Developing Training Programs for Commercial Nuclear Power Plants in the Initial Stages of Decommissioning

8/13/2019 Developing Training Programs for Commercial Nuclear Power Plants in the Initial Stages of Decommissioning.

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December 2013

Establishing Training Programs to Support

Decommissioning Activities at Commercial Nuclear

Power Plants

A Guide for Training Specialists and Managers

By Lauren Kent, Senior Training Specialist

San Onofre Nuclear Generating Station (SONGS)



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December 2013

Table of Contents

Introduction………………………………………………………………………………………1

Chapter 1: Navigating a Reduction in Force (RIF)

1. Pre-RIF Activities..................................................................................................2

2. Post-RIF Activities................................................................................................3

Chapter 2: Reviewing Sources of Information and Identifying Training

Requirements

1. Generic Sources of Information......................................................................5

2.

Station-specific Sources of Information......................................................8

Chapter 3: Establishing a Process for Conducting Training Activities at

the Station

1. Describe the Major Training Activities

2. Identify Roles and Responsibilities

3. Publish the Procedure and Communicate Changes

Chapter 4: Establishing Specific Training Programs

1. Develop task lists and qualification guides

2. Identify Additional Program Requirements

3. Review Recent Operating Experience

4. Publish the Procedure and Communicate Changes

Conclusion

Appendix A: List of Tables and Figures

Appendix B: Decommissioning Transition Checklist



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Introduction

Written for training specialists and training managers, this guide describes a

process for developing training programs that support the initial stages of

decommissioning. This document was written by a training specialist at San OnofreNuclear Generation Station (SONGS) in San Clemente, CA. In June 2013, the

company that owns SONGS announced that it would decommission both Units 2 and

3. The staff was reduced from 1500 to approximately 500 people just two months

later. The training staff was reduced from 71 to four.

With significantly fewer resources, the training staff worked to develop

programs and procedures for a permanently shutdown station. The training staff

quickly discovered that there is no instruction manual for developing trainingprograms during the initial stages of decommissioning. Guidance from the NRC and

INPO is scattered and sparse. After benchmarking two other stations, conducting a

significant amount of research, and eight months, the SONGS training staffsuccessfully developed a single procedure for the conduct of training at the station

as well as task lists, qualification guides, and training program descriptions for each

division.

As America’s nuclear power plants age and struggle to compete with cheapersources of energy, it is likely that more stations will be decommissioned over the

next few decades. Training staff at these stations will need clear guidance for how

to develop training programs and procedures during the initial stages of

decommissioning. To that end, this document discusses the following items.

Activities that should occur once decommissioning is announced, prior toand following a reduction in force (Chapter 1)

References that should be reviewed to identify training and qualification

requirements (Chapters 2)

A process to design, develop, and implement a procedure to govern the

conduct of training activities at the station (Chapter 3)

A process to use to design and develop task lists, qualification guides, and

training program descriptions for each program at the station, such ascertified fuel handler and general employee training (Chapter 4)



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Chapter 1: Navigating a Reduction in Force (RIF)

It is not uncommon for companies to downsize the staff at a station that is going

to be decommissioned. One major issue for the staff members who remain at the

station is the loss of knowledge that accompanies the RIF. At SONGS, the staffmembers who were selected to stay post-RIF were notified anywhere from one

week to one day prior to the RIF. This left only a very small amount of time for

turnover and transfer of knowledge to occur. The list of pre-RIF activities in this

chapter can be used to ensure that essential knowledge is transferred from the staff

that is leaving to the staff that will remain.

After such a major reduction in staff size, it may take several months for people

to settle into their roles in the new organization structure. It is not uncommon forpeople to have to learn and perform new job functions on a daily basis. At SONGS,

the remaining training staff members had to earn Nantel proctoring qualifications

and take over the administration of general employee training and radiation workerpractical factors training. This period of time can be unsettling, confusing, and

frustrating. The list of post-RIF activities identifies actions that training staff can

take immediately following the RIF to move forward efficiently during this

transition time.

Pre-RIF Activities

Gather and store passwords. Exam banks, exam records, attendance

records, and lesson plans that are saved electronically may require a

password. Gather a list of any passwords that may be required to access

documents. Even if it’s likely that the training staff won’t use thesedocuments ever again, it is possible that staff may need to locate them during

internal and external audits.

Obtain network/database access. At some stations, important files are

stored in various areas of the internal computer network or in databases.

Ask the current network or database owner to grant access for the post-RIF

training staff, as necessary. At SONGS, the licensed operator exam banks

were stored on an internal network, which allowed access only to a handful

of people. Since none of those individuals were staying after the RIF, it was

essential for at least one person on the post-RIF staff to gain access to that

network location in order to conduct licensed operator training activities1.

Obtain keys. There may be locations in the training building that are locked

and contain items that the post-RIF staff may need. It is also possible that

1 For information on why licensed operator training continued during the initial stages of decommissioning

at SONGS, refer to Chapter 4.



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these areas may contain items like halon bottles and fire extinguishers thatmust be inspected on a regular basis.

Submit records. After the RIF is announced, most people will be thinking

about finding a new job, moving, and starting a new life elsewhere. Post-RIF

staff members should work with management to ensure that all employeessubmit training records in their possession, such as lesson plans, completed

remediation plans, attendance records, and exam scores prior to their

departure.

Make a list of contacts. It may be necessary to contact former coworkersafter their departure. Consider connecting on LinkedIn or Facebook with

coworkers, or exchange personal email and/or cell phone numbers.

Additionally, creating a list of contact information for contractors (for

simulator support or other training support) will be helpful.

Identify and learn essential skills. If there are any staff members withessential skills, it may be necessary for the post-RIF staff to learn these

before the RIF. At SONGS, there was one person who processed invoices for

the training department, and he was leaving. Prior to his departure, he

created a simple user guide so that the post-RIF staff could process several

outstanding invoices. Other essential skills may be entering attendanceinformation into a database, submitting records for storage, or

reactivating/renewing operator licenses.

Post-RIF Activities

Inventory the skillset of the post-RIF training staff. The remainingmembers of the training staff should meet shortly after the RIF to discuss

their areas of expertise. At SONGS, the post-RIF training staff consisted of a

supervisor with experience in project management and general employee

training, an engineering training instructor, a non-licensed operator training

instructor, and a licensed operator training instructor. Knowing which skills

each individual has will allow the staff to solve problems faster and

distribute work appropriately.

Review the new organization chart. A review of the new organization

chart can identify potential training needs. For example, if radiationprotection (RP) and chemistry divisions are merged, then it is possible that

RP technicians may be required to perform sampling. If this is a new task for

RP technicians, then training may be required.

Review training procedures. Procedures owned by the Training Division

should be reviewed to determine which ones can be voided, superseded, or

revised to eliminate requirements that no longer apply. The Procedures



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Division can provide a list of procedures owned by the Training Division. Itmay be necessary to transfer ownership of certain procedures to other

divisions. At SONGs, the Engineering Training Division was responsible for

the cyber security training procedure before the RIF. Post-RIF, it was

determined that the Engineering Department should take ownership of this

procedure, since the Engineering Training Division was eliminated post-RIF.

One concept to remember is to take things “one RIF at a time.” It is only possible

to develop and implement programs and procedures for the current state of the

station. Procedures should reflect current business practices, not what might

happen after the next RIF or in five years.

Most training specialists and managers know how to maintain INPO-accredited

training programs. However, when a station permanently shuts down, stations arenot required to maintain accreditation or follow guidance contained in INPO

academy documents (ACADs). The following chapter will help training staff to

identify the requirements for training and qualifications that apply to a station inthe initial stages of decommissioning.



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Chapter 2: Reviewing Sources of Information and Identifying

Training Requirements

This chapter describes the generic and station-specific sources of

information that can help training staff to understand the regulatory basis fortraining, identify training commitments that must be upheld, and identify

commitments that no longer apply.

Generic Sources of Information

Table 1 lists sources of information that are applicable to all stations duringthe initial stages of decommissioning.

Table 1: Generic Sources of Information for Training and Qualification

Source Applicability

INPO ACAD 02-002 Discusses administrative withdraw of accreditation2 for plants that are

permanently shutdown.

NRC rules and

associated NUREGs3

10CFR 50.120,

Training andQualification of

Nuclear PowerPlant Personnel,

and NUREG 1220,

Training Review

Criteria Procedure

10CFR 50.54M,Staffing and

Licensed Operator

Requirements

NUREGs provide guidance on how to implement NRC rules as stated in the

Code of Federal Regulations (10CFR).

Discusses the requirement for training programs to follow a systems

approach to training (SAT) as described in NUREG 1220. These

documents describe the “bare bones” requirements of the SAT process.

Pay close attention to the “REQUIRED ELEMENT” statements and“Applicable Program Characteristics” (refer to Figure 1 for an example

using the second SAT element, learning objectives). This rule is

discussed in further detail in Chapter 3.

Discusses requirements for licensed operators on shift. The NRC initiallystated that 50.54M applied to defueled stations. As a result, the NRC

required SONGS to submit a license amendment request (LAR) and arevision to its administrative technical specifications before it allowed

removal of operator licenses. However, the NRC has recently changed its

position on 50.54M. Refer to Chapter 4 for additional information.

2 Withdraw of accreditation from INPO can be accomplished by submitting a copy of the letter the station

sends to the NRC declaring that the plant is permanently shutdown. Note that the station can retain access

to Nantel for general employee training.



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10CFR 50.82,

Termination of

License

Requires a station to submit written notification to the NRC once the

decision has been made to permanently cease operations and once the

reactor(s) have been permanently defueled. Once both of these steps are

taken, the NRC’s oversight activities at the station change: utilities will beinspected per Inspection Manual Chapter (IMC) 2561, Decommissioning

Power Reactor Inspection Program.

NRC inspection

procedures

IMC 2561,Decommissioning

Power Reactor

Inspection

Program

IP 36801Organization,

Management, andCost Controls

(core procedure)

IP 37801 Safety

Reviews, Design

Changes, and

Mods (core

procedure)

Inspection manual chapters (IMCs) and inspection procedures (IPs) are

available at www.NRC.gov.

Lists the core and discretionary IPs that the NRC will use to evaluate

activities at a permanently shutdown plant. Core procedures will beincorporated into the annual inspection schedule. Discretionary

procedures may or may not be incorporated into the inspection schedule.

Contains information regarding general employee training (GET) and

certified fuel handler (CFH) training requirements. This is discussed in

greater detail in Chapter 4.

Contains information about training related to 50.59 screening and

design changes at permanently shutdown facilities. This is discussed in

greater detail in Chapter 4.

Operating

Experience/

Benchmarking

Provides insight to how to structure programs and procedures. It’s

important to ensure that all of the station’s unique regulatory

commitments are maintained and a systems approach to training is

applied when designing and developing training programs. Refer to

Chapter 4 for additional information on benchmarking and operating

experience.

10CFR 50 Appendix

B, Quality Assurance

Criteria

Describes how to perform quality-affecting activities, which are those

activities that affect safety-related functions of structures, systems, and

components (SSCs). Quality-affecting activities must be described in

controlled procedures or instructions. For example, training programsfor staff that conduct quality-affecting activities should be described incontrolled procedures.

Regulatory Guide1.184,

Decommissioning

Power Reactors

Provides a broad overview of the entire decommissioning process. Referto Figure 2 for a timeline of major decommissioning milestones. The

activities described in this guide may occur before or after the permanent

shutdown of the unit(s).

http://www.nrc.gov/

http://www.nrc.gov/

http://www.nrc.gov/

http://www.nrc.gov/



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Figure 1, Elements of the Systematic Approach to Training from NUREG 1220,Training Review Criteria and Procedures

Figure 2, Simple Decommissioning Timeline from Regulatory Guide 1.184,

Decommissioning Power Reactors

Station-Specific Sources of Information

The table below lists sources that should be reviewed to identify

requirements and commitments that are unique to each station.



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Table 2: Station-Specific Sources of Information for Training and Qualification

Source Applicability

Administrative

Technical

Specifications andLicensee Controlled

Specifications

Contain the legal requirements related to qualifications and training.

Technical specifications may commit 4 the station to a particular

regulatory guide or American National Standards Institute (ANSI)document, which should also be reviewed to ensure requirements are

met.

Updated Final Safety

Analysis Report

(UFASR) chapters on

training and

qualifications

Contain requirements related to qualifications and training. There may

be commitments also stated in the UFSAR. Identify any changes that will

need to be made to the UFSAR. At SONGS, the UFSAR chapter on training

stated that the programs were accredited by INPO. Since accreditation

was withdrawn, this is no longer true. The UFSAR will need to be

updated to reflect this change.

Regulatory guides

and ANSI documents

Contain requirements related to qualifications and training. These

documents should be reviewed to determine the minimum requirementsfor each training program. Pay particular attention to the revision of

the regulatory guide or ANSI document that is discussed in thetechnical specifications and/or UFSAR. Keep in mind when

benchmarking that each station may be committed to different revisions

of the same ANSI document or regulatory guide. As such, requirements

can differ from station to station. The Quality Assurance or Nuclear

Oversight Division will be able to provide the training staff with copies of

these documents.

The CorrectiveAction Program

(CAP)

Contains requirements that must be followed as a result of operatingexperience. There may be CAP products such as corrective actions (CAs)

and corrective actions to prevent reoccurrence (CAPRs) embedded in

procedures. Follow station procedures for removing CAs and CAPRs if

necessary.

A review of these documents will enable training staff to identify program

requirements that must be maintained and those that can be removed. The staff

can now begin developing programs that support decommissioning activities and

meet regulatory requirements. This is the topic of the next chapter.

4 To be “committed” to a regulatory guide or ANSI document means that the station has told the NRC that

it will comply with the guidance contained in that document.

Documents

Developing Training Programs for Commercial Nuclear Power Plants in the Initial Stages of Decommissioning