incorporating a performance-based testing approach to qualify

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The following paper contains the opinion of the author and does not neces- sarily 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). Incorporating a Performance-based Testing Approach to Qualify Nuclear Nondestructive Testing and Quality Control Personnel by A.M. (Marty) Wenzig, Jr. w x ME OPINION PAPER PBT approach MAY 2012 • MATERIALS EVALUATION 521 From Materials Evaluation, Vol. 70, No. 5, pp: 521–524. Copyright © 2012 The American Society for Nondestructive Testing, Inc.

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Page 1: Incorporating a Performance-based Testing Approach to Qualify

The following paper contains the opinion of the author and does not neces-sarily reflect the opinion of ASNT or its Board of Directors.

T he majority of inspectors and examiners used by nuclear utilitiesfor outage purposes are contract workers provided by third-partynondestructive testing (NDT) suppliers. Contractually, there are anumber of citations in commercial nuclear codes and standards

that require technical assessments when qualifying NDT and quality controlpersonnel. However, this approach falls short when trying to determine if anindividual is able to perform his or her job function in-plant. Incorporatinghuman 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/ASNTCP-189: ASNT Standard for Qualification and Certification of NondestructiveTesting Personnel (1995), as augmented by the American Society forMechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI,and governed by the U.S. Nuclear Regulatory Commission (NRC) Code ofFederal Regulations (10 CFR 50.55a), delineate the NDT requirements forpersonnel qualification and certification for the in-service inspection ofnuclear power plant components (ASME, 2007; ASNT, 1995; NRC, 2011).

Incorporating aPerformance-basedTesting Approach to Qualify NuclearNondestructiveTesting and QualityControl Personnelby A.M. (Marty) Wenzig, Jr.

wx ME OPINION PAPER

PBTapproach

M A Y 2 0 1 2 • M A T E R I A L S E V A L U A T I O N 521

From Materials Evaluation, Vol. 70, No. 5, pp: 521–524.Copyright © 2012 The American Society for

Nondestructive Testing, Inc.

Page 2: Incorporating a Performance-based Testing Approach to Qualify

Regulation 10 CFR 50.55a also applies to compo-nents, parts and systems originally constructed andinstalled in accordance with ASME Boiler and PressureVessel Code, Section III (ASME, 2008). For the balanceof plant components, parts originally constructed andinstalled to meet ASME B31.1, Standard for PressurePiping: B31.1 incorporate ASNT RecommendedPractice No. SNT-TC-1A: Personnel Qualification and

Certification in Nondestructive Testing (ASME, 2001;ASME, 2008; ASNT 1992).

While the term nondestructive examination is usedin the commercial nuclear industry, it is synonymouswith NDT as used here. An NDT individual whoperforms tests in-plant typically qualifies to Level IIcompetency by completing a series of examinations,including both written and practical tests that areadministered by a Level III individual.

The written examinations challenge the knowledgebase of the individual. The general test shown inFigure 1 is a closed book examination where the indi-vidual is tested on his or her knowledge of the testingmethod. Depending on the examination format, theindividual is subjected to a multitude of comprehen-sive questions about the particular testing method:techniques used in that method, associated inspec-tion equipment and method applications. A timeconstraint is typically placed on this examination.

Typically, the individual must achieve at least a70% grade on this examination. SNT-TC-1A (1992),ANSI/ASNT CP-189 (1995) and ASME NQA-1 require aminimum of 70% on employer-administered tests witha composite score of at least 80% on the combinedmethod, specific and practical tests (ASME, 2007;ASNT, 1992; ASNT, 1995). ASME Section XI, AppendixVII (identified in 10 CFR 50.55a), requires a passinggrade of 80% for each test regarding ultrasonic testingpersonnel (ASME, 2007).

The specific test makes the individual use proce-dures, graphs, charts, photographs and scenarios todetermine answers to comprehensive questions, asshown in Figure 2. The number of questions in thistest is determined by code requirements. The specifictest challenges the individual’s ability to read and toderive answers based on the information provided.Normally, questions related to conditions and usage ofacceptance criteria are utilized. It is commonplace toestablish a time limit for this test.

The practical test is normally timed and requiresthe person to demonstrate his or her proficiency in thetest method by examining a test sample (or samples)and detecting discontinuities or conditions, as inFigure 3. The administrator is required to assess theindividual’s proficiency in use of equipment andtechnique, proper adherence to procedure, testsequencing, calibrations, materials, documentationand extent of tests. The accuracy and completeness ofinterpretations, evaluations and documentation of theactivities and test results are assessed as well. Thesepractical exam elements are incorporated into a multi-point checklist. The series of topics previouslydescribed is a basis for the test administrator toperform a practical test qualification assessment.

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Figure 1. Individual taking a general (closed book) test.

Figure 2. Individual taking a specific test with access to materials.

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The completed checklist serves as objective evidenceof the assessment results.

The qualification and certification of quality controlinspectors are addressed in the provisions of ASMENQA-1, Quality Assurance Requirements for NuclearFacility Applications (Supplements 2-S1 and 2-S2, andAppendix 2-A1) and ANSI N45.2.6 (ASME, 1994; ANSI,1978).

Regarding initial qualification of quality controlInspectors, ANSI N45.2.6 and ASME NQA-1,Supplement 2-S1 state, “The capabilities of acandidate shall be determined by a suitable evalua-tion of the candidate’s education, experience, training,and either test results or capability demonstration”(ASME, 1994; ANSI, 1978). Because of this, suppliersmay, but are not required to, utilize testing as a meansto evaluate quality control inspection personnel. Also,as referenced in ASME NQA-1, Code Interpretation(QA90-006), predicated on the supplier’s qualificationprogram, they may, but are not required to, use aLevel III when qualifying Level IIs (ASME, 1994).

While testing and capability demonstrations mayprogrammatically meet the imposed code require-ments, arguably, there is one concept not being fullyassessed.

U.S. NRC Regulatory Guide (Reg. Guide) 1.58provides comments and position statements regardingANSI N45.2.6 (ASME, 1978; NRC, 1980). Reg. Guide 1.58was withdrawn in 1991; however, a number of utilitiescontinue to commit implementation of these commentsto the regulator. Of significance, Reg. Guide 1.58provides Comment 10 regarding ANSI N45.2.6,pointing out that Section 2.2, Determination of Initial Capability, and Section 2.3, Evaluation ofPerformance, both explain “the use of evaluation ofjob performance and determination of initial capabilityto perform the job” (ASME, 1978; NRC, 1980).

The preceding, particularly the NDT practical test,addresses the individual’s capability to perform thejob from a technical perspective. However, it isconceivable to implement the requirements for quali-fying quality control personnel without any practicalassessment.

By incorporating a PBT approach for both the NDTand quality control disciplines, test administratorshave the opportunity to assess both technical andhuman skill elements of the NDT technicians in an in-plant atmosphere.

Performance-based TestingThe PBT concept, shown in Figure 4, mimics the princi-ples of the systems approach to training and PBT usedby 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’shuman performance skills, or soft skills. This includesevaluating the individual’s knowledge, skills andabilities (KSA), the combination of human knowledgeand capabilities required to perform a task. If a KSAdeficiency is one of the more frequently identifiedcauses for human error, then testing is the primarymeans to evaluate KSA proficiency. In testing, humanperformance depends directly and indirectly on taskcharacteristics and the testing environment presentedto the individual (IAEA, 2001).

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Figure 3. Individual taking an ultrasonic practical test on welding.

Figure 4. Individual taking a performance-based ultrasonic practical test onthickness.

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To evaluate an individual’s KSA using a PBT testingapproach, as a minimum, the following considerationsshould be included:� Testing in an environment replicating in-plant condi-

tions 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 (asso-

ciated 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 inspec-

tion procedures, for review� Requiring use of safety equipment, including As Low

As Reasonably Achievable (ALARA) requirements forthe area (NRC, 2012)By staging the practical test in this environment,

soft skill competencies can be included in the overallassessment, including:� Open communication: does the individual speak

candidly, concisely and articulately? Are listeningand writing skills observed? Does the assessorobtain feedback from the candidate? Does the indi-vidual differentiate opinions from fact?

� Adaptability: does the candidate maintain focusduring the test? Is the individual flexible if condi-tions change in the environment during the test?Does the individual know his or her own physicallimits?

� Problem identification: can the person identifyproblems? Does the individual exhibit the ability tocomplete the inspection when conventional actionsor resolutions are not apparent?

� Safety consciousness: does the individual show aquestioning attitude? Does the person intelligentlyfollow procedures? Is there a safety consciousnessbeing 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 certifi-cation procedures. When considering the NDT qualifi-cation process, implementation of a practical testchecklist for technical skill assessment is an existingrequirement. A recommendation is to include andimplement a human performance skill checklistconcurrently. The overall practical test grade can beobtained by assigning a weighted value to eachportion. While aggressive in concept, the PBTapproach can be used in the qualification process forquality control inspectors.

ConclusionWhile not a panacea, implementing a PBT approachprovides avenues of information that can be sharedwith the utility. PBT supports completing technical andhuman performance skill assessments. The processcan assist in identifying correctable weaknesses, whileimproving the abilities of the inspector. wx

AUTHOR

A.M. (Marty) Wenzig, Jr.: Industrial Testing LaboratoryServices, 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 PowerPlants, American National Standards Institute, New York,New York, 1978.

ASME, ANSI/ASME NQA-1: Quality Assurance Requirementsfor Nuclear Facility Applications, Supplements 2-S1 and 2-S2, Appendix 2-A1, The American Society of MechanicalEngineers, New York, New York, 1994.

ASME, ASME B31, Standard for Pressure Piping: B31.1 –Power Piping, The American Society of Mechanical Engi-neers, 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 forInservice 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 Qualificationand Certification of Nondestructive Testing Personnel(1995), The American Society for Nondestructive Testing,Inc., Columbus, Ohio, 1995.

ASNT, Recommended Practice No. SNT-TC-1A: PersonnelQualification and Certification in Nondestructive Testing(1992), The American Society for Nondestructive Testing,Inc., Columbus, Ohio, 1992.

IAEA, A Systematic Approach to Human PerformanceImprovement in Nuclear Power Plants: Training Solutions,International Atomic Energy Agency, Vienna, Austria, March2001.

NRC, Code of Federal Regulations, Title 10: Energy – Part20.1003 Definitions, U.S. Nuclear Regulatory Commission,Washington, D.C., 31 January 2012.

NRC, Code of Federal Regulations, Title 10: Energy – Part50.120 Training and Qualification of Nuclear Power PlantPersonnel, U.S. Nuclear Regulatory Commission, Wash-ington, D.C., 12 June 2009.

NRC, Code of Federal Regulations, Title 10: Energy – Part50.55a Codes and Standards, U.S. Nuclear RegulatoryCommission, Washington, D.C., 2011.

NRC, Code of Federal Regulations, Title 10: Energy – Part55.4 Operators’ Licenses, U.S. Nuclear Regulatory Commis-sion, 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 July1991), U.S. Nuclear Regulatory Commission, Washington,D.C., September 1980.

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