ML13325B015

Vermont Yankee Nuclear Power Station - Request for Approval of Certified Fuel Handler Training Program

ML13325B015
Person / Time
Site:	Vermont Yankee
Issue date:	10/31/2013
From:	Wamser C J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 13-095
Download: ML13325B015 (14)

Text

--- EntergyEntergy Nuclear Operations, Inc.Vermont Yankee320 Governor Hunt RoadVernon, VT 05354Tel 802 257-7711Christopher J. WamserSite Vice President BVY 13-095October 31, 2013U.S. Nuclear Regulatory Commission ATTN: Document Control Desk11555 Rockville PikeRockville, MD 20852

SUBJECT:

Request for Approval of Certified Fuel Handler Training ProgramVermont Yankee Nuclear Power StationDocket No. 50-271License No. DPR-28

REFERENCES:

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of NRC Permanent Cessation of Operations,"

BVY13-079, datedSeptember 23, 20132. Zion Station, Units I and 2, letter dated March 16, 1998, "Requestfor Approval of the Certified Fuel Handler Training and Retraining Program"3. Zion Station, Units I and 2, letter dated July 20, 1998, "Acceptance of Certified Fuel Handlers Program"

Dear Sir or Madam:

By letter dated September 23, 2013 (Reference 1), Entergy Nuclear Operations (ENO) providedformal notification of the intention to permanently cease power operations of the VermontYankee Nuclear Power Station (VY) at the end of the current operating cycle, in accordance with10 CFR 50.82(a)(1)(i).

After certifications of permanent cessation of power operations and of permanent removal of fuelfrom the reactor vessel for VY are submitted in accordance with 10 CFR 50.82(a)(1)(i) and (ii),the 10 CFR 50 license no longer will authorize reactor operation or placement or retention of fuelin the reactor vessel. As a result, licensed reactor operators will no longer be required tosupport plant operating activities.

Instead, approval of a Certified Fuel Handler Training andRetraining Program is needed to facilitate activities associated with decommissioning andirradiated fuel handling and management.

Pursuant to 10 CFR 50.2, ENO hereby requests NRC approval of the VY Certified Fuel Handler(CFH) Training and Retraining Program.

In 10 CFR 50.2, the definition of Certified Fuel Handleris described as "a non-licensed operator who has qualified in accordance with a fuel handlertraining program approved by the Commission."

BVY 13-095 / page 2 of 3A copy of the proposed CFH Training and Retraining Program for VY is provided in theattachment to this submittal.

The program is patterned after the Zion Certified Fuel HandlerProgram which was previously submitted (Reference

2) and approved by the NRC (Reference 3).The VY CFH Training and Retraining Program will ensure that the qualifications of personnel arecommensurate with the tasks to be performed and the conditions requiring response.

10 CFR50.120, "Training and Qualification of Nuclear Power Plant Personnel,"

requires trainingprograms to be established, implemented, maintained, and derived using a systematic approachto training (SAT) as defined in 10 CFR 55.4. The requirements of 10 CFR 50.120 apply toholders of operating licenses issued under Part 50. After permanent cessation of operation andcertification of fuel removal, the VY license will no longer authorize operation of the reactor.

TheVY CFH training program will nonetheless align with the provisions of 10 CFR 50.120. The fivekey elements are: (1) analysis of job performance requirements and training needs, (2)derivation of learning objectives based on the preceding

analysis, (3) design and implementation of the training program based upon learning objectives, (4) trainee evaluation, and (5) programevaluation and revision.

The VY CFH Training and Retraining Program provides adequateconfidence that appropriate SAT based training of personnel who will perform Certified FuelHandler duties is conducted to ensure the facility is maintained in a safe and stable condition.

The program allows for changes to be made to the program without prior NRC approvalprovided the program continues to comply with ANSI/ANS 3.1-1978, "American NationalStandard for Selection and Training of Nuclear Power Plant Personnel,"

consistent with the levelof hazard at the facility and to ensure the facility is maintained in a safe and stable condition.

By a separate submittal, ENO will provide a license amendment request to delete therequirements for Licensed Operators and Senior Reactor Operators and add new requirements for the Certified Fuel Handlers for VY.ENO requests approval of this CFH Training Program by November 1, 2014 in order to supportour timely transition to a permanently shutdown and defueled facility.

This submittal contains no new regulatory commitments.

If you have any questions regarding the content of this submittal, please contact Mr. ColeyChappell at (802) 451-3374.

SincyerCJW/JTMAttachments:

1.Vermont Yankee Certified Fuel Handler Training and Retraining Program BVY 13-095 / page 3 of 3cc: Mr. William M. DeanRegion 1 Administrator U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100King of Prussia, PA 19406-2713 Mr. Douglas V. Pickett, Project ManagerDivision of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O8C2A11555 Rockville PikeRockville, MD 20852-2378 USNRC Resident Inspector Vermont Yankee Nuclear Power StationMr. Christopher

Recchia, Commissioner VT Department of Public Service112 State Street, Drawer 20Montpelier, VT 05620-2601 Entergy Nuclear Operations, Inc.Vermont Yankee Nuclear Power StationDOCKET NUMBER 50-271LICENSE NUMBER DPR-28ATTACHMENT 1VERMONT YANKEE NUCLEAR POWER STATIONCERTIFIED FUEL HANDLER TRAINING AND RETRAINING PROGRAM Vermont YankeeCertified Fuel HandlerTraining and Retraining ProgramTable of ContentsSection Title Page1.0 Introduction

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12.0 Initial Training Program .................................................................

22.1 Eligibility Requirements

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22.2 Fundamentals Training

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22.3 On-the-Job Training (OJT) .................................................

32,4 Candidate Evaluation

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32.4.1 Examination

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32.4.2 Examination Failures

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32.4.3 Exemption of Training Requirements

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42,5 Qualifications

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53.0 Retraining Program ........................................................................

53.1 Eligibility Requirements

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53.2 Retraining

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53.3 Schedule

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53.3.1 Course Schedule

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53.3.2 Missed Training

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63.4 Evaluation of Retraining

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63.4.1 Examinations

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63.4.2 Examination Failures

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63.5 Maintenance of Certified Fuel Handler Qualifications

...... 63.5.1 Requirements to Maintain Qualification

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63.5.2 Exemption of Maintenance of Qualification Requirements

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74.0 Program Evaluation

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75.0 Record Retention

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7Appendix A Written Examination Area, Certified Fuel HandlerTraining and Retraining Program .................................................

8Appendix B Operating Examination Areas, Certified Fuel HandlerTraining and Retraining Program .................................................

9

1.0 INTRODUCTION

The Certified Fuel Handler Training and Retraining Program contained herein describes thetraining program to be implemented by Vermont Yankee Nuclear Power Station (VY) to ensurethe monitoring,

handling, storage and cooling of nuclear fuel is performed in a mannerconsistent with ensuring the public health and safety.The program describes the personnel to whom the program applies, the areas in which trainingis provided, what constitutes certification, how certification is maintained, and requiredqualifications (e.g., medical).

The program shall comply with ANSI/ANS 3.1-1978, "American National Standard for Selection and Training of Nuclear Power Plant Personnel,"

consistent withthe level of hazard at the facility and to ensure the facility is maintained in a safe and stablecondition.

Based on the anticipated permanently defueled status of VY as committed to under10 CFR 50.82(a)(1),

the Certified Fuel Handlers will not be trained as licensed operators;

however, candidates in the training program will meet minimum operator experience requirements of ANS/ANS 3.1-1978.

Changes to this program may be made without priorNuclear Regulatory Commission (NRC) approval provided the program continues to comply withANSI/ANS 3.1-1978.

The VY Certified Fuel Handler Training and Retraining Program will become effective upon:(1) Approval of the Certified Fuel Handler Training and Retraining Program by the NRC,and(2) Amendment of the VY facility license to eliminate the requirements for the NRC LicensedSenior Reactor Operators and Reactor Operators, and the requirement for the associated 10CFR 55 Training Program.Training of personnel can be conducted prior to the Certified Fuel Handler Training andRetraining programs being approved by the NRC or prior to the training program effective date.The Certified Fuel Handler Training and Retraining Programs are not accredited with NationalAcademy for Nuclear Training in accordance with ACAD 02-002, The Process for Accreditation of Training in the Nuclear Power Industry.

Although the program is not accredited, a systematic approach to training (SAT) process will be applied to the Certified Fuel Handler Training andRetraining Program.

The program adheres to the guidelines of NUREG-1220, "Training ReviewCriteria and Procedures,"

Revision

1. Adherence may be demonstrated by compliance withapplicable Entergy fleet training procedures.

As stated immediately above, an SAT process will be applied to the Certified Fuel HandlerTraining Program.

The SAT process contains the following elements:

(1) Analysis of job performance requirements and training needs1 (2) Derivations of learning objectives based upon the preceding analysis(3) Design and implementation of the training program based upon learningobjectives (4) Trainee evaluation (5) Program evaluation and revisions The 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 using a process similar to fleet training procedure EN-TQ-212, Conduct of Training and Qualification.

The Certified Fuel Handler Training Programs consist of an initial training program and arequalification training program (or retraining program) as described below.2.0 INITIAL TRAINING PROGRAM2.1 Eligibility Requirements Candidates for enrollment in the Certified Fuel Handler initial training program shall meet theapplicable requirements of ANSI 3.1-1978, Section 4.5.1.Specifically at the time of appointment to the CERTIFIED FUEL HANDLER position thecandidate shall have:1. High school diploma or equivalent

2. Two years power plant experience; one year of which is nuclear power plantexperience.

At least 6 months of the nuclear experience shall be at VY.3. Possess a high degree of manual dexterity and mature judgmentFor the purposes of the Certified Fuel Handler training program the definition of nuclear powerplant experience listed in ANSI 3.1-1978 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.2.2 Fundamentals TrainingThe fundamental training phase of the Certified Fuel Handler Training Program consists oflecture, and/or self-study of topics appropriate to the monitoring,

handling, storage, and coolingof 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 studyof texts, handouts, and other materials.

Selection of topics will be based on a job analysis for theCertified Fuel Handler tasks and functions.

Depending on an analysis of the candidate's 2

background, self-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, knowledges, andabilities required for successful performance of Certified Fuel Handler job and associated tasks.Typically the fundamental topics 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.2.3 On-the-Job Training (OJT)The on-the-job training phase of the Certified Fuel Handler Training Program includes hands-ontraining of shift operations such as shift turnover, shift record keeping, removal and return ofequipment to service, and specified watchstanding activities.

Watchstanding activities includeon-the-job training in operation of systems/components used to provide handling, storage,cooling, and monitoring of the fuel; normal, abnormal, and emergency procedures; accidentanalysis; Emergency Plan; facility license; and the content, bases, and importance of Technical Specifications.

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.2.4 Candidate Evaluation

2.4.1 Examination

A comprehensive final examination shall be administered at the end of the initial trainingprogram.

The comprehensive examination shall include a written examination and an operating examination.

Areas examined are described in Appendices A and B for the written andoperating examinations, respectively.

The written examination requires a minimum score of 80percent to pass. The operating examination will consist of Job Performance Measures (JPMs).Passing criteria for an individual JPM is that the examinee successfully completes the assignedtask in accordance with the governing procedure without missing any critical steps. Missed orincorrectly performed critical steps are the bases for JPM failure.

Critical tasks for a JPM will bepre-identified as defined in NUREG 1021, Rev. 9, Supplement

1. Each JPM will be scored on apass/fail basis. The candidate must pass at least 80 percent of the administered JPMs tosuccessfully pass the operating examination.

2.4.2 Examination FailuresAn individual who fails to pass either the written or operating examination shall not performCertified Fuel Handler duties until he/she has completed a remedial training program andpasses an appropriate re-examination.

Only those portions of the original examination thatwere failed need to be re-examined (i.e. written or operating exam).3 2.4.3 Exemption of Training Requirements The plant manager (or designee) may exempt an individual from specific training requirements based upon the individual's depth of experience and previous training.

Any exemptions grantedshall be based on an evaluation of the candidate's training and/or work history to ensure that theintent of the exempted training objectives is satisfied.

Such exemptions, including the basis,shall be documented using a process similar to fleet training procedure EN-TQ-212, Conduct ofTraining and Qualification.

The requirement for a medical examination shall not be exempted.

Training of current Licensed Operators (i.e. individuals who hold a current NRC issued VYReactor Operator or Senior Reactor Operator License) may be evaluated to determine if theysatisfy all of the requirements of this training

program, or if they only need to complete portionsof this program to qualify as a Certified Fuel Handler.

This evaluation will focus on thedifferences between the requirements of a Certified Fuel Handler and a Licensed Operator toidentify any additional training required to become a Certified Fuel Handler.

Examples mayinclude an examination on Technical Specifications, fuel handling, and administrative controlsrequired to perform the Certified Fuel Handler function.

The Certified Fuel Handler TrainingProgram allows for the evaluation of other VY personnel to determine if portions of the requiredtraining have already been completed and therefore may be exempted.

The evaluation willconcentrate on required areas to determine if the level of previous training and examination were the same as that required for a Certified Fuel Handler.In general the training of holders of NRC Senior Reactor Operator licenses who are alsoqualified as Fuel Handling Supervisors will meet the qualification requirements for Certified FuelHandler.

However it is expected that some additional training requirements may arise as theplant transitions to a permanently shutdown and defueled configuration.

These additional training requirements may arise from changes to plant systems or procedures associated withSpent Fuel Pool operations.

Therefore the training requirements for Certified Fuel Handler willbe specifically identified and enumerated using the SAT process prior to permanent defueling.

The training history of each currently licensed Senior Reactor Operator who is identified as acandidate for Certified Fuel Handler qualification will be separately evaluated to ensure that allthe specific training requirements of the Certified Fuel Handler training program are met.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 Certified Fuel Handler.The plant manager (or designee) shall approve the basis for evaluations qualifying an individual as a Certified Fuel Handler.4

2.5 Qualifications

All candidates shall satisfy the following requirements:

(1) Complete the Certified Fuel Handler Training Program or have the requirement exempted per Section 2.3.3(2) Score ? 80 percent on a written examination (3) Pass a 80 percent of the administered JPMs on the operating examination (4) Pass a medical examination by a physician to determine that the candidate's medicalcondition is not such that it might cause operational errors that could endanger otherplant personnel or the public health and safety3.0 RETRAINING PROGRAM3.1 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 trainingprogram.3.2 Retraining All certified fuel handlers will participate in retraining program.

The Certified Fuel HandlerRetraining Program 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 bebased upon the tasks selected during program development for the retraining cycle. A retraining plan will be developed and will be approved by the plant manager (or designee).

The trainingplan will be developed utilizing the SAT process described in Section 2.1. Retraining willtypically include a review of changes associated with the facility and procedures, as well asproblem areas associated with the monitoring,

handling, storage, and cooling of nuclear fuel,and selected topics from the initial training program.3.3 Schedule3.3.1 Course ScheduleThe Certified Fuel Handler Retraining Program shall be administered in a biennial training cycle.This cycle includes annual operating examinations and biennial written examination.

Biennialand annual are as defined in NUREG-I 021, "Operator Licensing Examination Standards forPower Reactors",

Rev. 9, Supplement 1.5 3.3.2 Missed TrainingAny missed training or examination must be made up within 90 days of the missed trainingactivity.

If required training or evaluation is not completed within the specified makeup period,the Certified Fuel Handler shall be suspended from Certified Fuel Handler duties, pendingsuccessful completion of the missed training or evaluation.

3.4 Evaluation of Retraining

3.4.1 Examinations

Participants in the Certified Fuel Handler Retraining Program must pass a biennial writtenexamination and an annual operating examination to maintain their qualification.

Areasexamined are described in Appendices A and B for the written and operating examinations, respectively.

The written examination requires a minimum score of 80 percent to pass. Theoperating examination will consist of JPMs and each JPM will be scored on a pass/fail basis.Passing criteria for an individual JPM is that the examinee successfully completes the assignedtask in accordance with the governing procedure without missing any critical steps. Missed orincorrectly performed critical steps are the bases for JPM failure.

Critical tasks for a JPM will bepre-identified as defined in NUREG 1021, Rev. 9, Supplement

1. Each JPM will be scored on apass/fail basis. The candidate must pass at least 80 percent of the administered JPMs tosuccessfully pass the operating examination.

Periodic written and/or operating exams may be administered during the retraining cycle toassess student knowledge and training effectiveness.

3.4.2 Examination FailuresAn 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 iscompleted and an appropriate re-examination is passed. Only those portions of theexamination that were originally failed need to be successfully re-examined prior to restoring qualifications (i.e. written or operating exam).3.5 Maintenance of Certified Fuel Handler Qualifications 3.5.1 Requirements to Maintain Qualification To maintain the Certified Fuel Handler qualification, the following requirements must be satisfied or they may be exempted per Section 3.4.2:(1) Complete all required Certified Fuel Handler Retraining (2) Score -80 percent on the biennial written examination 6

(3) Pass > 80 percent of the administered JPMs on the annual operating examination (4) Pass a biennial medical examination by a physician to determine that the Certified FuelHandler's medical condition is not such that it might cause operational errors that couldendanger other plant personnel or the public health and safety(5) Stand the designated Certified Fuel Handler watch for a minimum of eight (8) hours percalendar quarter.

A Certified Fuel Handler who fails to meet this time requirement canregain qualified status by serving eight (8) hours of watch under the instruction of aqualified Certified Fuel Handler.

The time under instruction should include a review ofthe spent fuel pool cooling system and shift turnover procedures.

An individual who fails to meet any of the requirements for maintaining the Certified FuelHandler qualification shall be removed from all duties associated with that position until suchtime as the discrepancies can be resolved.

The Operating Shifts shall be notified of theindividual's removal and subsequent status.3.5.2 Exemption of Maintenance of Qualification Requirements The plant manager (or designee) may exempt an individual from a specific retraining requirement.

Such exemptions, including the basis, shall be documented using a processsimilar to fleet training procedure EN-TQ-212, Conduct of Training and Qualification.

Therequirement for a biennial medical examination shall not be exempted.

An individual shall notbe exempted from the annual operating or biennial written examinations unless that individual prepared the examination.

No individual may be exempted from any two consecutive annualoperating exams. No individual may be exempted from any two consecutive biennial writtenexaminations.

4.0 PROGRAM EVALUATION As part of the training

process, routine assessments of the effectiveness and accuracy oftraining are conducted by appropriate VY management personnel during and at the end of eachtwo (2) year training cycle. Evaluation results shall be reviewed by a station oversight board asdefined in site procedures.

The station oversight board will verify the resolution of anydiscrepancies identified by the evaluation.

Any required changes to the program determined bythe station oversight board, shall be incorporated into the program.5.0 RECORD RETENTION Records associated with the Certified Fuel Handler Training and Retraining Program will beretained in retrievable format for the duration of the plant license.7 APPENDIX AWRITTEN EXAMINATION AREASCERTIFIED FUEL HANDLER TRAINING AND RETRAINING PROGRAMThe written examination shall include a sample of the following aspects of the Certified FuelHandler 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 ariseduring normal, maintenance, and abnormal activities.

(4) Principles of heat transfer, thermodynamics, and fluid mechanics as they apply to fuelhandling,

storage, cooling, and monitoring.

(5) Conditions and limitations of facility

license, including

content, basis and importance ofTechnical Specifications.

(6) Assessment of facility condition and selection of appropriate procedures during normal,abnormal and emergency situations.

(7) Fuel handling facilities and procedures.

S APPENDIX BOPERATING EXAMINATION AREASCERTIFIED FUEL HANDLER TRAINING AND RETRAINING PROGRAMThe operating examination will consist of Job Performance Measures and shall include a sample ofthe 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 resultsduring normal, abnormal, and emergency conditions.

This includes the spent fuel poolcooling system and those auxiliary and emergency systems that could affect the release ofradioactive 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 arelease or determine appropriate remedial actions for an alarm condition.

(4) Evaluate abnormal or emergency conditions to determine if the emergency plan for thefacility should be implemented and, if implemented, evaluate performance of duties asrequired by the emergency plan.9