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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 Introduction1 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. 2. 3. 4. Develop task lists and qualification guides Identify Additional Program Requirements Review Recent Operating Experience 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 Onofre Nuclear 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 training programs 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 staff successfully 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 Americas nuclear power plants age and struggle to compete with cheaper sources 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 to and 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 as certified 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 staff members 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 for people 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 worker practical 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 its likely that the training staff wont use these documents 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
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For information on why licensed operator training continued during the initial stages of decommissioning at SONGS, refer to Chapter 4.

Revision 0 December 2013 these areas may contain items like halon bottles and fire extinguishers that must 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 employees submit 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 coworkers after 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 with essential 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 attendance information 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 remaining members 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 radiation protection (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 3

Revision 0 December 2013 Division can provide a list of procedures owned by the Training Division. It may 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 are not 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 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 for training, 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 during the initial stages of decommissioning. Table 1: Generic Sources of Information for Training and Qualification Source Applicability INPO ACAD 02-002 NRC rules and associated NUREGs3 10CFR 50.120, Training and Qualification of Nuclear Power Plant Personnel, and NUREG 1220, Training Review Criteria Procedure 10CFR 50.54M, Staffing and Licensed Operator Requirements Discusses administrative withdraw of accreditation2 for plants that are permanently shutdown. 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 initially stated that 50.54M applied to defueled stations. As a result, the NRC required SONGS to submit a license amendment request (LAR) and a revision 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.

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.

Revision 0 December 2013 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 be inspected per Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program. 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 be incorporated 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.

NRC inspection procedures IMC 2561, Decommissioning Power Reactor Inspection Program IP 36801 Organization, Management, and Cost Controls (core procedure) IP 37801 Safety Reviews, Design Changes, and Mods (core procedure) Operating Experience/ Benchmarking

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.

Provides insight to how to structure programs and procedures. Its important to ensure that all of the stations 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. 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 programs for staff that conduct quality-affecting activities should be described in controlled procedures. Provides a broad overview of the entire decommissioning process. Refer to 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). 6

10CFR 50 Appendix B, Quality Assurance Criteria

Regulatory Guide 1.184, Decommissioning Power Reactors

Revision 0 December 2013 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.

Revision 0 December 2013 Table 2: Station-Specific Sources of Information for Training and Qualification Source Applicability Administrative Technical Specifications and Licensee Controlled Specifications Updated Final Safety Analysis Report (UFASR) chapters on training and qualifications Regulatory guides and ANSI documents Contain the legal requirements related to qualifications and training. Technical specifications may commit4 the station to a particular regulatory guide or American National Standards Institute (ANSI) document, which should also be reviewed to ensure requirements are met. 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. Contain requirements related to qualifications and training. These documents should be reviewed to determine the minimum requirements for each training program. Pay particular attention to the revision of the regulatory guide or ANSI document that is discussed in the technical 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. Contains requirements that must be followed as a result of operating experience. 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.

The Corrective Action Program (CAP)

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.

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.