-Dominion Energy Kewaunee, Inc. · The November 4, 2013, requested approval date for the submittal...

-Dominion Energy Kewaunee, Inc. 0Do5000 Dominion Boulevard, Glen Allen, VA 23060 minionWeb Address: www.dom.com

September 17, 2013

U. S. Nuclear Regulatory Commission Serial No. 13-278AAttention: Document Control Desk LIC/CDS/ROWashington, DC 20555-0001 Docket No. 50-305

License No. DPR-43

DOMINION ENERGY KEWAUNEE, INC.KEWAUNEE POWER STATIONRESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDINGREQUEST FOR APPROVAL OF SHIFT MANAGER / CERTIFIED FUEL HANDLERTRAINING PROGRAM

By letter dated June 17, 2013 (Reference 1), Dominion Energy Kewaunee, Inc. (DEK),requested approval of the Kewaunee Power Station (KPS) Shift Manager / CertifiedFuel Handler (CFH) Training Program. As stated in that letter, approval of the KPSCFH Training Program is needed to facilitate activities associated with decommissioningand irradiated fuel management as documented in DEK's Post-ShutdownDecommissioning Activities Report and Updated Irradiated Fuel Management Plan.

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request foradditional information (RAI) regarding the CFH Training Program (Reference 2). TheRAI questions and associated DEK response are provided in Attachment 1 to this letter.

The November 4, 2013, requested approval date for the submittal remains unchanged.

Please contact Mr. Jack Gadzala at 920-388-8604 if you have any questions or requireadditional information.

Sincerely,

Paul A. BlasioliDirector - Nuclear Protective Services and Emergency Preparednessfor Dominion Energy Kewaunee, Inc.

Acof

Serial No. 13-278ACFH Training Program RAI Response

of 2

Attachment:

1. Response to Request for Additional Information

Enclosure

1. Procedure TR-KW-101, "Conduct of Training"

References:

1. Letter from Paul A. Blasioli (DEK) to NRC Document Control Desk, "Request forApproval of Shift Manager / Certified Fuel Handler Training Program," dated June17, 2013 (ADAMS Accession No. ML13176A117)

2. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK), "MF1952 (DefueledLicense and TS), MF2370 (Cert Fuel Handler Training Program) RAIs are beingprepared - see attached drafts," dated August 8, 2013

cc: Regional Administrator, Region IIIU. S. Nuclear Regulatory Commission2443 Warrenville RoadSuite 210Lisle, IL 60532-4352

Mr. K. D. FeintuchProject ManagerU.S. Nuclear Regulatory CommissionOne White Flint North, Mail Stop 08-D1511555 Rockville PikeRockville, MD 20852-2738

NRC Senior Resident InspectorKewaunee Power Station

Public Service Commission of WisconsinElectric DivisionP.O. Box 7854Madison, WI 53707

Serial No. 13-278A

ATTACHMENT I

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:REQUEST FOR APPROVAL OF SHIFT MANAGER / CERTIFIED FUEL HANDLER

TRAINING PROGRAM

KEWAUNEE POWER STATIONDOMINION ENERGY KEWAUNEE, INC.

Serial No. 13-278AAttachment 1

Page 1 of 6

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:REQUEST FOR APPROVAL OF SHIFT MANAGER / CERTIFIED FUEL HANDLER

TRAINING PROGRAM

By letter dated June 17, 2013 (Reference 1), Dominion Energy Kewaunee, Inc. (DEK),requested approval of the Kewaunee Power Station (KPS) Shift Manager I CertifiedFuel Handler (CFH) Training Program. As stated in that letter, approval of the KPSCFH Training Program is needed to facilitate activities associated with decommissioningand irradiated fuel management as documented in DEK's Post-ShutdownDecommissioning Activities Report and Updated Irradiated Fuel Management Plan.

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request foradditional information (RAI) regarding the CFH Training Program (Reference 2). TheRAI questions and associated DEK response are provided below.

NRC Question MF2370-RAII-AHPB-Lapinsky-001

When fully implemented, will the Kewaunee CFH training program meet the guidelinesof Regulatory Guide 1.8, Revision 3, "Qualification and Training of Personnel forNuclear Power Plants" that are relevant to a defueled nuclear power plant?

Response:

When fully implemented, the KPS CFH training program will meet the qualificationrequirements provided in KPS TS 5.3.1 (as approved by NRC in Amendment 207).KPS is not committed to Regulatory Guide 1.8, Revision 3. Rather, TS 5.3.1 requiresthat each member of the facility staff shall meet or exceed the minimum qualifications ofANSI N18.1-1971, except for the radiation protection manager, who shall meet orexceed the recommendation of Regulatory Guide 1.8, Revision 1-R, September 1975.


In Sections 5.1 of the submittal, the licensee refers to a document, "TR-KW-101,Conduct of Training", for a listing of responsibilities. Sections 4.1 "Definitions", 6.3.5.d.1"written examinations", 6.7.1 "exemptions", and 6.8.1 "remediation" also make the samereference. Submit the current revision of the document," TR-KW-101, "Conduct ofTraining".

Response:

The current revision of Procedure, TR-KW-101, "Conduct of Training," is provided asEnclosure 1 to this letter. This procedure describes the process for administering and


Page 2 of 6

maintaining the training programs at KPS, including the Shift Manager / Certified FuelHandler Program.

NRC Question MF2370-RAII-AHPB-Lapinsk¥-003

In Section 1.4.3, the licensee concludes that "This program satisfies all requirements forthe Certified Fuel Handler Training Program (also referred to as the CFH)". Thisstatement provides no practical information. The licensee should submit a table with allof the current CFH training requirements, the source document for each requirement,and a description of how the requirement is satisfied by the proposed program. Such atable will reflect how the requirements are satisfied so that, in the future, personnel willknow whether a certain aspect of CFH training must be retained or may be deleted.This table will also be more useful and less misleading if, in the future, requirements areadded or changed by the NRC.

Response:

Procedure TR-KW-101, "Conduct of Training" (discussed in the previous question),references use of 10 CFR 50.120, "Training and Qualification of Nuclear Power PlantPersonnel," which requires a systems approach to training. The table below containsthe current CFH training requirements, the source document for each requirement, anda description of how the requirement is satisfied by the proposed program. The term"TPG" refers to the Shift Manager / Certified Fuel Handler Training Program Guide.Documentation of training, evaluation, and qualification activities are controlled via theShift Manager / Certified Fuel Handler Qualification Manual.

CFH Training Requirement Source Implementation Document/MethodDocument

Prerequisites (high school ANSI N18.1-1971 e TPG Section 6.1.1, Prerequisites.diploma, required experience) o TPG Section 6.1.2, Entry level experience

requirements.* Job Descriptions.

Systematic analysis of job 10 CFR 50.120 o TR-KW-101, Section 3.2, Maintain Total Task List.(requirements analysis) * TPG Approved Task List.

e Shift Manager/Certified Fuel Handler TrainingProgram implements the requirements.

Learning objectives 10 CFR 50.120 e TR-KW-101, Section 3.7, Developing/RevisingTraining Materials.

e Each individual lesson plan.

Training design and 10 CFR 50.120 a TR-KW-101, Section 3.1, Maintaining Trainingimplementation (program Program Guide.design) * Shift Manager/Certified Fuel Handler Training

Program implements the requirements.


Page 3 of 6

CFH Training Requirement Source Implementation Document/MethodDocument

Trainee evaluation 10 CFR 50.120 * TR-KW-101, Section 3.9, Developing/RevisingWritten/Oral Examination; Section 3.14, ConductingExaminations.

9 Shift Manager/Certified Fuel Handler TrainingProgram implements the requirements.

Program evaluation (including 10 CFR 50.120 e Procedure TR-KW-101, Section 3.3, Determiningoperating experience and Training Requirements; Section 3.4, Request forprocess changes) Training Submittal and Review; Section 3.17,

Monitoring Training Programs.

Program content 10 CFR 50.120 • TR-KW-101, Section 3.1, Maintaining TrainingProgram Guide.

e Shift Manager/Certified Fuel Handler TrainingProgram implements the requirements.

Management effectiveness 10 CFR 50.120 e Procedure TR-KW-101, Section 3.15, End-of-review Course Training Feedback; Section 3.17,

Monitoring Training Programs.

Record retention 10 CFR 50.120 e Requirements implemented by ShiftManager/Certified Fuel Handler Training Program(Section 7.0).

Requalification 10 CFR 50.120 a Shift Manager/Certified Fuel Handler TrainingProgram implements the requirements in Sections6.4, Continuing/Refresher Training; and 6.5,Maintenance of Qualification.

Medical requirements N/A * TPG Section 6.1.3, Candidate PhysicalExamination.

Trainer qualifications N/A * Note: CFH instruction is an ancillary job functionperformed by subject matter experts and qualifiedmentors who meet the qualification requirementsestablished in either TS 5.3.1 or TS 3.5.2depending upon their particular role within this jobfunction.


Although the cover letter of the June 17, 2013 submittal states that its CFH trainingprogram aligns with the requirements of 10 CFR 50.120, the program description doesnot include some of the fundamental elements of a Systems Approach to Trainingrequired by 10 CFR 50.120 as defined in 10 CFR 55.4. These elements were listed inthe cover letter but, except for trainee evaluation, were not included in the actualsubmittal. As stated in the licensee's cover letter: "The five key elements of theprogram are: (1) analysis of job performance requirements and training needs, (2)derivation of learning objectives based on the preceding analysis, (3) design andimplementation of the training program based upon learning objectives, (4) trainee


Page 4 of 6

evaluation, and (5) program evaluation and revision." Clarify this discrepancy by

describing how the CFH program implements all five elements of SAT.

Response:

The KPS Certified Fuel Handler Program was developed using the systems approach totraining discussed in 10 CFR 50.120, "Training and qualification of nuclear power plantpersonnel."

The program was developed by Training and Operations personnel using an approvedtask list and creating a task training work matrix. The task training work matrix wasused to determine the initial and continuing training required for each task based on theDifficulty, Importance, Frequency (DIF) process (analysis), which determines if initialand continuing training are required. Learning objectives were determined from the tasklist based on the required knowledge and skills for each task (derivation of learningobjectives). The training materials (lesson plans/exams) and the Shift Manager /Certified Fuel Handler Qualification Manual were then developed from the learningobjectives (design of the training program). The Shift Manager / Certified Fuel HandlerTraining Program Guide was issued, which established the program (implementation ofthe training program). KPS Procedure TR-KW-101, "Conduct of Training," ensures thatthe systems approach to training is used for trainee evaluation and for maintaining andevaluating the Shift Manager / Certified Fuel Handler Program, including an annualreview of the program which is documented and reported to senior management(program evaluation and revision).


Section 5.3.2 requires that the CFH training program be maintained. Who manages theCFH training program? Will that person be a CFH or have equivalent qualifications?

Response:

The Manager Nuclear Operations is responsible for maintaining and implementing theCFH training program. The Manager Nuclear Operations assigns a DepartmentTraining Coordinator, who is typically a Certified Fuel Handler, to assist in theimplementation of the program.

The proposed TS 5.3.2 is identical to the requirement approved by NRC in the currentlyexisting TS 5.4.1 for Millstone 1.


Page 5 of 6

NRC Question MF2370-RAII-AHIPB-Lapinsky-006

In Section 6.2.1, the licensee requires that Shift Managers complete the Plant Operator(PO) Training Program. Describe the PO training program or submit the procedure(s)that control it. Does this program have any relationship to 10 CFR 55, OperatorLicenses? Does the PO training use a Systems Approach to Training?

Response:

The Plant Operator Training Program is designed to train the Plant Operator on theknowledge and technical skills necessary to safely and efficiently monitor and controlthe operations of the KPS spent fuel pool and its support systems during normal andabnormal situations. The program was developed and is being maintained per theelements of the Systems Approach to Training (SAT) process. The program does nothave any relationship to 10 CFR 55, as it is not intended to provide individuals with anNRC operator license.


In its May 29, 2013 letter, Dominion Energy Kewaunee (DEK) submitted a licenseamendment request (LAR) (ADAMS Accession No. ML13156A037) proposing revisionsto its Technical Specifications (TSs). Proposed TS 5.2.2.d states that shift managerswill be CFH-trained. However, the note on page 5 of 23 of the CFH training programsubmitted to the NRC on June 13, 2013 allows personnel to be trained for the ShiftManager position only. Clarify which submittal is correct.

Response:

Both submittals are correct.

Proposed TS 5.2.2.d states that the Shift Manager shall be a CFH. To comply with thisrequirement, the Shift Manager who is used to satisfy the on-shift compliment for theShift Manager position must also be qualified as a CFH.

Although the note on page 5 of 23 of the CFH training program submitted to the NRC onJune 13, 2013 allows personnel to be trained for the Shift Manager position only, suchan individual could not be used to fulfill the TS 5.2.2.d requirement. Only a ShiftManager qualified as a CFH could fulfill the TS 5.2.2.d requirement. Shift Managerswho are not qualified as CFHs are used at KPS for other administrative functions thatare not required by TS. In effect, there are two classes of Shift Managers. Only thosewho are qualified as a CFH would be used to fulfill the TS 5.2.2.d requirement.


Page 6 of 6

References

1. Letter from Paul A. Blasioli (DEK) to NRC Document Control Desk, "Request forApproval of Shift Manager / Certified Fuel Handler Training Program," dated June17, 2013 (ADAMS Accession No. ML13176A117)

2. Email from Karl D. Feintuch (NRC) to Jack Gadzala (DEK), "MF1952 (DefueledLicense and TS), MF2370 (Cert Fuel Handler Training Program) RAIs are beingprepared - see attached drafts," dated August 8, 2013.

Serial No. 13-278A

ENCLOSURE I

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:REQUEST FOR APPROVAL OF SHIFT MANAGER I CERTIFIED FUEL HANDLER

TRAINING PROGRAM

PROCEDURE TR-KW-101, "CONDUCT OF TRAINING"

KEWAUNEE POWER STATIONDOMINION ENERGY KEWAUNEE, GNC.

Kewaunee Power Station

V-7W nAdministrative Procedure

Title: Conduct of Training

Procedure Number Revision Number Effective Date and

TR-KW-101 1 Approvals On File

Revision Summary

This revision 1 procedure includes the following changes:

" Per FIP, changed 1.2 and 5.4.1 .a to reference 10 CFR 50.120 and 10 CFR 55.4 instead of theDecommissioning Position Paper; and added 5.4.1.b

" Made the following format changes (per writer's guide/template):

* Changed the word "Section" to "Subsection" in 3.4.3.a & b; and split both into substeps

" Split 3.6.1, 3.15.5, and 3.16.3 into substeps

" Split 3.7.5 into a note and substep

" Reworded 3.14.2.k.3 and split into a substep

" Split 3.15.1 into two steps

" Reworded 3.17.1 and split into two steps

" Updated 5.2 responsibilities section to proper format

INFORMATION USE

DOMINION TR-KW-101Revision 1

Page 2 of 21

TABLE OF CONTENTS

Section

1.0 PU R PO S E ............................................

2.0 S C O P E ..............................................

3.0 INSTRUCTIO NS .......................................

3.1 Maintaining Training Program Guide (TPG) ............

3.2 Maintaining the Total Task List ......................

3.3 Determining Training Requirements ...................

3.4 Request for Training Submittal and Review ............

3.5 Initiating Alternative Solutions to Training Actions .......

3.6 Initiating Training Solutions ..........................

3.7 Developing/Revising Training Material .................

3.8 Determining Training Methods .......................

3.9 Developing/Revising Written/Oral Examination ..........

3.10 Allocating Instructional Resources ....................

3.11 Scheduling Training ................................

3.12 Presenting Training ................................

3.13 Documentation of Training ..........................

3.14 Conducting Examinations ...........................

3.15 End-of-Course Training Feedback ....................

3.16 Post-Training Feedback .............................

3.17 Monitoring Training Programs ........................

3.18 Exemption/Alternate Qualifications (Ref. 5.4.1.c, 5.4.1 .d) .

3.19 Verification of Qualifications .........................

4.0 R EC O R DS ............................................

4.1 Q A Records ......................................

4.2 Non-QA Records ..................................

5.0 ADMINISTRATIVE INFORMATION ........................

5.1 Com m itm ents .....................................

5.2 Responsibilities ....................................

5.3 D efinitions ........................................

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5.4 References

INFORMATION USE

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2 1


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1.0 PURPOSE

1.1 This procedure describes the basic process in administering and maintaining

SAFSTOR training programs at the Kewaunee Power Station.

1.2 This procedure provides a systems approach to training, as discussed in10 CFR 50.120, Training and Qualification of Nuclear Power Plant Personnel

and defined in 10 CFR 55.4, Definitions. (Ref. 5.4.1 .a and 5.4.1 .b)

2.0 SCOPE

2.1 This procedure applies to all SAFSTOR Training Programs.

2.2 Subsections and steps within this procedure, which describe separate or unique

activities, are NOT required to be performed in sequence and may be selected

and performed independently, as needed, to accomplish specific tasks.

3.0 INSTRUCTIONS

Training Program 3.1 Maintaining Training Program Guide (TPG)Owner

3.1.1 DEVELOP and MAINTAIN Training Program guides for each

appropriate department. As a minimum, the following items should beincluded in the Training Program Guide (TPG):

" PURPOSE

" APPLICABILITY

• REFERENCES

" DEFINITIONS

" RESPONSIBILITIES

" ENTRY LEVEL/EXPERIENCE REQUIREMENTS

" INITIAL TRAINING REQUIREMENTS

" CONTINUING TRAINING REQUIREMENTS

* STANDARDS

" REMEDIATION REQUIREMENTS

3.1.2 CONDUCT annual review of the TPG and DOCUMENT results.

3.1.3 ENSURE all information is correct.

INFORMATION USE

DOMINION

DepartmentTrainingCoordinator

Training ProgramOwner

TR-KW-101Revision 1

Page 4 of 21

3.1.4 REVISE TPG as necessary.

3.2 Maintaining the Total Task List

3.2.1 MAINTAIN Total Task List that, as a minimum, identifies the following:

" Program title

" A list of all tasks or topics (including task number and titles)

* Identification of training documents and evaluation instruments for

those tasks selected for training

3.2.2 CONDUCT a biennial review to ensure the Total Task List accurately

reflects the following:

" All tasks/topics performed by job incumbents

" Tasks/topics selected for training reflect current training documents

and evaluation method

3.2.3 REVISE the Total Task List as needed for changes, such as:

" Identification of new task(s) (i.e., new equipment, modifications)

" Modification of existing tasks

* Selection or de-selection of task(s) for training

3.2.4 DOCUMENT Total Task List changes, including comments

and rationale.

3.2.5 REVISE the training program description and associated trainingdocuments, as appropriate.

3.2.6 APPROVE Total Task List.

3.3 Determining Training Requirements

3.3.1 REFER to the appropriate Training Program Guide for information on

determining Initial and Continuing Training Requirements.

3.3.2 CONDUCT an annual training needs survey by Training Program to

determine additional continuing training requirements.

INFORMATION USE


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3.4 Request for Training Submittal and Review

NOTE: Just-in-Time Training (JITT) should be requested using the following process.

All Personnel 3.4.1 IDENTIFY training needs or recommendations from the

following sources:

" Changes in management expectations

" Human performance trending

" Management feedback

" New or revised procedures or processes

* New or revised regulatory and industry documents

" New tools or test equipment

" Operating experience

" Performance indicators

" Equipment reliability issues

" Personnel performance deficiencies

" Self-assessments

" Plant or equipment modifications

" Student feedback

" Trending reports and audits

" Site Corrective Action Process

3.4.2 FORWARD a request for training to the Training Program Owner.

INFORMATION USE


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Training Program 3.4.3 REVIEW training request.Owner

a. IF the training request duplicates another training request or is NOTa training issue, THEN INFORM the initiator of the status of theprevious training request or the justification for NO training.

1. GO TO Subsection 3.5, as appropriate.

b. IF the training request is valid, THEN ASSIGN to the appropriateDepartment Training Coordinator/Instructor to determine if trainingmaterials need to be developed.

1. TRACK actions through CRS or other appropriate tracking

processes.

2. GO TO Subsection 3.6.

3.5 Initiating Alternative Solutions to Training Actions

3.5.1 IF training is NOT selected, THEN INITIATE any of the followingmethods, as appropriate:

" Procedure change request

" Information sharing

" Job aid

" Human performance review

" Other applicable station processes to address the issue

3.5.2 NOTIFY initiator of any actions to be taken and status of

training request.

INFORMATION USE


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3.6 Initiating Training Solutions

3.6.1 DETERMINE if training is based on a new or modified task.

a. IF training is based on a new or modified task, THEN PERFORM the

following actions:

1. REVISE Training Program Guide, as appropriate.

2. REVISE Total Task List, as appropriate.

3.6.2 DETERMINE if current training documents exist, including documents at

other Dominion fleet sites and training programs.

a. IF current training documents exist and are in need of revision,THEN REVISE training documents before implementation

of training.

b. IF current training documents exist that meet the requested action

and are acceptable to the Program Owner, THEN

SCHEDULE training.

c. IF NO training documents exist, THEN DEVELOP training materials

for Training Program Owner approval.

INFORMATION USE

DOMINION

DepartmentTrainingCoordinator orInstructor

TR-KW-101Revision 1

Page 8 of 21

3.7 Developing/Revising Training Material

3.7.1 DEVELOP lesson plans containing the following:

" Goal of Training

" Learning Objectives

" Prerequisites

" Training Resources

" References

" Commitments

* Evaluation Method

" Operating Experience

" Tasks Associated with Lesson Plan

" Lesson Plan Content

" Summary

3.7.2 DEVELOP lesson plans in any of the following formats:

- Single column

- Two column

- Self-Study Guide

- Power Point Lesson

3.7.3 ORGANIZE lesson plan content using the following techniques:

" Job Performance Order: The learning sequence is the same as the

job sequence

" Simple to Complex: Content may be sequenced in terms ofincreasing complexity

* Critical Sequence: Content is ordered in terms of relative importance

" Known to Unknown: Familiar topics are considered before

unfamiliar topics

INFORMATION USE


Page 9 of 21

3.7.4 DEVELOP handouts, exercises, Power Point presentations, and other

activities to support the training session.

NOTE: Pen and ink changes are acceptable.


DepartmentTrainingCoordinator orInstructor/Trainer

3.7.5 REVISE training material as appropriate.

a. INITIAL and DATE all pen and ink changes incorporated into thelesson plan prior to conducting training.

3.7.6 APPROVE lesson plan.

3.8 Determining Training Methods

3.8.1 CONSIDER the following training methods when developing LessonPlans/Training Materials:

" Lecture

• Demonstration/practice

" Guided discussion

* Self-paced

" Walk through

" Role-playing

" Dynamic learning activities

3.8.2 DETERMINE which training method(s) would be most suitable for thetraining being conducted. More than one training method may beincorporated into any one training session.

INFORMATION USE


Page 10 of 21

3.9 Developing/Revising Written/Oral Examination

3.9.1 DEVELOP, REVISE, or DELETE written test questions which support

specific learning objectives. Test questions shall support the learning

objective being evaluated.

3.9.2 DEVELOP, REVISE, or DELETE oral test questions which support

specific learning objectives. Oral questions administered for qualificationpurposes shall be written down with the answer to ensure reliable andvalid oral boards are conducted.

3.9.3 DEVELOP written or oral examinations in any one of the following

formats or combinations, as appropriate:

" Multiple choice

* True/False

" Matching

" Short answer

3.9.4 WHEN multiple sessions of the training are conducted, THENDEVELOP a minimum of two different exams by varying multiple

versions of the same exam by at least 30 percent.

3.9.5 ROTATE versions of the exam for multiple training sessions.

3.9.6 IF developing a remedial exam, THEN ENSURE the following:

a. Remedial exam differs from the previous exam by at least

30 percent.

b. Areas failed on the previous exam are included.

c. Areas which the trainee previously passed may be included.

Training Program 3.9.7 APPROVE written or oral examination.Owner

INFORMATION USE


Page 11 of 21

3.10 Allocating Instructional Resources

3.10.1 ALLOCATE instructional resources for the purpose of instruction.

a. SELECT instructor/trainer or subject matter expert to conduct

training based on the following:

" Has documented technical expertise on the specific tasks or

duty areas for which trainees will be trained and evaluated

(task qualified)

* Has overall job knowledge

" Maintains high standards of performance and commitment

to quality

" Displays expected professionalism and judgment

* Supports a conservative approach to nuclear safety

" Practices expected observation and communication skills

3.11 Scheduling Training

3.11.1 CONTACT Department Training Coordinators to schedule training.

3.11.2 SCHEDULE and COORDINATE resources to support training requestto include, but NOT limited to, the following:

" Classroom/laboratory space

" Training equipment, as appropriate

" SME support, as appropriate

" Trainees

3.11.3 SCHEDULE off-site training support personnel (e.g., instructors forFirst Aid Training) far enough in advance to ensure NO delays occur inimplementing the training session.

All Personnel


INFORMATION USE


Page 12 of 21

Instructor, Trainer, 3.12 Presenting Trainingor SME

3.12.1 REVIEW lesson plans to ensure familiarity with lesson content,

equipment and tools, and the use of media, text material, references,

and tests.

3.12.2 PREPARE to ensure consistent and effective delivery of lessons and

time management.

3.12.3 PRESENT the training in accordance with the approvedlesson plan/training material.

3.13 Documentation of Training

3.13.1 DOCUMENT completion of training using site Record of Attendance

Form for the following settings:

- Classroom or Laboratory

. Self-Study

3.13.2 DOCUMENT training or performance evaluation for OJT, TPE,Mentoring, Job Familiarization Guide (JFG), Activity Performance

Measure (APM), or other skill based session on the appropriate

qualification document.

3.13.3 FORWARD all completed documentation of training or evaluation toRecords for filing. Examples of training documentation include, but NOTlimited to, the following items:

" Signed and implemented Lesson Plans

" Record of Attendance forms

" Completed OJT and TPE guides, Mentoring guides, JFGs, and APMs

" Written or Oral Examination results

INFORMATION USE


Page 13 of 21

3.14 Conducting Examinations

3.14.1 MAINTAIN examination security by performing one of the following:

a. MAINTAIN possession of the examination material at all times.

b. WHEN NOT in use, THEN KEEP written/oral examinations in asecure location (e.g., an envelope marked CONFIDENTIAL, placedinto a secured, locked exam bag, locked in a desk drawer or in alocked office) until all applicable personnel have completed

the evaluation.

c. WHEN examination material is transferred from one individual to

another, THEN DELIVER by hand, which is the preferred method.

d. IF examination material is sent through the mail, THEN ENSURE thefollowing requirements are met:

" The examination material is in a sealed envelope identified as

examination material (with the sender's signature covered by

transparent tape across the seal).

" The sealed envelope is placed in an unmarked mailing envelope

marked PERSONAL and CONFIDENTIAL.

e. PROTECT examinations in electronic form using passwordprotected files or access restricted folders.

f. MAINTAIN security requirements during examination process(e.g., establishing examination boundaries and controlling access to

the exam area).

INFORMATION USE


Page 14 of 21

3.14.2 ADMINISTER examinations in accordance with the following:

a. PROVIDE the same exam directions to all trainees (e.g., how toselect a response, time limits, acceptable reference materials, etc.).

b. ADMINISTER the exam to all trainees under the same conditions

(e.g., one exam per trainee, standard time limits, same references,

etc.).

c. PROCTOR the examination to the extent necessary to ensure the

exam is NOT compromised.

d. WHEN answering trainee's questions regarding test items, THENPROVIDE only information that clarifies the test item.

e. PROVIDE clarifying information to all trainees.

f. IF administering an oral exam, THEN PRESCRIPT questions and

answers and DOCUMENT trainee's response to each question.

g. COLLECT all copies of exams (including supporting material and

scratch paper) that were distributed.

h. GRADE all exams using the examination key.

i. ENSURE all trainees are given the opportunity to review their

examinations to ensure the correct answers to any questionsanswered incorrectly are understood.

j. DOCUMENT the trainees grade/total points on the exam

cover sheet.

k. IF the trainee fails to achieve a passing score, THEN TAKE the

following action:

1. DETERMINE impact on qualifications.

2. IMPLEMENT remedial training.

3. ADMINISTER remedial exam, which shall be 30% different than

the initial exam.

(a) IF the trainee fails the remedial examination, THEN CONFERwith the appropriate Training Program Owner to determine

actions to be taken.

4. REINSTATE qualifications, if appropriate.

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Training ProgramOwner/TrainingSupervisor

I. For performance based evaluation failures, TAKE the

following actions:

1. DETERMINE impact on qualifications.

2. IMPLEMENT remedial training.

3. CONDUCT reevaluation.

4. REINSTATE qualifications, if appropriate.

3.15 End-of-Course Training Feedback

3.15.1 PROVIDE each trainee a Trainee Feedback Form at the completion of

each training session.

3.15.2 FORWARD completed Trainee Feedback forms to the DepartmentTraining Coordinator.

3.15.3 DOCUMENT trainee feedback on the Trainee Feedback

Summary Form.

3.15.4 FORWARD Trainee Feedback Summary to the appropriate Training

Program Owner.

3.15.5 REVIEW trainee feedback.

a. DOCUMENT and TRACK actions taken.

3.16 Post-Training Feedback

3.16.1 COLLECT post-training feedback on Initial and Continuing Training

within six months after completion of training.

3.16.2 SUMMARIZE post-training feedback using Post-TrainingSummary Form.

3.16.3 EVALUATE feedback.

a. DOCUMENT necessary actions.

b. TRACK actions taken.

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3.17 Monitoring Training Programs

3.17.1 CONDUCT an annual review of training programs, including, but NOT

limited to, the following:

* Progression of job incumbents enrolled in training courses

" Training Program Guide

" Total Task List

" Lesson Plans

* Training Materials

" Written and Oral Examinations

* Training Feedback

" Actions taken to resolve training issues

3.17.2 DOCUMENT and REPORT results to Senior Management.

3.18 Exemption/Alternate Qualifications (Ref. 5.4.1.c, 5.4.1.d)

NOTE: Exemption and Alternate Qualifications shall be reviewed on a case-by-case basis.


3.18.1 REVIEW the following information to determine exemptions and

alternate qualifications:

" Review of previous training, education, and experience records

" Knowledge based examination

* Skill based examination (e.g., TPE/APM/JFG)

3.18.2 DOCUMENT exemption or alternate qualification on the current

qualifying training document and FORWARD completed documentation

to Records.

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Line Supervisor! 3.19 Verification of QualificationsIndividualsDirecting Work 3.19.1 ENSURE training and qualifications are satisfied prior to assigning an

individual a task or an evolution by checking the Training and

Qualification Matrix.

3.19.2 IF a work assignment extends beyond a shift, THEN PERFORM

verification daily.

3.19.3 Do NOT assign individuals to perform tasks or functions independently

for which they are NOT indicated to be qualified.

3.19.4 For qualifications with an expiration date, ENSURE appropriatemeasures are taken to confirm worker qualification throughout the

conduct of the assigned task.

All Personnel 3.19.5 KNOW and MAINTAIN qualifications.

3.19.6 ENSURE training and qualifications are satisfied prior to performing atask or an evolution by using one of the following, as applicable:

" On-line database

* Training/Qualification report matrix hard copy (with the time and date

of report generation) less than or equal to seven days old

" Automatically generated qualification reports

" As approved by the Manager Nuclear Training, in hand paperwork forthe task and all day components or ancillary tasks needed to performthe task

3.19.7 IF a work assignment extends beyond the shift, THEN PERFORM

verification daily.

3.19.8 IF NOT qualified to perform a task independently, THEN NOTIFY

supervisor upon assignment of task.

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4.0 RECORDS

The following QA records and non-QA records are generated by or createdaccording to this document and are listed on the KPS Records RetentionSchedule. These records shall be maintained according to the KPS RecordsManagement Program.

4.1 QA Records

None

4.2 Non-QA Records

None

4.3 The following item(s) completed as a result of this procedure SHALL be records

for retention transmitted to QA records.

" Record of Attendance

* Written or Oral Examination results

" OJT and TPE completions

" Mentoring Guides

" Job Familiarization Guides

" Qualification Manuals

" Activity Performance Measures

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5.0 ADMINISTRATIVE INFORMATION

5.1 Commitments

None

5.2 Responsibilities

5.2.1 Training Program Owners

Training Program Owners are responsible for the following:

a. Maintaining the Training Program Guide.

b. Approving Total Task List.

c. Reviewing/approving Request for Training.

d. Approving Training Materials and examinations.

e. Reviewing and Tracking trainee feedback.

f. Conducting annual review of Training Program.

g. Reviewing and approving exemptions and alternate qualifications.

h. Verifying qualifications when work is assigned.

5.2.2 Subject Matter Experts (SMEs)

Subject Matter Experts (SMEs) are responsible for conducting trainingwhen selected.

5.2.3 Training Supervisors

Training Supervisors (when assigned) are responsible for monitoring

Training Program implementation and evaluation.

5.2.4 Instructors/Trainers

Instructors/Trainers (when assigned) are responsible for:

a. Conducting training.

b. Administering written and oral examinations.

c. Administering performance evaluations.

I

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5.2.5 Line Personnel

Line Personnel are responsible for:

a. Submitting Requests for Training.

b. Validating qualifications prior to conducting work.

5.2.6 Senior Management

Senior Management is responsible for:

a. Overall implementation of Training Programs.

b. Determining supervisory training requirements.

5.2.7 Department Training Coordinator

The Department Training Coordinator is responsible for:

a. Maintaining Total Task List

b. Developing/revising training material

c. Determining training methods

d. Developing/revising Written/Oral exams

5.3 Definitions

5.3.1 Request for Training

A method used to communicate an identified or potential training need

to the training organization. The training request is an input into thetraining organization work process and site action request process.

5.3.2 Subject Matter Expert (SME)

A person who has attained a level of expertise by education,

experience, or plant/vendor task qualification.

5.3.3 Task

A defined unit of work having an identifiable beginning and end,

containing two or more elements.

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5.3.4 Topic

A cluster of common skills and knowledge for training analysis and

design purposes. This cluster is usually fundamental to many tasks asopposed to a unique knowledge or skill for a specific task.

5.3.5 Total Task List

A list of tasks for a specific job or position. This list includes all tasks

selected and non-selected for initial and continuing training.

5.3.6 Training Program Owner

The line manager or supervisor who has direct responsibility for the

determination and approval of the scope and content of a trainingprogram, for the scheduling of training, and for the qualification of their

respective work group(s).

5.4 References

5.4.1 Other

a. 10 CFR 50.120, Training and Qualification of Nuclear Power Plant

Personnel

b. 10 CFR 55.4, Definitions

c. DTO-7.22.B, Prepare exemption request for Operator Requal and

Staffing

d. DTO-7.22.T, Prepare exemption request for training

INFORMATION USE

-Dominion Energy Kewaunee, Inc. · The November 4, 2013, requested approval date for the submittal...

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