ML20248H460

Inc - List of Explanations, Changes, and Justifications for Raj CFH Training and Requalification Program

ML20248H460
Person / Time
Site:	Aerotest
Issue date:	08/28/2020
From:	Slaughter D Aerotest
To:	Office of Nuclear Reactor Regulation
References
Download: ML20248H460 (14)

Text

AEROTEST OPERATIONS, INC.

3455FOSTORIAWAY* SANRAMON,CA 94583 * (925)866-1212

• FAX(925)866-1716 August 28, 2020 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 staffs communication ML20177A203 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 with the list of explanations, changes and justifications provided in Enclosure 1. A clean copy of the revised CFH document is included in Enclosure 2.

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

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

incerelyyour~~

D id M. Slaughter, Ph.D.

President, Reactor Administrator, Manager Aerotest Operations, Inc.

Enclosures:

1. List of Explanations, Changes, and Justifications

2. Clean copy CFH program/checklist

Enclosure 1 AEROTEST OPERATIONS, INC.

3455 FOSTORIA WAY

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

• FAX (925) 866-1716 August 28, 2020 List of Explanations, Changes, and Justifications for RAJ CFH Training and Requalification Program In repose to the RAI we have rewritten and renumbered the CFH Training and Requalification Program to add items and to clarify items.

Provide information in response to the following requests or justify why no additional information is required:

1. The CFHTRP covers requalification and retraining, but the NRC staff did not find information on the initial qualification and training requirements to be considered a CFH or CFH Supervisor.

Added sections 2. EXPERENCE/QUALIFICATIONS and Section 4 INTIAL TRAINING PROGRAM.

"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 education in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement. Manual dexterity and mature judgment. 2.2CFH - shall have at least 2 years of experience in irradiated fuel movements and demonstrated knowledge of the relevant NRC regulations and ALARA principles. Classroom education in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement. Manual dexterity and mature judgment. 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 education in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement."

"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 other decommissioning-related activities, and includes training on CFH tasks as well as required fundamental topics. 4. lLectures and Self Study Topics to be covered include: 4.1. lDesign, 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

Enclosure 1 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 Evaluate annunciators; valve, pump, and breaker status indicators; and instrument readings as necessary to determine/perform appropriate remedial actions. 4.2.1 Evaluate the ability to manipulate the controls required to obtain desired operating results during normal 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. 4.2.2 Evaluate 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. 4.2.3 Evaluate 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. 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)."

1.1 Revise the CFHTRP to provide a description of the initial CFHTRP Qualification Training for both the CFH and CFH Supervisor. Indicate lecture/self-study topics appropriate to storage/handling offuel, reactor decommissioning (see RAJ 8, below), and normal, abnormal, and emergency response procedures.

We do not believe the CFH or CHF Supervisor needs training on decommissioning because the fuel needs to be removed from storage before we can decommission the facility.

Added section 2 EXPERENCE/QUALIFICATIONS. See insert above at question 1.0.

1.2. Revise the CFHTRP to indicate the evaluation criteria used to determine initial satisfactory understanding of the topics, including any required on-the-job training, and examinations and passing grades.

Added section 4 INITIAL TRAINING PROGRAM. See inset at question 1.0 1.3. Revise the CFHTRP and/or TSs to indicate the experience and/or qualification requirements needed to be considered eligible to become a CFH and, as necessary, to clarify the experience

Enclosure 1 and/or qualification requirements needed to be considered eligible to become a CFH supervisor.

(See 1.1 above)

Added section 2. EXPERENCE/QUALIFICATIONS. See insert above at question 1.0.

2. The NRC staff did not find information in the CFHTRP that appears to distinguish the training requirements between a CFH and the CFH Supervisor (or Fuel Handling Supervisor; seeproposedTSs 11.3, 12.1.1, and 12.1.4).

Revise the CFHTRP to provide a description of the requalification training/or the CFH Supervisor.

Training requirements are the same for all CFH's. Qualifications are different.

Qualifications are in newly Added section 2. EXPERENCE/QUALIFICATIONS. See insert above at question 1.0.

3. The NRC staff did not find any information in the CFHTRP that indicates if the CFHTRP can be modified without NRC approval.

Added to Section I Purpose "Any changes to CFH traininglrequalification program must be approved by the NRG" Added to Section 1 Purpose. "1.2 The CFH training/requalification program requires approval by the Nuclear Regulatory Commission. The CFH training/requalification program is to be reviewed periodically by the Reactor Safety committed and any changes to CFH training/requalification program must be approved by the NRC."

4. NUREG-1537, Part 1, Section 17.2.1.2, "Technical Specifications," states, in part, "[t}he technical specifications should contain a section describing the facility administration ...

necessary to ensure continued management of the facility and should describe personnel and programs for specified surveillance and maintenance activities." In its review of the proposed TSs, the NRC staff did not find a complete description of the roles and responsibilities of the CFH and CFH Supervisor, or a requirement to implement and maintain the CFHTRP.

4.1. Revise the proposed TSs to provide a complete description of the roles and responsibilities of the CFH and CFH Supervisor in supporting ARRR emergency response and safe conduct of decommissioning activities (see RAJ 8, below), in addition to fuel handling activities. This description should also explain that the CFH and CFH Supervisor are replacing the NRC-licensed RO and SRO.

Added to 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 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

Enclosure 1 systems needed for safe storage of spent fuel, including the safe handling and storage of spent fuel, and response to plant emergencies.

Added to 3 DUTIES "3.1 CFH Supervisor - Supervise other CFH and perform CFH duties. 3 .2 CFH - The certified fuel handler is intended to be the licensee representative who is present to ensure the safe handling, maintenance and storage of spent 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."

4.2. Revise the proposed TSs to include a requirement to implement and maintain the NRC-approved CFHTRP for CFHs and CFH Supervisors (e.g., "The NRC-approved ARRR CFHTRAININGIREQUALIFICATION PROGRAM/or Certified Fuel Handlers shall be implemented and maintained. )

Added to T.S. 12.1.4 "CFH Supervisor shall maintain qualification by an NRC approved ARRR CHF Training/Requalification program.

5. The NRC stafffound that the CFHTRP provides a description of how the records of each CFH and CFH Supervisor are maintained by the requalification program; however, the NRC staff did not find in the CFHTRP a description of the retention period for each record.

Former VII is renumber Section 8 added "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 biannual 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 or CFH Supervisor are no longer needed."

6. The NRC stafffound that the CFHTRP, Section V, "CFH Evaluation/ Exam-Administration, "

states, in part, "The Aerotest Operations President shall be responsible for the preparation, administration and grading of the written examination. " However, it is not clear to the NRC staff how the current President, or any future President, would be required to be qualified to prepare, administer, and grade the written examination. Additionally, it is not clear whether the President may be a CFH or CFH Supervisor.

Revise the CFHTRP to indicate how the President is required to be qualified to prepare, administer, and grade the written examination. If the President is required to be qualified as a CFH Supervisor, or otherwise may be a CFH or CFH Supervisor, explain how the President

Enclosure 1 would obtain this qualification (e.g., who would prepare, administer, and grade the President's written examination?).

Added sections 2. EXPERENCE/QUALIFICATIONS "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 education in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement."

Added Section 3. DUTIES "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 Safety Committee -Designated member of committee will oversee president's CFH training, testing and evaluate/scores on his Written Test and Job Performance Measures."

7. The NRC staff did not find that the CFHTRP and proposed TSs include any reviews or audits of the CFHTRP.

Revise the CFHTRP and/or provide proposed TSs detailing the required reviews, evaluations, assessments, and/or audits that Aerotest will perform of the CFHTRP to ensure the continuing effectiveness of the program, including by the ARRR Reactor Safeguards Committee.

Added to section 1 PURPOSE "1.2 The CFH training/requalification program requires approval by the Nuclear Regulatory Commission. The CFH training/requalification program is to be reviewed periodical by the Reactor Safety committed and any changes to CFH training/requalification program must be approved by the NRC."

8. The NRC staff did not find that the CFHTRP includes any provisions to ensure that trained individuals have requisite knowledge and experience in reactor decommissioning.

We do not believe the CFH or CHF Supervisor needs training on decommissioning because the fuel needs to be removed from storage before we can decommission the facility.

9. The NRC stafffound that the required periodicity of items in Section III of the CFHTRP is not clear.

Revise the CFHTRP to clearly provide the periodicity of the items listed in Section III Section III ON-THE-JOB CFH TRAINING was deleted. In section 4.2 on the job CFH training (Initial Training) and section 5.2 on the job CFH training details operational items they CFH will learn on the job.

Enclosure 1 "4.2 On the Job CFH Training. 4.2.1 Evaluate 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 the fuel handling tool to obtain desired results during normal, and emergency conditions. 4.2.3 Evaluate 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. 4.2.4 Evaluate 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."

5.2 On the Job CFH Training. 5.2.1 Evaluate 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 the fuel handling tool to obtain desired results during normal, and emergency conditions. 5.2.3 Evaluate 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. 5 .2.4 Evaluate 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."

10. The NRC stafffound that the CFHTRP Section VI (first occurrence) appears to be a typographical error and should be Section IV Revised the CFHTRP to address this apparent typographical error. And renumbered the sections after addition Sections.

Corrected when we rewrote plan.

Enclosure 2 ARRR CFH TRAINING/REQUALIFICATION PROGRAM Revision 8/25/2020 I. 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.

1.2. The CFH training/requalification program requires approval by the Nuclear Regulatory Commission. The CFH training/requalification program is to be reviewed periodically by the Reactor Safeguards Committees and any substantial changes to CFH training/requalification program shall be approved by the NRC. Minor and clarification changes to the program shall require Reactor Safeguards Committee approval only.

1.3. After Initial CFH training, a reoccurring qualification program shall be conducted biannually not to exceed 26 months. (Preference will be given to CFH candidates which maintained successfully a SRO license from a 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 education in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement. Manual dexterity and mature judgment are required.

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 education in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement. Manual dexterity and mature judgment are required.

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 education in the nuclear and radiation related fields of study may be considered in lieu of the experience requirement.

Enclosure 2

3. DUTIES 3.1. CFH Supervisor - Supervise other CFH and perform CFH duties.

3.2. CFH-The certified fuel handler is intended to be the licensee representative who is present to ensure the safe handling, maintenance and storage of spent 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.

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 Safety Committee-Designated member of committee 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 of lectures 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 Evaluate 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 the fuel handling tool to obtain desired results during normal, and emergency conditions.

4.2.3 Evaluate 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.

4.2.4 Evaluate 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.

Enclosure 2 4.3 Comprehensive Final Examination 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. RETRAINING PROGRAM 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 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. Assessment of facility condition and selection of appropriate procedures during normal and emergency situations.

5.1.6. Fuel handling facilities and procedures.

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

Enclosure 2 5.2.2 Evaluate the ability to manipulate the fuel handling tool to obtain desired results during normal, and emergency conditions.

5.2.3 Evaluate 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.

5.2.4 Evaluate 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.

5.3 Comprehensive Final Examination A comprehensive final examination shall be administered at the end of the requalification 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.

6.2 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.

6.3 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. MEDICAL EXAMINATION If required, a medical examination shall be required for the confirmation of the general physical health of the CFH.

Enclosure 2

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 biannual 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 or CFH Supervisor are no longer needed.

Enclosure 2 CHECKIIST for CFH TRAINING/ REQUALIFICATION PROGRAM Period _ _ _ to _ __

The CFH program shall be conducted for a period of two years (not to exceed 26 months) and will be followed by consecutive 24-month programs.

Name: - - - - - - -

CFH No. _ _ _ _ _ (Retired SRO N o . - - - ~

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

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

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

Enclosure 2

___Evaluate 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.

- - -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.

ACTIVE/INACTIVE STATUS

- - -To maintain active status, each CFH shall "actively" performs 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> per program duration of CFH activities.

- - -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 - - -

If required, Medical Exam date _ __