U.S. Nuclear Regulatory Commission

Chemistry Technician Training and Qualifications

HPPOS-062 PDR-9111210248

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,

Technical Specifications

Subject codes: 1.1, 1.2, 10.1

Applicability: Reactors