ML20246C006
| ML20246C006 | |
| Person / Time | |
|---|---|
| Issue date: | 11/02/1978 |
| From: | Liza Cunningham NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Quick J NUCLEAR SUPPORT SERVICES, INC. |
| References | |
| NUDOCS 8905090234 | |
| Download: ML20246C006 (3) | |
Text
- - _ - - . _ - - - - - - - - - - . _ _ _ _ _ _ _ _ _ --
.. r = =:. .=.. r
- 7. -
%g- QS f j:p
, g.
[]
liDV 2 1378 f! /
h Mr. Joe C. Quick, President Huclear Support Services. Inc. {
1 14055 Jefferson Davis Highway ' -
Woodbridge, VA . 22191 l
.- i Dear Mr. Quick.. ;
Thank you for your letters about the NSS Qualification Plan, including :
copies of the relevant NSS documents. TQ-7030 and QA-6030. You have : '
obviously given a lot of thought and attention to the problems involved :
in meeting the intent of Regulatory Guide 1.8. The relevant ANSI stand- : )
ard, ANSI N18.1-1971, " Selection and Training of Huclear Power Plant "i j Personnel " is about to be updated and re-issued as ANSI /ANS 3.1-1973, '
with the same title. A copy may be obtained from the American Nuclear ,
Society, 555 Horth Kensginton Avenue, La Grange Park. Illinois 60525. ;
In general, we must take the position that all contra'et health physics staff when working under contract to our licensees, meet the provisions ,
of ANSI /ANS 3.1, as adopted by Reg. Guide 1.8. Work is currently under- !
way to revise that Guide, adopting ANSI /ANS 3.1-197S, with certain !
l conditions. That revision is currently scheduled to be issued for
)
co raent in the early spring of 1979.
]
We have compared the provisions of the two l'SS documents with the guidance in our Reg. Guide and in the ANSI /ANS Standards. We conclude that your documents, TQ-7030 and QA-6030 are, for the most part, in acceptable confomance witt that guidance. The only exceptions relate to tne provisions at Secti<.4 4.5.2 in ANSI N18.1-1971 and in its current updating ANSI /ANS 3.1-1978:
(1) The current standard (ARSI 18.1) states that technicians shall have a minimum of two years of working experience in their specialty, and should have an additional year of related technical training.
Assuming that the tern "related technical training' includes academic training in health physics, one year of training would be equivalent to about 500 academic hours.
In your TQ-7030. Section 4.3, the first four sub-sections meet the -
years of working experience requirement; the fifth, 4.3.5 does not. 1 Only the fifth meets the suggested related tecnnical training )
provision. l
~
OW
- i I :
N1102 PDC . - = ..........
r",},j.E"l7 ]" " E _ llfk.... -- . d~" _, ::Eg"..[... . , 2%[.:-hhS- -
~
a_:L=c:~ 1
;;;*;; #a:5
. 2 Ul E 'II^i (2) The revised stancard ( ALSI/A1;S 3.1) states that technicians shall have three year:; of.wrking experience, of which one year shculd be related technical experience.
In your TQ-7030, Section 4.3, the first three sub-sections meet the years of wrking experience requirement; the fourth end fifth. l 4.3.t. and 4.3.5. do not. Again, only the fif tn reets the surgested related technical training provision. l (3) A.s noted in (a) below, we have recomended that ecuivalent cualifi-cation credit be given for one year of workinc experience and for one year of femal schooling. If this chance were to be cade, the first three sub-sections would neet the working experience requirement; the fourth and fif th would not, althouch the fifth would then rect the relatec technical training provision. With regard to the specific cuestions raised in your letter of July 5, . ; i 1976, we have the following cociments:
- a. We agree with the US$ position that an individual with an associate degree in health physics and one year of experience is likely to be as good or better than an individual with no fomal schcoling and three years of experience. We have recccrended that Section 4.5.2 in A1:SI/A1:5 3.1 be adopted in F.cr. Guide 1.8 such as to cive equiv-alent qualification credit for one year of relevant experience, and one year of femal schooling. However, this change, if everyone ccrees, woule not take place until all coments on the Guice are in
- and it is issued in final fom.
- b. The question of what should detemine a year of experience relates to tiro observations about transithft health physics wrkers:
- 1. They often work lone shifts with no days eff--thus acch.ulating cany hours of " experience' in less than one calendar year.
- 2. They are typically employed at such work for less than nine conths during any given year.
We are reluctant to accept any criterion that night encourage excessive overtine hours--with the likely increate in fatigue, t e
" "??' 2"T "N
/'
"'"1 tu...,...
- 5=.7 ====;:.
. . . ." * " ' '"~" -
- .= :::5
--a.----_ : .--_2____
*' ** # .$m:
- j
. ';_.a.. .
3 decrease in worker efficiency, and the resulting additional risks on the job. A possible guideline for equivalency of one year experience eight be: 2030 or rore working hours, accumulated during a total period of not less than 40 weeks at assignments to nuclear plants.
- c. A::SI/ANS 3.1, page 1, clearly defines nuclear power plant experience !
and the conditions under which other kinds of experience may be substituted.
- d. The licensee is responsible for the determination that a temporary 1 health physics technician job assignment is_ in accordance with the relevant guidance, regardless of the position title. The itRC per-forms audits te assure the licensee implaents the responsibility.
Sincerely yours, ,
?
Wr L.tJ. Cunningham, Acting Asst. Dir. Division of Fuel Facilities and Fbterials Safety Office of Inspection and Enforcement
. bec: T. liurphy J. Nehenias
______._.m _._ _ _ _ _}}