ANO - Units 1 & 2 - Radiochemistry Personnel Qualifications
See the letter from J. T. Enos (Arkansas Power & Light Company) to E. H. Johnson dated September 6, 1985. Attachment 2 of the letter is a final interpretation provided by the ANS-3 Committee.
Technicians in responsible positions are capable of performing all tasks in the discipline. Less qualified technicians can perform specifically defined tasks (e.g., sample taking, preparation, or analysis). Academic training is not a substitute for experience.
AP&L's initial correspondence with the ANS-3 Committee dated May 28, 1984, stating the company's and NRC Region IV's positions in this matter, and the final interpretation of the ANS-3 Committee dated October 30, 1984, are included as attachments to this letter.
The ANS-3 Committee is responsible for ANSI N18.1 and ANS 3.1 standards on personnel qualifications for nuclear power plants. Although the ANS-3 Committee did not support AP&L's position that academic training (specifically four year science degrees) should not be allowable substitute for much of the experience requirement for radiochemistry technicians specified by ANSI-N18.1-1971, the Standards Committee did emphasize that the current revision of ANSI / ANS 3.1-1981, addresses the qualification requirements for technicians more specifically and that not all technicians must meet the experience requirements for the "responsible" technician.
Two excerpts from the October 30, 1984, ANS-3 interpretation elaborating on these provisions are repeated below:
- "Other lesser qualified technicians within the group can perform other specifically defined tasks such as sample taking, preparation, and analysis.
- "Individuals in training or apprentice positions are not considered technicians or maintenance personnel for purposes of defining qualifications in Section 4, Qualifications, but are permitted to perform work in the job classification for which qualification has been demonstrated.
These individuals may perform work without the direction and observation of qualified individuals if they have previously demonstrated their ability to perform these specific tacks."
AP&L considers this to be representative of the duties of on-shift radiochemists and chemists at ANO, and that lesser qualified individuals, performing with direct supervision and observation, are acceptable, provided that they have demonstrated their ability to accomplish the required tasks.
It is noted that the second statement above is a direct quotation from ANSI / ANS 3.1-1981. Adoption of this position was in effect the recommendation of the ANS-3 Committee since they felt that the 1981 standard had already addressed the specific problem raised herein.
Although the committee did not agree with the position relative to the qualification of a "responsible" technician, they did provide clarification of which job functions require a "responsible" (and therefore fully qualified) technician.
An agreement was reached which appears to be acceptable to both AP&L and NRC. One individual qualified either under provisions of paragraphs 4.4.3 or 4.5.2 of ANSI N18.1-1971 will be on each shift for the radiochemistry and chemistry disciplines. The ANSI qualification can, therefore, be met by either a professional-technical background (minimum 4 year of related technical or academic training and one year of related experience) or a technician background (minimum two years working experience in the specialty).
AP&L was in compliance with ANSI N18.1-1971 when applied in the above discussed manner. There was some uncertainty in the ability to maintain compliance over the next few months.
However, due to additional personnel becoming qualified in December 1985, AP&L was able to commit to maintaining compliance beginning January 1, 1986. Further, as a compensatory action, AP&L was committed to provide an ANSI qualified individual on-call in the event of an unavoidable temporary interruption in full qualified shift coverage due to future personnel turnover problems.
Regulatory references: ANSI N18.1-1971, ANSI / ANS 3.1-1981, Technical Specifications
Subject codes: 1.1, 1.2, 10.1