installed to meet ASME B31.1, Standard for Pressure. Piping: B31.1 incorporate
ASNT Recommended. Practice No. SNT-TC-1A: Personnel Qualification and.
w x ME OPINION PAPER
PBTapproach Incorporating a Performance-based Testing Approach to Qualify Nuclear Nondestructive Testing and Quality Control Personnel by A.M. (Marty) Wenzig, Jr.
From Materials Evaluation, Vol. 70, No. 5, pp: 521–524. Copyright © 2012 The American Society for Nondestructive Testing, Inc.
The following paper contains the opinion of the author and does not necessarily reflect the opinion of ASNT or its Board of Directors.
T
he majority of inspectors and examiners used by nuclear utilities for outage purposes are contract workers provided by third-party nondestructive testing (NDT) suppliers. Contractually, there are a number of citations in commercial nuclear codes and standards that require technical assessments when qualifying NDT and quality control personnel. However, this approach falls short when trying to determine if an individual is able to perform his or her job function in-plant. Incorporating human performance assessments, while using a performance-based testing (PBT) approach, provides for more meaningful personnel assessments. The provisions of the American National Standards Institute (ANSI) and American Society for Nondestructive Testing (ASNT) standard ANSI/ASNT CP-189: ASNT Standard for Qualification and Certification of Nondestructive Testing Personnel (1995), as augmented by the American Society for Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, and governed by the U.S. Nuclear Regulatory Commission (NRC) Code of Federal Regulations (10 CFR 50.55a), delineate the NDT requirements for personnel qualification and certification for the in-service inspection of nuclear power plant components (ASME, 2007; ASNT, 1995; NRC, 2011).
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Regulation 10 CFR 50.55a also applies to components, parts and systems originally constructed and installed in accordance with ASME Boiler and Pressure Vessel Code, Section III (ASME, 2008). For the balance of plant components, parts originally constructed and installed to meet ASME B31.1, Standard for Pressure Piping: B31.1 incorporate ASNT Recommended Practice No. SNT-TC-1A: Personnel Qualification and
Figure 1. Individual taking a general (closed book) test.
Figure 2. Individual taking a specific test with access to materials.
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Certification in Nondestructive Testing (ASME, 2001; ASME, 2008; ASNT 1992). While the term nondestructive examination is used in the commercial nuclear industry, it is synonymous with NDT as used here. An NDT individual who performs tests in-plant typically qualifies to Level II competency by completing a series of examinations, including both written and practical tests that are administered by a Level III individual. The written examinations challenge the knowledge base of the individual. The general test shown in Figure 1 is a closed book examination where the individual is tested on his or her knowledge of the testing method. Depending on the examination format, the individual is subjected to a multitude of comprehensive questions about the particular testing method: techniques used in that method, associated inspection equipment and method applications. A time constraint is typically placed on this examination. Typically, the individual must achieve at least a 70% grade on this examination. SNT-TC-1A (1992), ANSI/ASNT CP-189 (1995) and ASME NQA-1 require a minimum of 70% on employer-administered tests with a composite score of at least 80% on the combined method, specific and practical tests (ASME, 2007; ASNT, 1992; ASNT, 1995). ASME Section XI, Appendix VII (identified in 10 CFR 50.55a), requires a passing grade of 80% for each test regarding ultrasonic testing personnel (ASME, 2007). The specific test makes the individual use procedures, graphs, charts, photographs and scenarios to determine answers to comprehensive questions, as shown in Figure 2. The number of questions in this test is determined by code requirements. The specific test challenges the individual’s ability to read and to derive answers based on the information provided. Normally, questions related to conditions and usage of acceptance criteria are utilized. It is commonplace to establish a time limit for this test. The practical test is normally timed and requires the person to demonstrate his or her proficiency in the test method by examining a test sample (or samples) and detecting discontinuities or conditions, as in Figure 3. The administrator is required to assess the individual’s proficiency in use of equipment and technique, proper adherence to procedure, test sequencing, calibrations, materials, documentation and extent of tests. The accuracy and completeness of interpretations, evaluations and documentation of the activities and test results are assessed as well. These practical exam elements are incorporated into a multipoint checklist. The series of topics previously described is a basis for the test administrator to perform a practical test qualification assessment.
The completed checklist serves as objective evidence of the assessment results. The qualification and certification of quality control inspectors are addressed in the provisions of ASME NQA-1, Quality Assurance Requirements for Nuclear Facility Applications (Supplements 2-S1 and 2-S2, and Appendix 2-A1) and ANSI N45.2.6 (ASME, 1994; ANSI, 1978). Regarding initial qualification of quality control Inspectors, ANSI N45.2.6 and ASME NQA-1, Supplement 2-S1 state, “The capabilities of a candidate shall be determined by a suitable evaluation of the candidate’s education, experience, training, and either test results or capability demonstration” (ASME, 1994; ANSI, 1978). Because of this, suppliers may, but are not required to, utilize testing as a means to evaluate quality control inspection personnel. Also, as referenced in ASME NQA-1, Code Interpretation (QA90-006), predicated on the supplier’s qualification program, they may, but are not required to, use a Level III when qualifying Level IIs (ASME, 1994). While testing and capability demonstrations may programmatically meet the imposed code requirements, arguably, there is one concept not being fully assessed. U.S. NRC Regulatory Guide (Reg. Guide) 1.58 provides comments and position statements regarding ANSI N45.2.6 (ASME, 1978; NRC, 1980). Reg. Guide 1.58 was withdrawn in 1991; however, a number of utilities continue to commit implementation of these comments to the regulator. Of significance, Reg. Guide 1.58 provides Comment 10 regarding ANSI N45.2.6, pointing out that Section 2.2, Determination of Initial Capability, and Section 2.3, Evaluation of Performance, both explain “the use of evaluation of job performance and determination of initial capability to perform the job” (ASME, 1978; NRC, 1980). The preceding, particularly the NDT practical test, addresses the individual’s capability to perform the job from a technical perspective. However, it is conceivable to implement the requirements for qualifying quality control personnel without any practical assessment. By incorporating a PBT approach for both the NDT and quality control disciplines, test administrators have the opportunity to assess both technical and human skill elements of the NDT technicians in an inplant atmosphere.
Figure 3. Individual taking an ultrasonic practical test on welding.
With PBT, besides performing a technical assessment, the evaluation also includes assessing an inspector’s human performance skills, or soft skills. This includes evaluating the individual’s knowledge, skills and abilities (KSA), the combination of human knowledge and capabilities required to perform a task. If a KSA deficiency is one of the more frequently identified causes for human error, then testing is the primary means to evaluate KSA proficiency. In testing, human performance depends directly and indirectly on task characteristics and the testing environment presented to the individual (IAEA, 2001).
Performance-based Testing The PBT concept, shown in Figure 4, mimics the principles of the systems approach to training and PBT used by nuclear utilities to implement training required by 10 CFR 50.120 and 10 CFR 55.4 (NRC, 2001; NRC, 2009).
Figure 4. Individual taking a performance-based ultrasonic practical test on thickness.
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To evaluate an individual’s KSA using a PBT testing approach, as a minimum, the following considerations should be included: ● Testing in an environment replicating in-plant conditions with in-place equipment ● Requiring the individual to fully prepare equipment and dress to perform the practical test ● Including in the practical test a work package (associated with the practical test) to review ● Performing the test using the same equipment used in-plant ● Reviewing and implementing a radiation work permit ● Providing software, such as computerized inspection procedures, for review ● Requiring use of safety equipment, including As Low As Reasonably Achievable (ALARA) requirements for the area (NRC, 2012) By staging the practical test in this environment, soft skill competencies can be included in the overall assessment, including: ● Open communication: does the individual speak candidly, concisely and articulately? Are listening and writing skills observed? Does the assessor obtain feedback from the candidate? Does the individual differentiate opinions from fact? ● Adaptability: does the candidate maintain focus during the test? Is the individual flexible if conditions change in the environment during the test? Does the individual know his or her own physical limits? ● Problem identification: can the person identify problems? Does the individual exhibit the ability to complete the inspection when conventional actions or resolutions are not apparent? ● Safety consciousness: does the individual show a questioning attitude? Does the person intelligently follow procedures? Is there a safety consciousness being exhibited? ● Professionalism: is a quality focus being maintained? Is the individual self-critical, willing to admit a mistake, willing to apologize and willing to compromise? The PBT process can be easily incorporated into the testing supplier’s written qualification and certification procedures. When considering the NDT qualification process, implementation of a practical test checklist for technical skill assessment is an existing requirement. A recommendation is to include and implement a human performance skill checklist concurrently. The overall practical test grade can be obtained by assigning a weighted value to each portion. While aggressive in concept, the PBT approach can be used in the qualification process for quality control inspectors.
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Conclusion While not a panacea, implementing a PBT approach provides avenues of information that can be shared with the utility. PBT supports completing technical and human performance skill assessments. The process can assist in identifying correctable weaknesses, while improving the abilities of the inspector. w x AUTHOR A.M. (Marty) Wenzig, Jr.: Industrial Testing Laboratory Services, 635 Alpha Dr., Pittsburgh, Pennsylvania 15238; e-mail
[email protected]. REFERENCES ANSI, ANSI/ASME N45.2.6: Qualification of Inspection, Examination, and Testing Personnel for Nuclear Power Plants, American National Standards Institute, New York, New York, 1978. ASME, ANSI/ASME NQA-1: Quality Assurance Requirements for Nuclear Facility Applications, Supplements 2-S1 and 2-S2, Appendix 2-A1, The American Society of Mechanical Engineers, New York, New York, 1994. ASME, ASME B31, Standard for Pressure Piping: B31.1 – Power Piping, The American Society of Mechanical Engineers, New York, New York, 2001. ASME, Boiler & Pressure Vessel Code Section III (Division 1): Rules for the Construction of Nuclear Facility Components, The American Society of Mechanical Engineers, New York, New York, 2008. ASME, Boiler & Pressure Vessel Code Section XI: Rules for Inservice Inspection of Nuclear Power Plant Components, The American Society of Mechanical Engineers, New York, New York, 2007 edition with 2008 addenda. ASNT, ANSI/ASNT CP-189: ASNT Standard for Qualification and Certification of Nondestructive Testing Personnel (1995), The American Society for Nondestructive Testing, Inc., Columbus, Ohio, 1995. ASNT, Recommended Practice No. SNT-TC-1A: Personnel Qualification and Certification in Nondestructive Testing (1992), The American Society for Nondestructive Testing, Inc., Columbus, Ohio, 1992. IAEA, A Systematic Approach to Human Performance Improvement in Nuclear Power Plants: Training Solutions, International Atomic Energy Agency, Vienna, Austria, March 2001. NRC, Code of Federal Regulations, Title 10: Energy – Part 20.1003 Definitions, U.S. Nuclear Regulatory Commission, Washington, D.C., 31 January 2012. NRC, Code of Federal Regulations, Title 10: Energy – Part 50.120 Training and Qualification of Nuclear Power Plant Personnel, U.S. Nuclear Regulatory Commission, Washington, D.C., 12 June 2009. NRC, Code of Federal Regulations, Title 10: Energy – Part 50.55a Codes and Standards, U.S. Nuclear Regulatory Commission, Washington, D.C., 2011. NRC, Code of Federal Regulations, Title 10: Energy – Part 55.4 Operators’ Licenses, U.S. Nuclear Regulatory Commission, Washington, D.C., 17 October 2001. NRC, Regulatory Guide, 1.58 (Revision 3) – Power Reactors (Division 1): Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel, (withdrawn 31 July 1991), U.S. Nuclear Regulatory Commission, Washington, D.C., September 1980.
