Developing Training Programs for Decommissioning

8/13/2019 Developing Training Programs for Decommissioning

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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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Table of Contents

Introduction 1

Chapter 1: Navigating a Reduction in Force (RIF)

Pre-RIF Activities 2

Post-RIF Activities 3

Chapter 2: Reviewing Sources of Information and

Identifying Training Requirements

Generic Sources of Information 5

Station-Specific Sources of Information 8

Chapter 3: Establishing a Process for Conducting

Training Activities at the Station

Describe the Major Training Activities 9

Identify Roles and Responsibilities 11

Publish the Procedure and Communicate Changes

11

Chapter 4: Establishing Specific Training Programs

Develop Task Lists and Training Materials

13

Develop Procedures to Govern Training Programs

14

Conclusion 16

Appendix A: List of Tables and Figures 17


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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

department.

As Americas 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 qualificationrequirements (Chapters 2)

A process to design, develop, and implement a procedure to govern theconduct of training activities at the station (Chapter 3)

A process to use to design and develop task lists, qualification guides, andtraining 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, attendancerecords, 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 its likely that the training staff wont 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 arestored 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 lockedand contain items that the post-RIF staff may need. It is also possible that

1SONGS staff decided to maintain operator licenses for a period of time after decommissioning. This was

because the NRC originally told Kewaunee that 10CFR 50.54M applied to permanently shutdown plants.


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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 thinkingabout 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 thesebefore 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 organizationchart can identify potential training needs. For example, if radiationprotection (RP) and chemistry departments 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 TrainingDepartment should be reviewed to determine which ones can be voided,

superseded, or revised to eliminate requirements that no longer apply. The


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Procedures Department can provide a list of procedures owned by theTraining Department. It may be necessary to transfer ownership of certain

procedures to other departments. At SONGs, the Engineering Training

Department 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 TrainingDepartment was eliminated post-RIF.

One concept to remember is to take things one RIF at a time. It is only possibleto 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-accreditedtraining programs. However, when a station permanently shuts down, stations are

not required to maintain accreditation or follow guidance contained in INPO

academy documents (ACADs). The following chapter will help training staff toidentify the requirements for training and qualifications that apply to a station in

the 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 accreditation2for 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 andApplicable Program Characteristics (refer to Figure 1for 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.

2Withdraw 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 NRCs 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 SafetyReviews, Design

Changes, and

Mods (core

procedure)

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

available atwww.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. Its

important to ensure that all of the stations unique regulatorycommitments 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 2for a timeline of major decommissioning milestones. The

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

shut down 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


Administrative

Technical

Specifications andLicensee Controlled

Specifications

Contain the legal requirements related to qualifications and training.

Technical specifications may commit4the 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 Department 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.

4To 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.


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Chapter 3: Establishing a Process for Conducting Training

Activities at the Station

One or more events withdraw of accreditation from INPO, cancellation of

training sessions, and the large reduction in the training staff will likely causemany people at the station to think that training will no longer occur. Although the

volume and frequency of training will be considerably less than when the plant wasoperating, the requirements of 10CFR 50.120 will still apply for non-licensed

operator5, chemistry, radiation protection, engineering, and maintenance personnel

(unless the station requests and is granted an exemption6from the rule).

Rule 10CFR 50.120 also directs that training must be derived from a

systems approach to training as defined in 10 CFR 55.4. Rule 10CFR 55.4 describes

the five elements of the systems approach to training (SAT). These five elements,

which are discussed in detail in NUREG 1220, are essentially the same as INPOs

ADDIE model (analysis, design, development, implementation, and evaluation):

A systematic analysis is conducted of the jobs to be performed Learning objectives are derived from the analysis and describe the

desired performance of trainees

Training design and implementation are based on the learningobjectives

Traineesmastery of the learning objectives is evaluated The training program is evaluated and revised based on the

performance of personnel in the job setting

Training staff at SONGS developed a procedure to describe the conduct oftraining activities at the site (titled Conduct of Training). This procedure replaced

the five ADDIE procedures. The next three sections in this chapter describe how to

develop and implement a procedure to govern the conduct of training at a

permanently shutdown facility with reduced staffing.

Describe the Major Training Activities

The procedure written to govern the conduct of training will need to

incorporate all five elements of the SAT process in order to comply with 10CFR

50.120. Staff may choose to review and simplify existing training procedures,modify procedures from other decommissioned stations, or start from scratch.

5This includes the certified fuel handler program, which is described in detail in Chapter 4.6The compliance or regulatory affairs personnel at the station can assist with submission of exemptions

from 10CFR rules.


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SONGS staff used several references to write its procedure: Kewaunees

procedure, NUREG 1220, and SONGs ADDIE procedures. The procedure contains

guidance for conducting the following activities:

Conducting analysis.The procedure directs that each program maintain atask list. The list must identify the tasks that are selected for initial and/or

continuing training. Because curriculum review committees (CRCs) are no

longer required, the procedure requires that a representative sample of job

incumbents review the task list biennially to ensure its accuracy. The

procedure also requires that line managers conduct an annual training needs

survey. This survey solicits feedback from incumbents about the quality of

their training programs and can be used to identify gaps in the program. In

addition, the procedure directs how to address training requests.

Developing learning objectives.The procedure includes direction on howto write learning objectives that contain an action, condition, and standardbased on the job analysis. Examples are included.

Design and implementation. A lesson plan template included as anattachment to the procedure provides guidance on how to create self-study

and/or classroom training materials. A checklist in a separate attachment

provides guidance for how to conduct training in all settings (e.g., on the job

training and classroom training).

Trainee evaluation. The procedure discusses how to create evaluationitems, including written and oral exams. Instructions for maintaining exam

security, proctoring exams, and conducting remedial exams are provided inattachments.

Program evaluation and revision. Observations of incumbents performingwork and observations of training (including OJT) are used to determine

training program effectiveness. These observations are performed by

supervisors, managers, and training staff.

The Conduct of Training procedure also contains guidance for training

activities that support the five elements of the SAT process:

Verifying worker qualifications. All staff must verify qualifications prior toconducting work, and supervisors must verify qualifications prior to

assigning work. The procedure prescribes how to verify qualifications.

Writing training requests. Incumbents need to know how to initiatetraining requests. At SONGS, training requests are initiated via a nuclear


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notification (NN), which is entered into the Corrective Action Program andreviewed by management.

Stations are encouraged to look at similar procedures from other stations

and to simplify their existing procedures to fit the needs of a permanently shutdown

station. When drafting this procedure, the writer(s) should remember thatthe users may not necessarily be INPO-qualified training instructors or even

members of the training staff. They may be job incumbents who are subject

matter experts (SMEs) but not experienced with training. Thus, the procedures

should be written to be as flexible and straightforward as possible if the procedure

users include staff outside of the training organization.

Identify Roles and Responsibilities

At SONGS, personnel involved in training activities include training staff,

training program owners (TPOs), and subject matter experts (SMEs).

The TPO is the line manager of a department (e.g., the Operations Manager is

the TPO for Operations Department). Each TPO is responsible for training activities

in their department. The procedure allows TPOs to delegate training activities to

training staff or to SMEs in their department. Depending on the size of the training

staff, TPOs may have to delegate all training activities to SMEs.

At SONGS, the training staff includes three trainers and one training

supervisor for a population of 200+ job incumbents. There simply are not enough

trainers to perform training activities for each department. As a result, the training

staff provides more coaching and oversight of the training programs than actual

training; the role of the SONGS training staff is to facilitate training of job

incumbents by SMEs.

Publish the Procedure and Communicate Changes

Once a new or revised procedure has been drafted, changes should be

communicated to all affected personnel.

There are several methods to use to inform staff at the station about the

changes. For changes that affect all personnel, several methods should be used inorder to reach the largest audience. For example, if there is a change to the way staff

verify qualifications or enroll in training, then a required reading, site-wide email, or

an announcement in the weekly bulletin may all be required to reach the largest

audience.

If certain staff members are going to have to take on more responsibilities as

a result of post-shut down reductions in force, then it may be best for training staff


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to schedule one-on-one meetings with these individuals to make sure that they are

aware of their new roles and responsibilities. At SONGS, the three trainers each

met with the TPOs to review the procedure with them. In this meeting, the trainers

ensured the TPOs were aware of their responsibilities and the resources available to

them to conduct training activities.

The Conduct of Training procedure is applicable to all training programs;

however, each department will need a procedure to outline the specific

requirements for its training and qualification program(s). The next chapter

discusses the development of training program descriptions for each department.


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Chapter 4: Establishing Specific Training Programs

As discussed in Chapter 3, 10CFR50.120 requires that training programs be

established for non-licensed operator, chemistry, radiation protection, engineering,

and maintenance personnel using a systems approach to training. During the initialstages of decommissioning, training requirements will be substantially less than

when the plant was operating. However, the training programs will need to comply

with all commitments described in the UFSAR, technical specifications, and licensee

controlled specifications until exemptions are granted, as discussed in Chapter 2.

This section describes a process to use to develop training programs for non-

licensed operator, chemistry, radiation protection, engineering, and maintenance

personnel during the initial stages of decommissioning.

Develop Task Lists and Training Materials

The existing task lists for each program should be revised to reflect onlythose tasks that are still relevant to a permanently shutdown station. At SONGS, the

training staff completed an initial revision of the task lists and then asked the

incumbents to review it. A final draft was submitted to each training programowner for review and approval. Task lists should also include new or modified

tasks that may result from reductions in staff, redistribution of workload, and

changes to procedures resulting from decommissioning. The revised tasks lists are

the first step in creating training programs for decommissioning.

After an approved task list has been created, it will be necessary to identify

the learning objectives and training materials associated with the tasks that are

selected for training. A document such as a task to training matrix, which can beproduced from a VISION database, should be developed or revised to indicate the

training materials that contain learning objectives associated with tasks.

It will also be necessary to develop new training materials for each program.

Qualification guides will need to be updated to reflect the tasks associated with

decommissioning. Also, new qualifications will need to be developed. For

Operations Department, certified fuel handlers and certified operators will replace

licensed senior reactor operators and licensed reactor operators (once the certified

fuel handler program is approved by the NRC, as required by 10CFR 50.2).

Many of the people remaining at the station will be able to be exempted from

the new qualifications. Training staff should ensure that all exemptions are

documented properly and that supporting documentation justifies theexemption. Reasons for exemptions should not be vague, such as, So and so has

five yearsexperience doing such and such job. However, So and so has been

qualified as a welder for five years, and inclusion of the individuals qualificationhistory, would be adequate.


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At SONGS, an audit of training and qualifications was performed by theNuclear Oversight Department about five months after the reduction in force. The

audit identified weaknesses in the exemption process, such as lack of supporting

documentation, and vague reasons for qualification exemption. Ensuring that

exemptions are accurate and detailed will prevent rework later.

Develop Procedures to Govern Training Programs

Each training program owner should maintain a training program

description (TPD) procedure (just like they did when the plant was operating). The

TPD should list the requirements of the initial qualification program, requirements

for continuing training to maintain proficiency, and any other requirements related

to training and qualification.

Training staff should review select NRC Inspection Manual Chapters (IMCs)

to identify training program requirements. The following table lists the IMCsapplicable to specific training programs.

Table 3: Sources of Information for Specific Training Programs


IP 36801

Organization,

Management, and

Cost Controls

Describes how inspections will be conducted for compliance with 10CFR

50.120:

A review of training should include an assessment of the licensee's

implementation of 10 CFR 50.120, if applicable. Although the NRC staff

expects that most licensees will apply for full or partial exemption fromthis requirement, requirements still apply to the certification and

periodic training of certified fuel handlers, operators of refueling

equipment, and personnel who perform maintenance and

surveillance of equipment important to safety.

Includes discussion on the certified fuel handler programs:

Operator training should include: normal and abnormal fuel handling

at the spent fuel pool or Interim Spent Fuel Pool Storage

Facility (references 5 and 6); fuel handling accidents and/or

events; and, the identification and mitigation of operatingconditions adverse to the safe storage of spent fuel or highlevel radioactive waste to name a few. An effective training

program could also include, in part, safety evaluations,

modifications, radiation protection, effluent controls, and

design changes.

Includes discussion about general employee training:


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Conclusion

In summary, the goal of the training staff during the initial stages of

decommissioning should be to develop revised task lists, training materials, training

program descriptions, and a procedure to govern the conduct of training activitieswith reduced staff and reduced training requirements (i.e., INPO requirements).

When developing these documents, training staff should keep in mind the

following items:

Simply as much as possible to support a reduced staff. Make processes as flexible as possible. Communicate changes to personnel using the most effective methods. Ensure the procedure that governs the conduct of training activities incudes

each element of the SAT process as described in NUREG 1220.

Trainers still need to be the training conscience for the organization,particularly when it comes to processing exemptions and waivers.

Maintain objective evidence of each phase of the SAT process duringprogram development (e.g., approved task lists, a document that identifies

tasks and their associated training materials, copies of lesson plans and

exams, and training records such as attendance sheets).

Sometimes the decision to decommission a station is announced eighteen

months prior to its permanent shutdown. Other times the decision todecommission plant seems to come suddenly, after a plant has been shut down

for equipment concerns. Either way, the decommissioning will bring about huge

changes in staffing and station activities.

As more stations begin the process of decommissioning, it will be beneficial

for the staff at these stations to learn as much as possible from others in theindustry that have lived through the process. Sharing operating experience and

expertise will enable the staff at these stations to know where to start when astation will be decommissioned.


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Appendix A: List of Figures and Tables

Figures

Figure 1: Elements of the Systematic Approach to Training fromNUREG 1220, Training Review Criteria and Procedures

7

Figure 2: Simple Decommissioning Timeline from Regulatory

Guide 1.184, Decommissioning Power Reactors7

Tables

Table 1: Generic Sources of Information for Training andQualification

5

Table 2: Station-Specific Sources of Information for Training

and Qualification8

Table 3: Sources of Information for Specific Training Programs 14

Documents

Developing Training Programs for Decommissioning