NQA-1 and 10 CFR 50 Appendix B: Building an NDT Program for the Nuclear Supply Chain

Two documents, one programme: Appendix B and NQA-1

Appendix B to 10 CFR Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, states eighteen criteria: Organization; Quality Assurance Program; Design Control; Procurement Document Control; Instructions, Procedures, and Drawings; Document Control; Control of Purchased Material, Equipment, and Services; Identification and Control of Materials, Parts, and Components; Control of Special Processes; Inspection; Test Control; Control of Measuring and Test Equipment; Handling, Storage and Shipping; Inspection, Test, and Operating Status; Nonconforming Materials, Parts, or Components; Corrective Action; Quality Assurance Records; and Audits. Each is a paragraph. None tells you how to run an NDT shop.

ASME NQA-1 is the consensus standard that translates those criteria into an auditable programme. Part I holds eighteen Basic Requirements that map onto the eighteen criteria, with Requirement 2 covering the quality assurance programme and training, Requirement 9 covering control of special processes, Requirement 10 covering inspection, Requirement 12 covering measuring and test equipment, Requirement 17 covering quality assurance records and Requirement 18 covering audits. Part II adds subject-specific Subparts, of which Subpart 2.7 on software and Subpart 2.14 on commercial grade dedication matter most to an NDT supplier.

NRC Regulatory Guide 1.28 Revision 6, issued 11 September 2023, endorses the Part I and Part II requirements in NQA-1-2017, NQA-1-2019 and NQA-1-2022 for implementing a quality assurance programme during the design and construction phases of nuclear power plants and fuel reprocessing plants, with clarifications and regulatory positions, and does not endorse Subpart 2.19. Which edition applies to you is a contract question, answered by the purchase order, not by whichever edition you happened to buy.

Criterion IX and Requirement 9: NDT is a special process

Criterion IX of Appendix B is one sentence long and it is the sentence that puts your company inside the regulation: 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. Nondestructive testing is named. It is not inferred from a general clause about competence. NQA-1 Requirement 9, Control of Special Processes, carries the same obligation into the standard.

The word qualified does two separate jobs in that sentence, and firms entering the market usually deliver only one of them. Qualified personnel means a documented certification programme with training hours, experience, examinations and vision records, held against a named standard. Qualified procedures means the written examination procedure itself has been demonstrated, reviewed and approved under the programme, with the correct approvals from a Level III and, where the code demands it, from the owner or the Authorized Nuclear Inservice Inspector.

Criterion X, Inspection, and Criterion XI, Test Control, then wrap the process. Criterion XII covers measuring and test equipment, which for an NDT contractor means calibration traceability for thickness gauges, densitometers, light meters, field indicators, hardness testers and the reference blocks themselves. Criterion XVII requires sufficient records to furnish evidence of activities affecting quality, including results of reviews, inspections, tests and audits. If your procedure library and your procedure approval trail are thin, that is where the audit stops. Building that library to code is the work described at /consulting/ndt-technical-procedure-development.

Where CP-189 displaces SNT-TC-1A

ASNT published SNT-TC-1A in 1968 as a recommended practice, not a standard. ASME Section III adopted it in the early 1970s, followed later by Section XI, and by the mid-to-late 1970s Section III had issued a code change stating that SNT-TC-1A shall be used as minimum requirements. That is the origin of the employer-based model that still governs most American NDT: the employer writes a written practice, the employer certifies, and the certificate does not transfer.

The nuclear industry then diverged. ANSI/ASNT CP-189, Standard for Qualification and Certification of Nondestructive Testing Personnel, was published in 1991 and incorporated into ASME Section XI in the mid-1990s. That is the only adoption of CP-189 by an industry sector and its associated code. Section III still references SNT-TC-1A and has chosen not to reference CP-189. NRC staff have stated that ANSI/ASNT CP-189 may be used as provided in ASME Code, Section XI, Division 1, and that ASME Code Case N-788-1 with ANDE-1-2015 is not sufficient on its own as an alternative to Subarticle IWA-2300.

The practical difference is prescriptiveness. SNT-TC-1A is a recommended practice the employer adapts; CP-189 is a standard that mandates. For a service company that has run an SNT-TC-1A written practice for a decade, moving into Section XI work is not a matter of relabelling the document. Hours, examination administration, Level III qualification and recertification all tighten. We set that comparison out method by method in our blog at /blog/asnt-snt-tc-1a-vs-cp-189-comparison, and rebuilding the written practice to the correct standard is the work at /consulting/written-practice-development.

Appendix VIII and the PDI: certification is not qualification

In the mid-1980s ASME began developing Appendix VIII, Performance Demonstration, in response to documented weaknesses in the employer-based model. Appendix VIII was incorporated into ASME Section XI in 1989. A Performance Demonstration Initiative committee was established by the utilities and, in cooperation with EPRI, implemented Appendix VIII by the late 1990s. Section XI also added Appendix VII with other additions to IWA-2300 covering training and certification requirements.

The history behind that decision is public and uncomfortable. The first American intergranular stress corrosion cracking through-wall pipe failure, at Nine Mile Point in 1982, led to a three-party agreement between the NRC, EPRI and the BWR Owners Group and to IGSCC qualification examinations at the EPRI NDE Center, where candidates had to detect and identify real cracking in representative samples. The initial pass rate for personnel already qualified and certified under SNT-TC-1A was 19 percent. Over three decades of triennial re-examination, the average pass rate for the previously qualified workforce settled around 50 percent.

For a supplier the lesson is operational rather than historical. A certificate proves that a technician accumulated hours and passed written and practical examinations under your programme. A performance demonstration proves that this technician, running that procedure on that equipment, finds the flaw. Section XI ultrasonic work requires the second. Budgeting a mobilisation on the assumption that certified staff are automatically deployable to Appendix VIII scope is the most expensive mistake a new entrant makes.

The NUPIC audit is the commercial gate

NUPIC, the Nuclear Procurement Issues Corporation, was formed in 1989 through a partnership involving all domestic and several international nuclear utilities. It evaluates suppliers furnishing safety-related components and services, and commercial-grade items, to nuclear utilities. The model is a cooperative joint audit: one team audits, and the report is shared, so that every member can evaluate it against its own criteria for its own approved supplier list rather than sending a separate team to your door.

The audit runs against a standardised checklist. A NUPIC audit team working from the NUPIC audit checklist covers the eighteen criteria of Appendix B to 10 CFR Part 50, delineating the activities to be examined within each section and using performance-based methods with data sheets to record objective evidence. Performance-based is the operative phrase: the team is looking for records of work actually performed, not for a manual that describes work that could be performed. The NRC periodically accompanies a NUPIC team to observe selected audits and confirm the process remains an acceptable alternative to its own vendor inspection programme.

This is where the commercial argument for an outside Level 3 lands. A NUPIC team will pull technician files, procedure approval records, calibration records and the corrective action trail in the same visit, and will test whether the person who approved the procedure is qualified to approve it. A programme signed by someone who does not hold the right level in the right method under the right standard fails on documentation before anyone reaches the shop floor. That gap is what /consulting/asnt-level-iii-consulting-services exists to close.

Commercial-grade dedication: the problem you inherit

10 CFR 21.3 defines a commercial grade item as a structure, system or component that affects a safety function but was not designed and manufactured as a basic component. Dedication is defined as an acceptance process undertaken to provide reasonable assurance that a commercial grade item to be used as a basic component will perform its intended safety function and, in this respect, is deemed equivalent to an item designed and manufactured under a quality assurance programme. Critical characteristics are the important design, material and performance characteristics that, once verified, provide that assurance.

EPRI NP-5652 identified four dedication methods: special tests and inspections, commercial grade survey of the supplier, source verification, and supplier or item performance record. NRC Generic Letter 89-02 conditionally endorsed those four methods, with the staff stating that the commercial grade survey should not be used as the basis for accepting items from suppliers with undocumented commercial quality control programs. NRC guidance also notes that in practice more than one method is typically required; no single method suffices on its own. NQA-1 Part II Subpart 2.14 provides the structure and supplements Requirement 7, Control of Purchased Items and Services.

For a service company the trap is quiet. You are selling inspection, not hardware, so dedication looks like the customer's obligation. Then your procedure calls for a specific couplant, a specific film, a specific calibration block, a specific probe, or acquisition software whose version affects the result. The moment a commercial item's characteristics affect a safety-related examination outcome, someone has to identify critical characteristics and verify them, and the purchase order decides whether that someone is you. Settle it in contract review, in writing, before mobilisation.

The records regime: lifetime, nonpermanent, and 10 CFR 21

Criterion XVII requires sufficient records to furnish evidence of activities affecting quality, including operating logs and the results of reviews, inspections, tests and audits. NQA-1 Requirement 17 implements it and adds the classification that defines nuclear recordkeeping: every quality assurance record is either a lifetime record or a nonpermanent record. Lifetime records are maintained for the life of the particular item while it is installed in the plant or stored. Nonpermanent records carry defined shorter periods.

That classification has to exist before the work does. Which of your outputs are lifetime records is a contract-specific determination made by the owner or the dedicating entity, and it flows into your procedures, your indexing scheme, your storage environment and your electronic records controls. Requirement 17 also demands that records be legible, reproducible, identified, indexed and filed, and stored so as to minimise the risk of loss. A shared drive with technician-named folders does not satisfy any of that.

Then there is 10 CFR Part 21. The dedicating entity is responsible for identifying and evaluating deviations, reporting defects, and maintaining records of the dedication process. If your scope makes you a dedicating entity for any item, you inherit a reporting obligation that has nothing to do with your NDT scope and everything to do with your ability to notice, evaluate and escalate a deviation within a defined period. Utility and EPC clients in the wider power sector face the same records discipline in a lighter form, which is why we treat nuclear records design as an extension of the work at /consulting/energy-utilities-ndt-consulting.

What catches firms crossing over from oil and gas

The first thing that catches them is the standard swap. A written practice that has served API 510 and API 653 clients for a decade is built on SNT-TC-1A, and Section XI work asks for CP-189. Hours, examination administration and Level III qualification all tighten, and the recertification cycle changes. Rewriting the written practice is a matter of weeks; discovering the requirement during a NUPIC audit costs a bidding cycle.

The second is procedure approval authority. Refinery work tolerates a procedure approved by a Level III on staff or on retainer, and the client rarely tests the approval chain. Nuclear work tests it every time. The person who approved the procedure must hold the right level in the right method under the standard the purchase order names, and the evidence of that qualification must be in the file, not asserted in the cover sheet.

The third is scope discipline. Appendix B applies to safety-related work. A firm that runs one programme for everything either gilds its commercial work or contaminates its nuclear work, and audits find both. A graded programme with clear boundaries, written down, is the only version that survives. The industry-specific programme design for plant work sits at /consulting/nuclear-ndt-consulting, and the procedure library that carries it is at /consulting/ndt-technical-procedure-development.

Request a consultation