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
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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 1Quality 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 beevaluated to determine theiradequacy, 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.
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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.

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.

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 serviceinduced 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 serviceinduced flaws from fabrication flaws qualifying personnel on flaws that do not adequately represent the flaws found in the field
NRC Concerns

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.
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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
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.

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(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

Appendix VII & Appendix VIII

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