Incorporating Human Performance Assessments into Nondestructive Testing and QC Qualification Practices by using Performance-Based Testing

The majority of inspectors and examiners used by nuclear utilities for outage purposes are contract workers provided by third-party NDT suppliers. Contractually, there are a number of citations in commercial nuclear codes and standards that require technical assessments when qualifying nondestructive testing (NDT) and quality control personnel. However, this approach falls short when trying to determine if an individual is able to perform their 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-189-1995, ASNT Standard for Qualification and Certification of Nondestructive Testing Personnel, 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). 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, Standard for Pressure Piping: B31.1 (ASME, 2008), incorporates ASNT Recommended Practice No. SNT-TC-1A: Personnel Qualification and Certification in Nondestructive Testing  ( ASNT 1992).

While the phrase “Nondestructive Examination” (NDE) is used in the commercial nuclear industry, it is synonymous with “Nondestructive Testing” (NDT).    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 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, CP-189 and NQA-1 require a minimum of 70% on employer-administered tests with a composite score of at least 80% onthe combined method, specific and practical tests (ASME, 2007; ASNT, 1995). ASME Section XI, Appendix VII (identified in 10 CFR 50.55a), requires a passing grade of 80% for each test regarding ultrasonic examination personnel.\

The specific test makes the individual use procedures, graphs, charts, photographs and scenarios to determine answers to comprehensive questions. The quantity 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. 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 Quality Assurance Requirements for Nuclear Facility Applications (NQA-1, 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 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 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 N 45.2.6 (ASME, 1978; NRC, 1991). This document 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, 1991). 

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 in-plant atmosphere.

Performance-based Testing

The PBT concept mimics the principles of the systems approach to training and performance based-training used by nuclear utilities to implement training required by 10 CFR 50.120 and 10 CFR 55.4 (NRC, 2001; NRC, 2009). 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).

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 dress out 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 ALARA (As Low As Reasonably Achievable) 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 between 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 incorporated easily 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.

Conclusion

While not a panacea, implementing a PBT approach provides avenues of information that can be shared with the utility. PBPT supports completing technical and human performance skill assessments. The process can assist in identifying correctable weaknesses, while improving the abilities of the inspector.

About the Author:

Albert M. Wenzig Jr., resides in Pittsburgh, Pennsylvania and is retired. Previously, he was President / CEO of Industrial Testing Laboratory Services (ITLS). He has a BS in Engineering (Material Sciences) from the University of Pittsburgh. He earned his AS in Welding Technology from the Community College of Allegheny County (CCAC). His diversified NDE training was obtained from Knolls Atomic Power Laboratory, Bettis Atomic Power Laboratory, (NAVSEA) and Watertown Arsenal, from the Department of Defense (DoD), Mr. Wenzig attended various NDE classes sponsored by the Pittsburgh Section of ASNT. His work experience began at the Beaver Valley nuclear power plant as an Inspector. His background continued with a nuclear valve company as a Quality Engineer / Welding Engineer. He was recruited by the Department of Defense, to perform assessments and surveillances on contractors making components for the Naval Nuclear Propulsion Program. Subsequently, Mr. Wenzig served as Quality Manager, Manufacturing Manager and then Vice President Fabricated Products for a major defense / nuclear component fabricator. After working for a consulting company as Mission Manager / Principal Level III / School Director, he became re-employed with ITLS. Mr. Wenzig led a leverage buy-out in 2001. Regarding ASNT, he held all local section offices, including ASNT Pittsburgh Section Chairman (1985 – 1986). Mr. Wenzig was Session Monitor Chair at the ASNT National Conference (2003), presenter at the NDE/NDT Structural Materials Technology for Highways and Bridges (2006). He authored articles on Radiography, Ultrasonics and NDE personnel qualification (Materials Evaluation). Mr. Wenzig also wrote the original ASNT audit checklist for assessing ASNT CP-189 compliance. He provided peer review on the ASNT PTP classroom texts and gave presentations on weld procedure / welder qualifications and leak testing at section meetings. Mr. Wenzig was an American Welding Society (AWS) Certified Welding Educator (CWE), SNT-TC-1A Level III (various methods), NAVSEA Examiner (PT, MT, UT, RT, VT, LT, AI, Metallographic). Currently Mr. Wenzig certifications include; ASNT NDT Level III (PT, MT, RT, UT, VT, LT), and an AWS Certified Welding Inspector (CWI). Outside of ASNT, Mr. Wenzig is a voting member on the American Society for Testing Materials (ASTM) E07 committee. He is a current member of ASNT, AWS, ASME, and ASTM. Other milestones included, co-sponsoring the CCAC AS Degree program in NDT, and defending Private School applications in Quality Control and NDT with the Pennsylvania Department of Education. Personally, he enjoys woodworking, reading, playing a number of musical instruments, and volunteering his services. 

REFERENCES

ASME, ANSI/ASME N45.2.6: ·Qualification of Inspection, Examination, and Testing Personnel for Nuclear Power Plants, The American Society of Mechanical Engineers, New York, New York, 1978.

ASME, ANSI/ASME NQA-1: ·Quality Assurance Requirements for Nuclear Facility Applications, Supplements 2-S1, 2-S2 and Appendix 2-A1, The American Society of Mechanical Engineers, New York, New York, 2008.

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, The American Society for Nondestructive Testing, Inc., Columbus, Ohio, 1995. 

ASNT, Recommended Practice No. SNT-TC-1A: Personnel Qualification and Certification in Nondestructive Testing, 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, DC, 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, DC, 12 June 2009.

NRC, Code of Federal Regulations, Title 10: Energy – Part 50.55a Codes and Standards, U.S. Nuclear Regulatory Commission, Washington, DC, 2011.

NRC, Code of Federal Regulations, Title 10: Energy – Part 55.4 Operators’ Licenses, U.S. Nuclear Regulatory Commission, Washington, DC, 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