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NRC Perspective on ASME

NDE Certification Process

Aladar Csontos, Wallace Norris, Carol Nove

NRC/RES/DE/CIB

Michael Anderson & Steven Doctor

PNNL

May 9, 2011

Outline

• Regulatory Requirements

• Appendix VII

• Appendix VIII

• Where are we today?

• Areas of Improvement

• ANDE Program

• NRC Feedback to ANDE

• Conclusion

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Regulatory Requirements

• Appendix A to Part 50: GDC-1 for NPP – Overall Requirements

– Criterion 1—Quality standards and records - Structures, systems, and

components important to safety shall be designed, fabricated, erected,

and tested to quality standards commensurate with the importance of

the safety functions to be performed. Where generally recognized

codes and standards are used, they shall be…evaluated to determine

their…adequacy, and sufficiency and shall be supplemented or modified

as necessary to assure a quality product in keeping with the required

safety function.

• Appendix B to Part 50--Quality Assurance Criteria for Nuclear Power

Plants and Fuel Reprocessing Plants

– IX. Control of Special Processes - Measures shall be established to

assure that special processes, including welding, heat treating, and

nondestructive testing, are controlled and accomplished by qualified

personnel using qualified procedures in accordance with applicable

codes, standards, specifications, criteria, and other special

requirements.

Regulatory Requirements (cont.)

• 10 CFR 50.55(a)(b) incorporates by reference the ASME Code,

Section XI, Rules for Inservice Inspection of Nuclear Power Plant

Components.

• Section XI, Appendix VIII, Performance Demonstration for

Ultrasonic Examination Systems, was first approved when the NRC

incorporated the 1995 Edition with the 1996 Addenda into 10 CFR

50.55a

• 10 CRF 50.55(a)(b)(2)(xiv) addresses Appendix VIII personnel

qualification and requires that all personnel qualified for performing

ultrasonic examinations in accordance with Appendix VIII shall

receive 8 hours of annual hands-on training on specimens that

contain cracks. This training must be completed no earlier than 6

months prior to performing ultrasonic examinations at a licensee's

facility.

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How do we assure that the “special

process” of nondestructive testing

is controlled and accomplished by

qualified personnel using qualified

procedures in accordance with the

applicable codes, standards,

specifications, criteria and other

special requirements?

Appendix VII

• ASME Code, Section XI, Appendix VII – Qualification of

Nondestructive Examination Personnel for Ultrasonic

Examination

– Requires that the skills and responsibilities associated

with each level of qualification be defined by

ANSI/ASNT-CP-189, Standard for Qualification and

Certification of Nondestructive Testing Personnel.

– Specifies requirements for employer certification of

personnel including required experience for initial

certification

– Allows use of outside agency to provide NDE Level III

or NDE Instructor services

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Appendix VIII

• ASME Code, Section XI, Appendix VIII, Performance

Demonstration for Ultrasonic Examination Systems,

published in the 1989 Edition and 1989 Addenda.

• Provides requirements for performance demonstrations

for ultrasonic examination procedures, equipment, and

personnel used to detect and size flaws.

• In contrast to prescriptive requirements, Appendix VIII

allowed any combination of procedures, equipment

and personnel to be used for ISI as long as the

combination could pass a statistically designed

performance demonstration blind test on

representative mockups containing realistic flaws.

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Implementation of

Appendix VIII

• The Performance Demonstration Initiative (PDI) was

formed and funded by the U.S. utilities in 1991 to

implement the performance demonstration requirements

of Appendix VIII.

• PDI is administered by the Electric Power Research

Institute (EPRI).

• Implementation of Appendix VIII through PDI has greatly

enhanced the reliability of ultrasonic examinations of

welds in primary reactor systems

• Appendix VIII references Appendix VII for the

qualification of personnel performing ultrasonic

examinations.

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Where are we today?

• Certification is employer based – varies from employer to

employer

• Training requirements -

– Only 8 hours of semi-annual practice required once

certification achieved

• To address the shortage of qualified inspectors, ASME

actions, such as Code Case N-784, Experience Credit for

Ultrasonic Examiner Certification, have been introduced

– CC N-784 reduces the number of hours required for

certification to Level II and substitutes laboratory practice for

field experience

– CC N-784 is limited with regard to its objectives - The NRC

staff believes a more comprehensive approach is required to

address the issues associated with personnel qualification.

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Where are we today?

Appendix VIII

• Has improved ability to detect and characterize service-

induced flaws in critical primary reactor systems

• Is a screening test that was developed to eliminate poor

performing combinations of procedures, personnel and

equipment, and to validate the training, knowledge, and

skills needed through performance

– passing/failing determined by combination of

detection tests (POD) coupled with false call rates

– length and depth sizing must fall within the

acceptance criteria provided by each of the

applicable Appendix VIII supplements

• Qualification data is wealth of untapped information.

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Where are we today?

• All personnel who take Appendix VIII qualification

exams are certified by their employer to the ANSI/ASNT

CP-189 standard.

– Huge variations in personnel capabilities exist due to

lack of process standardization

– Critical thinking skills/understanding of the

physics/materials/defects involved often missing,

resulting in lack of ability to assess field situations,

apply appropriate technique and interpret the UT

data

– Need to implement training on flaw discrimination

• Appendix VIII does not require requalification of

personnel after initial qualification.

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Where are we today?

• PDI mockups typically do not include weld fabrication flaws.

Use of these mockups may result in:

– the inability of qualified inspectors to distinguish service-

induced flaws from fabrication flaws

– qualifying personnel on flaws that do not adequately represent

the flaws found in the field

• The POD for qualification exams may be artificially high relative to

what it would be if real flaws in realistic mockups were used.

• Blank and flawed grading units with little potential for false calls

are selected to enhance the ability of the Performance

Demonstration Administrator (PDA) to conduct examinations.

Therefore, personnel may have limited opportunity to make false

calls during testing. 12

NRC

Concerns

Areas of Improvement

Where does NRC see room for improvement?

• Revisions to Appendix VII –

– any reduction in experience requirements for certification

must have an adequate, perhaps performance, basis

– only limited ability to substitute laboratory hours for field

experience

– more consistent application of training and examination

requirements

• Revisions to Appendix VIII –

– more real flaws and realistic conditions (i.e., inclusion of

fabrication flaws) in mockups

– requalification requirements

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Areas of Improvement

Where does NRC see room for improvement? (cont.)

• PDI program –

– analysis (with regulatory oversight) of the qualification data

to assess original assumptions used during development

of Appendix VIII, to determine how well the population of

examiners is actually performing during qualification

exams, to guide future mockup fabrication practices, and

generally shore up weaker areas of the program.

• Issues with Qualification to be addressed –

– Revise and/or implement certification (including recertification)

program that focuses on performance demonstration for NDT

– NRC supports EPRIs recent efforts to implement a program to

ensure maintenance of skills

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ANDE Program

NRC supports the ANDE Program…

• ANDE broadens discussion to include the entire range

of NDE methods typically used at NPPs.

• ANDE may possibly improve personnel qualifications

across the board by providing a consistent certification

process that removes the employer to employer

variability.

• Central certification may result in more qualified

personnel in the NDE pipeline. Personnel with new

certification will be able to move between employers.

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ANDE Program

NRC supports the ANDE Program…(cont.)

• Job Task Analyses can potentially provide a

meaningful basis for a consistently applied qualification

process.

• The administration of written and practical exams by an

independent third party provides the foundation for

standardizing the exam process, enhancing program

integrity and auditability.

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NRC Feedback to ANDE

• NRC would like to see the Committee

Membership represent a balance of all

interested sectors to ensure that ASME NDE is

accepted by the whole NDE community -

– Committee is heavily weighted towards

manufacturers and utilities

– NRC would like to see broader involvement from all

other interested parties including academic and

other NDE sectors

– Inclusive rather than exclusive

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Conclusion

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• NRC looks to ANDE to provide assurance

that certified personnel have

demonstrated, via appropriate training,

experience and testing, a given level of

knowledge and the ability to successfully

apply the knowledge for the various NDE

methods used in NPPs…

performance demonstration for

all NDE methods.

(Qualification for

other NDE methods)

• For in-service inspection, personnel qualification

requirements are found in the ASME Code, Section XI,

IWA-2300 “Qualifications of Nondestructive

Examination Personnel.”

– In accordance with ANSI/ASNT CP-189

• For new construction, personnel qualification

requirements are found in Section III, NB-5500,

“Qualifications and Certification of Nondestructive

Personnel.”

– In accordance with SNT-TC-1A

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(What did we do prior

to Appendix VIII?)

• Prior to 1989, UT requirements in Section XI based on prescriptive

procedures for ISI and PSI -

– amplitude-based methods, calibrated from machined reflectors

– did not provide adequate detection for real flaws because real

flaws do not behave like machined reflectors

• Specifying changes to existing procedures would not result in the

level of improvement desired

• More stringent qualification of the UT techniques through

personnel training and performance demonstration was necessary

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Appendix VII &

Appendix VIII