.

4.2.3 Understand radiation monitoring system readings, including alarm conditions, to determine appropriate actions.

4.2.4 Understand emergency conditions and remedial actions to be implemented according to the emergency plan for the facility.

4.3 A comprehensive final examination shall be administered at the end of the initial training program to provide assurance of mastery of the skills, knowledge, and abilities required for successful performance of Certified Fuel Handler tasks. The comprehensive examination shall include a written examination and an operating examination. Areas examined are described in 4.1 and 4.2.

4.3 .1 The written examination requires a minimum score of 80 percent to pass.

4.3.2 The operating examination will consist of Job Performance Measures (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.

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Enclosure 3 ARRR CFH TRAINING/REQUALIFICATION PROGRAM Revision 3/30/21 4.3.3 An individual who fails to pass either the written or operating examination shall not perform Certified Fuel Handler duties independently until he/she has completed a remedial training program and passes an appropriate reexamination.

Only those portions of the original examination that were failed need to be re-examined (i.e., written, or operating exam).

5. RETRAININGPROGRAM All certified fuel handlers will participate in the biennial retraining program. The Certified Fuel Handler Retraining Program consists oflectures 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. A retraining plan will be developed and will be approved by the President. The training plan will be developed utilizing the systematic approach to training (SAn. Certified Fuel Handlers (CFH) will spend a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> biennially on preplanned lectures and/or self-study.

5.1. Lectures and Self Study Topics to be covered include:

5 .1.1. Design, function, and operation of systems used in handling, storage, cooling, monitoring of nuclear fuel, and auxiliary support systems.

5 .1.2. Purpose and operation of the radiation monitoring systems.

5 .1.3. Radiological safety principles and procedures including radiation hazards that may arise during normal and maintenance activities.

5.1.4. Conditions and limitations of facility license, including content, basis, and importance of Technical Specifications.

5.1.5. Review of facility condition and procedures during normal and emergency situations.

5.1.6. Fuel handling facilities and procedures.

5.2 On the Job CFH Training 5.2.1 Understand annunciators; valve, pump, and breaker status indicators; and instrument readings as necessary to determine/perform appropriate remedial actions.

5.2.2 Manipulate the fuel handling tool to obtain desired results during normal, and emergency conditions.

5.2.3 Understand radiation monitoring system readings, including alarm conditions, to determine appropriate actions.

5.2.4 Understand emergency conditions and remedial actions to be implemented according to the emergency plan for the facility.

5.3 A comprehensive final examination shall be administered at the end of the retraining program to provide assurance of mastery of the skills, knowledge, and abilities required for successful performance of Certified Fuel Handler tasks. The comprehensive Page 4 of 6

Enclosure 3 ARRR CFH TRAINING/REQUALIFICATION PROGRAM Revision 3/30/21 examination shall include a written examination and an operating examination. Areas examined are described in 5.1 and 5.2.

5 .3 .1 The written examination requires a minimum score of 80 percent to pass.

5.3.2 The operating examination will consist of Job Performance Measures (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.

5.3.3 An individual who fails to pass either the written or operating examination shall not perform Certified Fuel Handler duties independently until he/she has completed a remedial training program and passes an appropriate reexamination.

Only those portions of the original examination that were failed need to be re-examined (i.e., written, or operating exam).

6. ACTIVE/INACTIVE STATUS 6.1 To maintain active status, each CFH shall "actively perform 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per year of CFH activities. If a CFH does not perform 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of CFH activities per year he/she shall not perform Certified Fuel Handler duties independently until he/she has completed 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of supervised CFH activities.

6.2 Maintain health/medical requirements required for the CFH job. The biennial CFH Health Questionnaire will be used to assess health/medical requirements.

6.3 Each CFH shall be cognizant of any changes to any part of the requirements and obligations for safe and secure fuel handling. Changes made in procedures and the facility and shall be reviewed before any scheduled activity that fuel is to be handled.

6.4 Each CFH shall participate in the biennial emergency drill. The drill and applicable alterations to emergency procedures shall be reviewed with all CFH within 30 days of the completed drill.

7. Certified Fuel Handlers Heath Questionnaire and Review 7.1. All CFH applicants must fill out Aerotest Operations, Inc's CFH health questionnaire when they apply to become a CFH and biennially thereafter.

7.2. The President or his designate, will review the Health Questioililaire to determine that the candidate's medical condition is not such that it might cause operational errors that could endanger other plant persoililel or the public health.

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Enclosure 3 ARRR CFH TRAINING/REQUALIFICATION PROGRAM Revision 3/30/21

8. RECORDS Records of the training requalification program will be maintained to document each CFH in the program. A summary document (log) will be maintained for each CFH that includes entries to support the CFH active-duty status, attendance dates for biennial lectures, and references for any on-the-job training activities. Records will also include copies of the written examination with the answers given by each CFH. Also, any additional training given in areas where CFH exhibited deficiencies. Records will be maintained until all fuel is shipped out of the facility and CFHs/CFH Supervisor are no longer needed.

Page 6 of 6

CHECKIIST for CFH TRAINING/ REQUALIFICATION PROGRAM Period _ _ _ to _ __

After Initial CFH training, the qualification program shall be conducted biennially over a period not to exceed 24 months, followed by successive 24-month period.

Name:

CFH No. _ _ _ _ _ (Retired SRO No. _ _ __,

LECTURES Preplanned lectures will be given to CFHs that at are given within the 2-year program. The lecture(s) encompass the topics listed below:

Date

___Design, function, and operation of systems used in handling, storage, cooling, monitoring of nuclear fuel, and auxiliary support systems.

___Purpose and operation of the radiation monitoring systems.

___Radiological safety principles and procedures including radiation hazards that may arise during normal and maintenance activities.

___Conditions and limitations of facility license, including content, basis and importance of Technical Specifications.

___Assessment of facility condition and selection of appropriate procedures during normal and emergency situations.

___Fuel handling facilities and procedures.

ON-THE-JOB TRAINING

___Understand annunciators; valve, pump, and breaker status indicators; and instrument readings as necessary to determine/perform appropriate remedial actions.

___Manipulate the fuel handling tool to obtain desired results during normal, and emergency conditions.

_ _-_Understand radiation monitoring system readings, including alarm conditions, to determine appropriate actions. Such actions may include setting an alarm set point to monitor a release or determine appropriate remedial actions for an alarm condition.

CHECKIIST for CFH TRAINING/ REQUALIFICA TION PROGRAM Period _ _ _ to _ __

_ _ _Understand emergency conditions and remedial actions to be implemented according to the emergency plan for the facility.

ACTIVE/INACTIVE STATUS

_ _ _To maintain active status, each CFH shall "actively perform 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per year of CFH activities. If a CFH does not perform 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of CFH per year shall not perform Certified Fuel Handler duties independently until he/she has completed 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of supervised CFH activities.

_ _ _ Maintain health/medical requirements required for the CFHjob. The biennial CFH Health Questionnaire will be used to assess health/medical requirements.

_ _ _Each CFH shall be cognizant of any changes to any part of the requirements and obligations for safe and secure fuel handling. Changes made in procedures and the facility and shall be reviewed before any scheduled activity that fuel is to be handled.

_ _ _Each CFH shall participate in the biennial emergency drill. The drill and applicable alterations to emergency procedures shall be reviewed with all CFH within 30 days of the completed drill.

CFH EVALUATION/EXAM-ADMINISTRATION Biennial written examinations: Instr.- - - Score: - - - Date - - -

Certified Fuel Handler Health Questionnaire Reviewed Date _ __

AEROTEST OPERATIONS, INC.

3455 FOSTORIA WAY

• SAN RAMON, CA 94583 * (925) 866-1212

• FAX (925) 866-1716 Certified Fuel Handler's Health Questionnaire Date of Birth- - - - -

Name:

- - - - - - - - - - - - - Sex: Male Female Home Address: _ _ _ _ _ _ _ _ _ _ _ _ _ _City _ _ _ __ Zip_ _ _ __

Home Telephone: - - - - - Job

Title:

- - - - - - - - - Hire Date:- - - - - -

INTRODUCTION The information you provide in this questionnaire is extremely important. It will be used by the company President or his designate to assess your ability to perform the essential functions of the job safely without endangering yourself or others. Please fill out the questionnaire completely and accurately.

Please answer all questions completely. Do not leave any answers blank; use either NA" (not applicable) or

Don't Know."

QUESTIONS

1. Date of Last Tetanus Immunization _ _ _ _ _ _ _ _ _(Never) (Unknown)

2. Do you have, or have you ever had (check all that apply - circle those you don't know):

• _ Vision problems -eye disease, surgeries, temporary/permanent loss of vision in either eye

• Color Blind

• _ Skin condition (recurrent eczema, irritated skin, open lesions)

• Arthritis

• _ Dizziness/fainting/loss of consciousness/black outs

• _ Convulsions/seizures/epilepsy

• _ Psychological problems/anxiety/stress/nerves/depression

• Headaches

• _ Prior drug/alcohol treatment

• _ Chronic Fatigue/Gulf War Syndrome

• _ Bad reaction to cold, heat, heights or closed spaces

• Swollen ankles or varicose veins

• _ Fractures (broken bones or ribs)

• _ Trouble Smelling odors

• _ A reaction, allergy, and/or sensitivity to any drugs (such as codeine, penicillin, or sulfa), latex, foods, plants, or chemicals

• _ Shortness of breath when walking fast on level ground or walking up a slight hill or incline

• _Shortness of breath that interferes with your job

3. Chronic or recurring pain or swelling or limited motion associated with:

Neck Wrist Back Ankle Shoulder Hand

_ Hip Foot Elbow Knee _ Fingers Other - - - - - - - - -

\I

• r ..

4. Do you have you any difficulty with any of the following activities? (Put a Y for YES and N for NO on the line)

• _Standing

• _Walking

• _Sitting

• _Driving

• _ Manual dexterity

• Co-ordination

5. Do you currently have any of the following musculoskeletal problems? (Put a Y for YES and N for NO on the line)

• _Weakness in any of your arms, hands, legs, or feet?

• _Back pain?

• _ Difficulty fully moving your arms and legs?

• _Pain or stiffness when you lean forward or backward at the waist?

• _Difficulty fully moving your head up or down?

• _ Difficulty moving your head side to side?

• _Difficulty bending at your knees?

• _Difficulty squatting to the ground?

• _Difficulty climbing a flight of stairs or a ladder carrying more than 25 lbs.?

6. In the past year (Put a Y for YES and N for NO on the line)

• _ Have you had repeated feelings of numbness, tingling, or "pins and needles" sensations in one or both hands or one or both feet

• _ Have you had repeated feelings of soreness or pain in either forearm or elbow

7. Have you ever (Put a Y for YES and N for NO on the line)

• _Deliberately harmed yourself in any way?

• _Deliberately harmed someone else or someone's property?

• _Had a drug or Alcohol dependency or misuse including prescription drugs, non-prescription drugs or recreational drugs?

8. Do you take medications at work or before work which you believe could affect your physical or mental function or performance? Yes _No Don't Know

9. Are you currently under medical care for any emotional or mental illnesses?

Yes No Don'tKnow I hereby certify that all of my statements and answers are true and complete, and I understand that any misstatement of material fact may subject me to disqualification or dismissal and may cause forfeiture of all rights to employment.

Signature in full: _ _ _ _ _ _ _ _ _ _ _ _ _ _ Date: _ _ _ _ _ _ __

Reviewer: - - - - - - - - - - - - - - - - - Date:* - - - - - - - - -

Comments:- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

2