U.S. Nuclear Regulatory Commission
Chemistry Technician Training and Qualifications
Title: Chemistry Technician Training and Qualifications
See the memorandum from B. Murray to W. Fisher dated
January 31, 1984, and the incoming request from W. Fisher
dated January 31, 1984. It discusses chemistry technicians
in responsible positions. New hires cannot fill
responsible positions unless they have two years
experience. Experience may be gained in either a
radiochemical or secondary laboratory, and experience may
also be gained preoperationally. HPPOS-096, a letter from
J. T. Enos (Arkansas Power & Light Company) to E. H.
Johnson dated September 6, 1985, contains a related topic.
During inspections of a licensee's chemistry programs, the
interpretation of ANSI N18.1-1971 in regard to chemistry
technician (or Chem Tech) qualifications was questioned.
The Region IV position had been that all Chem Techs must
meet the ANSI N18.1-1971 education and qualifications
before issuance of an operating license at preoperational
facilities, and at licensed facilities, all newly hired
Chem Techs must meet the ANSI qualifications. Region IV had
also taken the position that if a technician was assigned
responsibilities in a radiochemical laboratory, the
technician must have 2 years experience in a radiochemical
laboratory and the equivalent requirements applied to
technicians assigned responsibilities in a secondary
laboratory. This issue has generic implications at many
plants and in other departments besides chemistry,
therefore, guidance was sought of NRR so as to have
consistent enforcement throughout the industry. It should
be noted that inspection Procedure 83523 requires
preoperational inspections in two areas that relate closely
to ANSI N18.1-1971.
Inspection Procedure 83523-02.01b relates closely to N18.1
Section 5. The inspector should determine whether the
licensee has or will have a training program in accordance
with Section 5.1 and 5.3 and whether that training program
ensures Chem Techs are trained in one or more of the three
ways described in Section 5.3.4.
Inspection Procedure 83523-02.02a relates closely to N18.1
sections 4.1 and 4.5.2. The inspector should determine
whether the sampled Chem Techs have received or will have
received experience and education in accordance with
Section 4.5.2, so that the objectives of Section 4.1 may be
reached. Section 4.5.2 requires two years of "working
experience in their specialty." Both years of experience
could be at the plant before OL (Section 2.2.4). One of
the two years could be on-the-job training (Sections 2.2.7
and 4.1). Besides the required experience, Section 4.5.2
recommends one year of related technical training, which
could be obtained at the plant or elsewhere (Section 2.2.6).
If technical specifications will require compliance with
ANSI N18.1-1971, the licensee is expected to comply by OL
issuance. Chem Techs in responsible positions must have 2
years of experience, both of which could have been obtained
at the plant as discussed above. "Chemistry technicians in
responsible positions" are those whose decisions and
actions during normal and abnormal conditions may affect
the safety of the plant (see N18.1 Section 4.1). Unless
the licensee makes an acceptable case to the contrary, all
Chem Techs who perform radiochemistry or coolant chemistry
and who are not in on-the-job training should be considered
to hold "responsible positions."
New hires at operating facilities also should be treated as
above. That is, unless they have 2 years of experience,
they may not fill "responsible positions."
ANSI N18.1-1971 clearly requires that technician experience
be gained in the specialty (e.g., chemistry). Whether
experience was gained in one kind of a laboratory or
another is irrelevant. The important consideration is the
applicability of the experience. The licensee must
determine the applicability.
ANSI N18.1-1971 does not discriminate against
pre-operational experience. As above, the important
consideration is the applicability of the experience. If
the preoperational experience helped prepare the person to
work in a "responsible position, " it should be counted.
Again, the licensee must determine that applicability.
Regulatory references: ANSI / ANS 3.1-1981, ANSI N18.1-1971,
Subject codes: 1.1, 1.2, 10.1