U.S. Nuclear Regulatory Commission

ANO - Units 1 & 2 - Radiochemistry Personnel Qualifications

HPPOS-096 PDR-9111210202

Title: 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:

1. "Other lesser qualified technicians within the

group can perform other specifically defined tasks such as

sample taking, preparation, and analysis.

2. "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

Applicability: Reactors