United States Nuclear Regulatory Commission - Protecting People and the Environment

Chemistry Technician Training and Qualifications

HPPOS-062 PDR-9111210248

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, Technical Specifications

Subject codes: 1.1, 1.2, 10.1

Applicability: Reactors

Page Last Reviewed/Updated Monday, June 08, 2015