authorized inspection agency quality program manual

AUTHORIZED INSPECTION AGENCY

QUALITY PROGRAM MANUAL

I. Cover Page Edition 2 Rev.2

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I Cover Page

AUTHORIZED INSPECTION

AGENCY


Scope:

Authorized Inspection Agency for

performance of Authorized Inspections

activities, controlled from below location, to

cover ASME BPV Code Sections I, III Div.1 and

3, IV, VIII Div.1, 2 and 3, X and National Board

Inspection Code Part 3

Edition 2 Rev. 2

Issued on September 26th, 2018

C&P S.r.l.

Via Guidoni,7 20851 Lissone (MB) Italy VAT No. 06286540965

Tel+39 039 9165344 Fax +39 02 93661369

www.cpinspection.com

http://www.cpinspection.com/



III. Cross Reference Edition 2 Rev. 2

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III CROSS REFERENCE

QAI-1: 2016 Part 1, 4 and 5 Requirements C&P Authoized Inspection Agency Quality Program Manual

Qualifications 1-1.1 5-1.1

1.1.2, 1.1.3

Conflict of interest 1-1.1.5 5-1.1.7

1.1.5

Confidentiality 5-1.1.8 2.4.1

Liability Insurance 1-1.1.6 2.2.4

Adequate arrangements to cover liabilities 1-1.1.6(a) 2.2.4

Finances and sources of income evaluation 1-1.1.6(b) 2.2.6

Documentary evidences of liabilities cover and finances evaluation

1-1.1.6(c) 2.2.5

Quality Assurance Manual’s Statement of Policy 1-1.1.6(d) 2.2

Scope of Accreditation 4-2 (a) 2.1

Duties – Provide Inspectors and Supervisors to participate in the ASME survey/review

1-1.2.1 5-1.2.1

1.3.2.1

Duties – Make bound diaries available for investigation 1-1.2.1 5-1.2.1

1.3.2.3

Duties – Provide Inspectors to monitor construction 1-1.2.2 5-1.2.2

1.3.2.4

Duties – Maintain Supervisors to monitor Inspectors performance

1-1.2.3 5-1.2.3

1.3.2.5

Duties - Notice to Inspectors about their Supervisor ref. 1-1.2.4 5-1.2.4

1.3.2.6

Duties - Provide instruction in writing to Inspectors and their Supervisors, specifying their duties

1-1.2.5(b) 5-1.2.5(b)

2.1.5

Duties - Provide instruction in writing to Inspectors to contact their Supervisor when are unable to resolve question concerning the Code

1-1.2.5(c) 5-1.2.5(c)

2.1.5

Duties - Conduct annual planed audit of Supervisors 1-1.2.5(d) 5-1.2.5(d)

2.7

Duties – Written policy to ensure levels of inspection activities commensurate with the Certificate of Accreditation

1-1.2.5(e) 5-1.2.5(e)

2.2.10

Duties - Training and certification of Inspectors and Supervisors

1-1.2.6 5-1.2.6

4.0, 4.3

Duties - Endorsement management 1-1.2.7/8 5-1.2.7/8

4.5.6

Duties - Verify to NB that the audit to Supervisors have been carried out

1-1.2.9 5-1.2.9

4.5.6

Duties - Notify to ASME Conformity Assessment Department about new agreement or cancellation with an ASME Certificate Holder

1-1.2.10 5-1.2.10

1.3.3

Duties - Notify to ASME Conformity Assessment Department when a change in qualification status occurs.

1-1.2.11 5-1.2.11

1.1.4

Program - Organziation 1-1.3.2(a) 5-1.3.2(a)

1.2

STATEMENT OF AUTHORITY 1-1.3.2(b) 5-1.3.2(b)

2.2

PROGRAM DESCRIPTION 1-1.3.2(b) 5-1.3.2(b)

2,2.1

DOCUMENT CONTROL 1-1.3.2(c) 5-1.3.2(c)

3

TRAINING 1-1.3.2(d) 5-1.3.2(d)

4

RECORDS 1-1.3.2(e) 5-1.3.2(e)

5

CORRECTIVE ACTIONS 1-1.3.2(f) 5-1.3.2(f)

6

AUDITS 1-1.3.2(g) 5-1.3.2(g)

7

Supervisors qualification 1-2.1 5-2.1

4.5

Supervisors duties 1-2.2 2.6

Inspectors qualification 1-3.1 4.5

Inspectors duties 1-3.2 2.7




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NB-263 Rev.10 RCI-1-2017 Requirements C&P Authorized Inspection Agency Quality Program Manual

Qualification requirements for the Inservice and Authorized Inspector Commissions

1-1 4.5

Qualification requirements for employment, education, and experience

1-1.1 4.5.1

National Board examination 1-1.2 4.5.1

Issuance of commission 1-2 4.5.1

Qualification requirements 1-3 4.5.2

Issuance of the Endorsement 1-4 4.5.3

Renewal of the Commission/Endorsement 1-5 4.5.7

Reinstatement of the Commission/Endorsement 1-6 4.5.8

Change of Employment 1-7 4.5.9

Continuing Education Requirements for Commissions/Endorsements

1-8 4.5.12

Supervisor Duties – Training to Inspectors and to Repair Inspectors to maintain their competency

4-1.1.1 5-2.1

2.6 a)

Supervisor Duties – record of those Inspectors And Repair Inspectors being supervised and description of their assignment

4-1.1.2 5-2.2

2.6 b) & c)

Supervisor Duties – Auditing and documenting performance of each Inspector and Repair Inspectors assigned to him

4-1.1.3 5-2.4

2.6 d)

Supervisor Duties – Documenting non conforming activities including violations

4-1.1.4 5-2.3

2.6 e) & f)

Supervisor Duties – Confirm that the necessary corrective actions have been verified and accepted by the Inspector or by the Repair Inspector

4-1.1.5 5-2.5

2.6 g)

Supervisor Duties – Ensure each Inspector maintains a Bound Diary

4-1.1.6 2.6 h)

Supervisor Duties – Recording in the Inspector Diary date of audits, and all visit related to his duties

4-1.1.7 5-2.6

2.6 i)

Supervisor Duties – Attending each joint review for each Inspector being supervised

4-1.1.8 5-2.7

2.6 j)

Inspector Duties – Recording daily inspection on the Inspector Diary

4-2.1.1 2.7.1 2.7.2

Inspector Duties – Administrative Verify Certificate Holder has a valid Certificate of Authorization Verify Certificate Holder has the necessary Code Books Monitoring the Certificate Holder’s accepted Quality Program/Quality Assurance Program Verify that any revision of to the Certified Holder’s quality program/quality assurance program meet Code requirements before implementation Notify the Certificate Holder and his Supervisor of any non conforming condition

4-2.1.2 2.7.1 2.7.2

Inspector Duties – Drawing, Design Calculation and Specification Control

4-2.1.3 2.7.1 2.7.2

Inspector Duties – Materials 4-2.1.4 2.7.1 2.7.2

Inspector Duties – Examination and Inspection 4-2.1.5 2.7.1 2.7.2

Inspector Duties – Welding 4-2.1.6 2.7.1 2.7.2

Inspector Duties – Calibration 4-2.1.7 2.7.1 2.7.2

Inspector Duties – Heat Treatment and NDE 4-2.1.8 2.7.1 2.7.2

Inspector Duties – Nonconformance 4-2.1.9 2.7.1 2.7.2

Inspector Duties – Records 4-2.1.10 2.7.1 2.7.2

Inspector Duties – Certification and Stamping 4-2.1.11 2.7.1 2.7.2

Inspector Duties – Joint review 4-2.1.12 2.7.1 2.7.2

Repair Inspector Duties – Recording daily inspection on the Inspector Diary

5-3.1 2.7.3




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Inspector Duties – Administrative Verify Certificate Holder has a valid Certificate of Authorization Verify Certificate Holder has the necessary NBIC, edition and addenda and referenced standards Monitoring the Certificate Holder’s accepted Quality Program/Quality Assurance Program Verify that any revision of to the Certified Holder’s quality program/quality assurance program meet NBIC requirements before implementation Notify the Certificate Holder and his Supervisor of any non conforming condition

5-3.2 2.7.3

Repair Inspector Duties – Drawing, Design Calculation and Specification Control

5-3.3 2.7.3

Repair Inspector Duties – Materials 5-3.4 2.7.3

Repair Inspector Duties – Examination and Inspection 5-3.5 2.7.3

Repair Inspector Duties – Welding 5-3.6 2.7.3

Repair Inspector Duties – Calibration 5-3.7 2.7.3

Repair Inspector Duties – Heat Treatment and NDE 5-3.8 2.7.3

Repair Inspector Duties – Nonconformance 5-3.9 2.7.3

Repair Inspector Duties – Routine Repair 5-3.10 2.7.3

Repair Inspector Duties – Records 5-3.11 2.7.3

Repair Inspector Duties – Certification and Stamping 5-3.12 2.7.3

Repair Inspector Duties – Joint review 5-3.13 2.7.3

Inspector Diary – Scope 6-0 2.7.4

Inspector Diary – Maintenance 6-1 2.7.4.1

Inspector Diary – Description 6-2 2.7.4.2

Inspector Diary – Entries Identification of activities Completeness Signature and date NB Commission n. Availability for investigation Meet requirements of C&P

6-3 2.7.4.3

Monitoring, Recording, Method 6-4 2.7.5

Code of Ethic – Scope 7-0 2.3

Code of Ethic -Conflict of Interest 7-1 2.3.1

Code of Ethic - Good Faith Actions 7-2 2.3.2

Code of Ethic - Public Perception 7-3 2.3.3

Code of Ethic – Independence, Impartiality, and Integrity 7-4 2.3.4




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NB-381 Rev.3 Quality Program for inspection organizations Requirements C&P Authoized Inspection Agency Quality Program Manual

Title of Page 2.1 a) Cover Page

Statement of Authority 2.1 b) 2.2

Organization 2.1 c) 1.2

Quality Program Responsibilities 2.1 d) 1.3

Scope 2.1 e) 2.1

Program description 2.1 f) 2.1.4

Document Control 2.1 g) 3.1 ÷ 3.4

Training 2.1 h) 4.1 ÷ 4.5

Records 2.1 i) 5.1 ÷ 5.3

Corrective Actions 2.1 j) 6.1 ÷ 6.3

Inservice Inspection Methods 2.1 k) N.A.

Repairs/Alterations Inspection Methods 2.1 l) 2.7.3

Reporting 2.1 m) 2.7.3, 4.5.5

Control of contracted Services 2.1 n) N.A.

Audits 2.1 o) 7.1 ÷ 7.8

Sample Forms 2.1 p) App.2




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NB-369 Rev.8 Accreditation of Authorized Inspection Agency performing Inservice or Repair/Alteration Inspection Activities - Requirements

C&P Authoized Inspection Agency Quality Program Manual

Inservice Commissioned Inspector Requirements 5.0 4.5

Organization and Management. 6.0 -

The AIA shall employ one or more supervisors/technical manager(s), however named, who have the overall responsibility for: carrying out inspection activities in accordance with this document; the required duties described in NB-263, RCI-1, Rules for Commissioned Inspectors; and monitoring the performance of the Inspector. The supervisor/technical manager shall hold a valid National Board Inservice Commission (IS) and an R Endorsement, if the scope of inspections includes repair/alteration inspections.

First dot 1.3.2

provide ongoing training to maintain competencies to its personnel

Second dot 4.5.10 4.5.11

Provide instructions to Inspectors specifying their respective duties and responsibilities including inspections in accordance with jurisdictional requirements

Third dot 2.1.5, 2.6, 2.7, 4.4

Professional liability insurance coverage for its inspection activities

Forth dot 2.2.1

Identify any entity within its ownership structure that provides a service or product that may create a conflict of interest with its AIA work

Fifth dot 2.3

Be an entity recognized as a legal entity under the laws of each jurisdiction in which it does the business

Sixth dot 1.1.1 1.1.2

Cannot be a sole proprietorship Seventh dot 1.1.1

Provide the company name as it will appear on the certificate Eight dot Cover page

Identify the owner or owners of AIA and any other owners up the chain of ownership

Ninth dot 1.1.1

Ensure confidentiality of information obtained in the course of its inspection activities and guaranties proprietary rights

Tenth dot 2.4

Independence, Impartiality and Integrity 7.0 -

The personnel of the AIA shal be free form any commercial, financial and other pressure which may affect their judgment. Procedure shall be implemented

First dot 2.3

The AIA shall be independent to the extent that is required with regards to condition under which it perform its services. It shall meet the following criteria:

The AIA shall be independent of the parties involved The AIA and its staff responsible for carrying out the inspection shall not be (see the list on the standard) The personnel shall not engaged in any activities that may conflict their independence, and integrity

Second dot 2.3

AIA Quality Program 8.0 See NB-381 references



IV. Reference documents, definitions and abbreviations Edition 2 Rev. 2

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IV REFERENCE DOCUMENTS, DEFINITIONS AND ABBREVIATIONS

IV.1 Reference Documents

- ASME QAI-1: 2016 - Qualifications for Authorized Inspection

- NB-263 Rev.10 / RCI-1: 2017 – Rules for Commissioned Inspectors

- NB-369 Rev.8 – Accreditation of AIAs Performing Inservice or Repair/Alteration Inspection Activities

- NB-381 Rev.3 - Quality Program for Inspection Organizations

IV.2 Definition and Abbreviation

AI Authorized Inspector holding a valid National Board Commission AI or IS issued by NB

AIS Authorized Inspector Supervisor holding a valid National Board Commission and also a B endorsement issued by NB

AM Administrative Manager

ANI Authorized Inspector holding a valid National Board Commission and an N endorsement issued by NB

ANIS Authorized Nuclear Inspector Supervisor holding a valid National Board Commission and a N and also a NS endorsement issued by NB

ASC ASME Service Contract or Inservice Contract

ASME American Society of Mechanical Engineers

ATM ASME Technical Manager

C&P C&P S.r.l.

CAR Corrective Action Report

Certificate Holder The “Certificate Holder” includes both Manufacturers and Owners (for Nuclear program)

Code ASME Boiler and Pressure Vessel Code and National Board Inspection Code

Construction An all-inclusive term comprising materials, design, fabrication, examination, testing, inspection, and certification required in the manufacture and installation of an item

Indoctrination The activities to transfer to C&P personnel the knowledge of their responsibility and authority, work methodologies, requirements of applicable Code and standards, C&P procedures, work instruction, and quality program requirements

Inspector Authorized Inspector or Authorized Nuclear Inspector as applicable

Manual C&P Srl Authorized Inspection Agency Quality Program Manual

MDM Manual Distribution Matrix

NB National Board of Boiler and Pressure Vessel Inspectors

NBIC National Board Inspection Code

NB-263/RCI-1 NB-263/RCI-1 – Rules for Commissioned Inspectors (latest edition)

NB-369 NB-369 - Accreditation of AIAs Performing Inservice or Repair/Alteration Inspection Activities (latest edition)

NB-381 NB-381 - Quality Program For Inspection Organizations

NCR Non conformity Report

Non conformity Any condition or activity not conducted in accordance with this Manual and its supporting procedure/instructions

Program This manual and the supporting procedure/instructions

QAI-1 ASME QAI-1 - Qualifications for Authorized Inspection (latest edition)

RI Repair Inspector holding a valid National Board Endorsement R issued by NB

Routine repair Routine repairs are repairs for which the requirements for in-process involvement by the Repair Inspector and stamping by the “R” Certificate Holder may be waived as determined appropriate by the jurisdiction and the Repair Inspector.

Server Server is the business device used for information management necessary to C&Ps administrative and technical operations

Share holders The owners of C&P holding a share of the company

Supervisor Authorized Inspector Supervisor or Authorized Nuclear Inspector Supervisor as applicable

Terms and Conditions

Document describing conditions used by C&P to provide services

Training The activities to transfer to C&P personnel the competencies to perform and implement her/his job



1. Organization Edition 2 Rev. 2

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1 ORGANIZATION

1.1 Legal requirements

1.1.1 C&P is a limited liability company, legally enrolled in the Chamber of Commerce (REA 1858177 inscription). It is made up by Valeria Cipiciani, Paolo Pacor, Sara Cipiciani and Luca Urbanetto.

1.1.2 C&P has been authorized by Italian Government through its “Ministry of Economic Development” on July 19th 2012 to operate as Notified Body within European Union according to European 2014/68/EU requirements to comply with QAI-1 §1-1.1.1(c), §5-1.1.1(c) as a company in the business of providing “third party” inspection services within a jurisdiction, which has government recognition to perform inspection and design reviews for boilers and pressure vessels.

1.1.3 ATM will notify in writing immediately the ASME Conformity Assessment when a change in the above accreditation or notification status occurs.

1.1.4 C&P Srl doesn’t provide any kind of consultancy or similar activity to avoid any conflict with his certification activity as per prescription of Italian “Ministry of Economic Development”.

1.2 Organization

The structure of C&P is defined in the organization chart below in Fig.1. This organization chart and the Quality Program is applicable to C&P inspection activities delivered in all geographical areas, including shops and assembly fields.




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Fig.1 - Organization Chart

C&P shall provide qualified Inspectors and Supervisors holding the appropriate commissions and endorsements for all inspection services activities.

1.3 Responsibility

1.3.1 Management Representative (MR)

The Management Representative has the overall responsibility for ASME services provided by C&P under accreditation as an ASME Authorized Inspection Agency.

MANAGEMENT REPRESENTATIVE

(MR)

ADMINISTRATIVE MANAGER

(AM)

ASME TECHNICAL MANAGER

(ATM)

SUPERVISORS (AIS / ANIS)

INSPECTORS (AI / RI / ANI)

AUDITORS

EXTERNAL AUDITORS




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He is responsible for:

a. ATM designation;

b. Approval of ASME Service Contract (ASC);

c. Assuring the adequacy of the liability insurance and/or financial reserves to cover existing and future liabilities;

d. Verification initially and on annual basis of available finances and sources of income to demonstrate that C&P S.r.l. and its employees are free from commercial, financial, or other pressures which could compromise impartiality

e. Evaluation of personnel competencies

f. Evaluation of adequacy of number of personnel employed to cover the workload

The MR takes the responsibilities of the ATM, when this activity involves the ATM itself. If necessary the MR will call upon experts with same qualification requirements of the ATM.

1.3.2 ASME Technical Manager (ATM)

The ATM is responsible for:

a. Overall responsibility for carrying out inspection activities in accordance with the required duties described in ASME QAI-1, NB-263/RCI-1and NB-369 and monitoring the performance of the Inspectors undertaking those duties;

b. Providing Supervisors and Inspectors to participate in the ASME survey and/or review of Certificate Holders for which C&P provides Authorized Nuclear Inspection and/or Authorized Inspections;

c. Ensuring the Inspector’s diaries are available for ASME surveys and investigations;

d. Providing qualified Inspectors with the appropriate commission and endorsements to monitor construction in accordance with the Code;

e. Maintaining qualified Supervisors to monitor and audit the performance of the Inspectors at shops and field sites for which inspection agreement has been made in accordance with the requirements listed in para 2.6;

f. Giving written notice in the designation letter to all Inspectors of the name, office address, email address, office phone, and mobile phone of their respective Supervisors upon appointment. Annually, or whenever there is a change in the above contact information, the ATM give the written notice to all inspectors within the document “Inspector Assignment” (DOC002A);




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g. Establish, document, and ensure implementation the C&P Quality Program;

h. Indoctrination and training of all personnel involved in the C&P Quality Program.

i. Scheduling of internal audits as specified in para 2.8 of this Manual.

When it comes necessary to call upon an expert for preparation and/or review of documents, procedures, work instructions etc., the ATM is responsible to verify that the level of competency is acceptable

1.3.3 Administrative Manager (AM)

The AM is responsible for documentation management, in particular for:

a. Notifying ASME of all signed ASC and when an ASC is terminated (via caconnect or e-mail);

b. Cooperation with the Management Representative for the definition of business policy and goals;

c. Retention and updating of records of qualifications (e.g. certificates of qualification), training, experience;

d. Arranging personnel folders of inspection personnel;

e. Maintaining and retaining records as specified in para 5 below;

f. Review of Manual, procedures, work instruction and Code of Conduct;

g. Prepare and review of Manual Distribution Matrix (DOC001A)

1.3.4 Supervisors

See para 2.6 below

1.3.5 Inspectors

See para 2.7 below




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1.3.6 Auditors

The Auditor is responsible for:

a. Preparing the audit plan and the Internal audit checklist (Form CL005A)

b. Conducting and recording the audit

c. Reporting to the ATM or MR the result of the audit

1.4 Level of authority

Each inspector has the authority and the duty to refuse to sign any data report involving nonconformance with the ASME Code. Any interference from C&P Management or other personnel with this is forbidden.

Supervisors have the authority to resolve problems concerning Code compliance when an Inspector is unable to do so.

In all cases the ATM retains overall responsibility for ensuring Code compliance.



2. Program Description Edition 2 Rev. 2

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2 PROGRAM DESCRIPTION

2.1 Scope of the Quality Program

2.1.1 The Quality Program describes the organization, responsibility, procedures necessary to satisfy the quality requirements required in accordance with the ASME QAI-1, NB-360, NB-369, NB-263/RCI-1 and NB381.

2.1.2 The scope of the program described in this manual cover the duties and activities performed by C&P and its inspectors and supervisors related to ASME certification conforming to Code Sections I, III Div.1 and Div.3, IV, VIII Div.1, Div.2, Div.3, X, NB certification conforming with NBIC Part 3 and meeting the requirements of the ASME QAI-1, applicable edition, part 1, 4 and 5 and the requirements of NB-369 limited to repair and alteration inspection activities, and NB-263/RCI-1 applicable edition.

2.1.3 All inspection activities are controlled from the C&P Head Office located in Via Guidoni 7 20851, Lissone (MB), Italy.

2.1.4 The quality program is documented in this manual, which includes all applicable requirements addressed in ASME QAI-1, NB-381, NB-369 and NB-263/RCI-1, and in supporting procedures/work instructions referenced within this manual that describe how the program shall be implemented.

2.1.5 In particular, the work instructions IO001A and IO002A have been issued to provide instruction to the Inspectors to specify their respective duties and responsibilities.




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2.2 Quality Policy – Statement of authority

2.2.1 C&P is totally committed to satisfying its obligations under the ASME Code, the ASME QAI-1 standard, the National Board of Boiler and Pressure Vessel Inspectors NB 369, NB 381 and Quality Assurance criteria as appropriate in respect of the supply of impartial and professional inspection and certification services to its clients. All these services are supplied under strict control of, and in accordance with, its Quality Program as set out in this Manual. Training, on the job training, independence and impartiality of personnel are the basis of this program. Accordingly, C&P personnel are strictly forbidden from being involved in design, construction, quality or consultancy activities associated with the inspections undertaken by C&P.

C&P acknowledges that it is subject to planned audits by ASME to maintain its accreditation as an Authorized Inspection Agency.

C&P will not enter into any contract for AIA Services where C&P identifies a possible conflict of interest. C&P shall have no commercial interest in, and shall be independent of any part of an organization having direct interest in the products to be inspected.

The Management Representative assures and guarantees autonomy and independence of the ATM, with regard to his/her certification and supervision duties.

C&P has insurance to cover the liabilities relating to C&P ASME activities as an AIA. This insurance covers all the services supplied by C&P and its personnel. C&P has insured itself up to a limit of 3.500.000 € through professional liability insurance and the Management Representative will monitor the adequacy of this amount to determine if an increase may be required at any point, see also para 7.8.2.

The insurance contract is available for review to ASME team or ASME Conformity Assessment upon request.

C&P has evaluated its finances and income and it is able to demonstrate that any commercial, financial or other pressure doesn’t compromise its impartiality. Annually, it will be reviewed by me to ensure that these conditions have been maintained.

C&P firmly believes that the satisfaction of the requirements of this Manual permits the achievement of its main goals, especially to reach and enforce its leadership among agencies belonging to the same sector regarding the quality of services, professionalism of its inspectors and employees, the satisfaction of client and both reaching and increasing the credibility and integrity of C&P.

The achievement of these goals will be assured through a specific training activity delivered to C&P personnel on the Quality Program, this Manual and applicable supplementary procedures.




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ATM is responsible for arranging the C&P on the job training courses concerning the Quality Program, this Manual and applicable procedures and work instructions whenever these are revised.

C&P assures the level of inspection activities through an adequate number of Inspectors and Supervisors holding the necessary commissions and endorsement commensurate with the Certificate of Accreditation and the request of our clients. C&P is committed to employing sufficient inspectors and supervisors holding the commissions and the endorsements necessary to meet our customers' needs.

ATM is responsible for ensuring the implementation of the Quality Program described in this Manual and he has the authority and organizational freedom to identify quality problems, initiate, recommend, provide solutions and verify implementation of solutions. The ATM has the full support of the Management Representative.

I will ensure that resolution of disagreements will be resolved in a manner that will not conflict with the ASME Code, NBIC, jurisdictional requirements, or this Manual.

Lissone, September 26th, 2018

Valeria Cipiciani – Management Representative




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2.3 Code of Ethics

2.3.1 Conflict of Interest

C&P personnel are strictly forbidden to undertake any activities which may cause a conflict of interest with any C&P inspection activities.

C&P Inspectors providing inspection services shall not inspect work that includes but is not limited to, designing, manufacturing, supplying, installing, purchasing, nondestructive examination, or calibration performed by entities under the C&P structure or contractual arrangement.

2.3.2 Good Faith

C&P personnel shall act in good faith towards each client, and other involved parties, in accordance with the Code of Conduct (DOC022N), which is reviewed and approved by Management Representative. The Code of Conduct formally defines the ethical responsibilities, duties and general basics of correct conduct for all C&P employees. It shall be given to all C&P personnel who will read and sign it to signify acceptance. A copy of the signed document shall be kept in personal files at the Head Office.

C&P personnel are not remunerated on the basis of the amount of inspections they undertake nor the inspection outcome.

C&P personnel shall maintain confidential all information obtained during inspection activities, including intellectual property such as designs, layout, technical solutions adopted, materials and business organization, in accordance with the C&P Code of Conduct.

2.3.3 Integrity

The principle of integrity imposes an obligation on all Inspectors and Supervisors to be straightforward and honest in professional and business relationships. Integrity also implies fair dealing and truthfulness.




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An Inspector or Supervisor shall not be associated with reports, returns, communications or other information where they believe that the information:

a. Contains a materially false or misleading statement;

b. Contains statements or information furnished recklessly; or

c. Omits or obscures information required to be included where such omission or obscurity would be misleading.

2.3.4 Public Perception

It is incumbent upon all Inspectors, Supervisors and C&P personnel to avoid any activities or behavior that may lead to discredit themselves or the company, harm the public, or reduce public confidence in the profession.

Inspectors shall maintain professional relationships with clients, colleagues and others associated with inspection activities without regard to race, colour, national origin, gender, religion, age, sexual orientation or disability.

Inspector's advertising, marketing, and promotion of their services or qualifications shall not be fraudulent, false, deceptive or misleading.

Inspectors shall abide by C&P policy, by laws and guidelines in respect to the use of the C&P logo and other C&P branded materials.

Inspectors shall respond professionally to client or C&P concerns and complaints about an inspection.

Inspectors shall report substantial and wilful violations of these requirements to the Management Representative.

2.4 Confidentiality

2.4.1 Under the European Regulation (UE) 2016/679 (on the protection of natural persons with regard to the processing of personal data and on the free movement of such data) and in observance of Italian Legislative Decree 30/2005 (to promote the defense of industrial propriety, brands, designs, templates, products, patents, etc.) the treatment of information attained during the inspection activity or those linked to it, relating to customer, committee, its suppliers or any other body linked to it, is performed by C&P in accordance with the following principles: correctness, lawfulness, openness, necessity, relevance and privacy protection. C&P personnel are strictly forbidden to reveal this information. This prohibition is cited in the Code of Conduct, accepted by C&P personnel. The use of such data is limited to:




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2.4.2 Carrying out jobs and all the activities linked to the service provision (offers, estimates, contracts, orders, etc.);

2.4.3 Carrying out law duties linked to civil, fiscal, accounting or legal provisions;

2.4.4 Understanding customers’ needs, including qualitative ones and to the appraisal of the Quality of services performed and the results achieved;

2.4.5 Sending advertisements and promotional documents or other elements useful for the market research or trade communication;

2.4.6 In case of disputes, banks, companies performing transport activities, or companies that deal with debt collection and legal assistance can seek access to personal information. Customers have the right to request the amendment, updating and cancellation of their personal data if it is found to be incomplete, incorrect or has been collected illegally.

2.4.7 Each inspector and supervisor, and all involved personnel, shall accept the confidentiality policy signing off the “Impartiality and Confidentiality Declaration”

2.5 Exclusivity 2.5.1 Inspectors shall be in the exclusive employment of C&P S.r.l.

The designation letters confirm that personnel cannot work for another AIA for ASME inspection services.

2.6 Supervisor duties

2.6.1 Non-nuclear supervisor (AIS) is responsible for:

a) Maintaining a record of Certificate Holders’ shop and field site where the Authorized Inspector (AI) and Repair Inspector (RI) assigned to them by C&P, for the purposes of supervision, are performing Code inspection activities (“AI assignment and AIS Certificate Holder List” DOC015A). The AIS shall maintains a record of the dates of visits to the Certificate Holders assigned locations in relation to supervisory duties;

b) Maintaining a record of those AIs/RIs assigned and a description of their assignment on the “AI assignment and AIS Certificate Holder List” (DOC015A) ;

c) Assist the ATM in maintaining competency of the AI/RI to an acceptable level as described in para 4.5.10.

d) Ensuring that each Inspector maintains a Bound Diary as described in paragraph 2.7.4;

e) The technical performance of the Inspectors assigned to him and reporting, in writing using an NCR, to the ATM any nonconforming activity




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reported to them or that they observe on the part of the AI/RI, following full investigation of such activity;

f) Audit the performance of each assigned AI/RI at a shop or field site to which they are assigned, as follows:

1) Audits shall be performed at least once a year at approximately 12-monthly intervals and at additional times as requested by the AI/RI. The ATM will issue (at 18-month interval) and update (monthly) the “Inspector and Supervisor Schedule (QU010A) specifying the timeline for the Audit date for each AI/RI assigned to each AIS.

2) The AIS shall be accompanied by the AI during the Audit;

3) An Audit is not required if the AI has not been engaged in ASME Code inspection activities within the twelve month period since the last Audit (see para 2.8.2);

4) The Audit shall be recorded in the OP003A where the AIS shall describe the status of each item audited and the objective evidence reviewed to evaluate the duty being audited.

g) Confirming that corrective action has been verified by the AI to ensure compliance with ASME Code requirements at the shops and sites which have been assigned to the AIS;

h) Reporting in writing to the ATM any nonconforming activities that are reported to, or are observed by, the AI/RI, using NCR form QU001A. Such instances shall also be brought to the attention of the Management Representative for the Management Review;

i) Recording in the Bound Diary dates of visits to shop and field locations when related to Code supervisory duties;

j) Reviewing the Quality System Program of “UM” Certificate Holders after the first and second years of each 3 year period of Certificate of Authorization. The AIS shall record the audit on the proper ASME form and forward this to the ATM who will send it to ASME for their renewal process;

k) Reviewing the Quality System Program of “E” Certificate Holder where the final shop inspection by the AI is not mandatory. The review shall be conducted on a quarterly basis or more frequently if deemed necessary by the AIS. The AIS shall record the audit on the proper ASME form and forward this to the ATM who will send it to ASME for their renewal process;

l) Attending each joint review for Certificate Holders for each AI/RI being supervised. When this is not possible or practicable, a substitute AIS may participate. It is not required for the AIS to attend joint reviews of Certificate Holders that are inactive. An inactive Certificate Holder is one that has not used its ASME Certificate of Authorization during the previous certification period.




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m) Perform any activity he retains useful for the AI and Certificate Holder compliance with Code and this Manual requirements.

2.6.2 In addition to the applicable duties defined in 2.6.1 the Nuclear Supervisor (ANIS) is responsible for:

a) Maintaining a record of Certificate Holders’ shops and field sites where the Authorized Nuclear Inspector (ANI) assigned to them by C&P for supervision are performing Code inspection activities (“ANI assignment and ANIS Certificate Holder List” DOC016A). The ANIS shall maintain a record of the dates of visits to the Certificate Holders assigned locations in relation to supervisory duties;

b) Maintaining a record of those ANI assigned and a description of their assignment on the “ANI assignment and ANIS Certificate Holder List” (DOC016A);

c) Assisting the ATM in maintaining competency of the ANI to an acceptable level as described in 4.5.10;

d) The technical performance of the ANIs assigned to him. They shall report, in writing, using NCR form QU001A, to ATM any significant nonconforming activities that are reported to them or that they have observed on the part of the ANI, following full investigation of such activity.

e) C&P ANIs are not considered as “Radiation-exposed personnel” and it is strictly forbidden for all C&P personnel the access areas subjected to radiation and it is forbidden to expose a worker to a controlled area.

f) Auditing the performance of each ANI under their supervision on a planned and periodic basis. The ATM will issue (at 18-month interval) and update (monthly) the “Inspector and Supervisor Schedule (QU010A) which record the Audit date, and the deadline for the next audit, for each ANI assigned to each ANIS as follows:

1) Audits, of active ANI (see para 2.8.3), shall be performed at least twice a year at the shop or site to which he is assigned. When an Inspector is assigned to more than one shop or site, at which Code activities are being performed, or have been performed since the previous audit, the ANI shall be audited at least once a year at each location;

2) The ANIS shall be accompanied by the ANI during the Audit;

3) An Audit is not required if the ANI has not been engaged in ASME Code inspection activities in twelve months since the last Audit;

4) The Audit shall be recorded in the OP004A where the ANIS shall describe the status of each item audited and the objective evidence reviewed to evaluate the duty being audited;

g) The ANIS shall select an ANI or themselves to audit at least twice a year that portion of activities covered by the Certificate Holder’s Quality




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Assurance Manual which are performed at locations not assigned to an ANI. The number of audits may be reduced to one per year in cases where no code activities have been performed since the last audit;

h) The ANIS shall audit, at least once a year, the portion of N-Type Certificate Holder’s Quality Assurance Program that involves the supply, or manufacture and supply, of material. The Audit shall be recorded in the “Material Organization Audit Report” (OP006A);

i) The ANIS shall audit the NS Certificate Holder’s Quality Assurance Program at least once a year. The Audit shall be recorded in the “NS Certificate Holder Report” (OP005A);

j) The ANIS shall audit annually the Owner’s Quality Assurance Program. The ANIS shall report the results to the ASME for review and determination as to whether the Owner’s Certificate shall be renewed;

k) The ANIS shall inform, in writing, the Quality Assurance System/Program Manager of the organization to be audited, at least 15 calendar days in advance, about the scope of the audit and provide an audit plan for the audit. The ANIS shall submit to the audited personnel his report as information, including his final observation and comments;

l) The ANIS shall investigate and report in writing to ATM any significant or reported ASME Code or Quality Assurance Program nonconformance by the Certificate Holder engaged in ASME Code Section III Div.1 or 3 activities;

m) Accepting the Certificate Holder Quality Assurance Manual before it is implemented and also provide a copy of the Quality Assurance Manual to the AM for record purposes;

n) Record in the Bound Diary dates of visits to shop and field locations when related to Code supervisory duties. ANIS shall provide the ATM with copy of the Bound Diary pages where audits of the ANI are recorded.

o) Perform any activity he retains useful for the AI and Certificate Holder compliance with Code and this Manual requirements.

2.7 Inspectors duties

2.7.1 Authorized Inspector (AI) Duties

The duties of the AI, as required by Code Section I, IV, VIII-series, and NB-263/RCI-1 are, but are not limited, to the following:

a) Verifying that the Certificate Holder has a valid Certificate of Authorization covering the scope of Code activities to be performed at the shop or field location;

b) Verifying that the Certificate Holder has a valid Certificate of Authorization




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to register with the National Board, if the code items are to be registered;

c) Verifying that the Certificate Holder has the necessary Code Books, referenced standards, and Code Cases to cover the work planned;

d) Monitoring the Certificate Holder’s accepted quality program on a continual basis (see para 2.7.5);

e) Verifying that any revision of the Certificate Holder’s quality program continues to meet Code requirements before implementation. Only the appointed AI shall verify that any revisions to the Certificate Holder’s quality program meet ASME BPV Code requirements before implementation accepting the quality program manual or equivalent document. The substitute inspector has the duty to check this verification and acceptance have been done. In case the appointed AI is not available, the substitute inspector may accept the quality program manual after consultancy with his assigned Supervisor;

f) Notifying the Certificate Holder and the AIS of any nonconforming condition using Form QU006A (Non-conforming condition Report);

g) Verifying that all applicable design drawing, specifications, and instruction for each job, including revisions, are complete and accurately reflect the Code requirements for the work to be performed;

h) Verifying that the design calculation for each job are on file and available for review (specific requirements are addressed on IO001A);

i) Verifying that only intended and identified material, as specified in the appropriate Code section, is used in the Code construction;

j) Verifying that material is identified, documented and remains traceable in accordance with the Certificate Holder’s quality program and Code requirements;

k) Verifying Code required documentation for material is available for review for each job. The AI shall review MTR and/or other material documentation required by the Code to ensure Code compliance;

l) Reviewing and accepting the method and extent of material defect repairs, prior to work being performed;

m) Designating inspection points at stages of construction that will provide meaningful results to verify Code and quality program requirements;

n) Performing inspection at designated inspection points;

o) Performing internal inspection whenever access permits and when required by the Code. When access is not afforded based on design, the Inspector shall use other means to verify Code compliance;

p) Performing all external inspections to verify Code compliance;

q) Witnessing all pressure tests and proof tests as required by the Code;




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r) Verifying that welding/brazing procedure specifications, procedure qualification records, and welder/welding operators’ qualifications are in compliance with the Code requirements;

s) Verifying that welders and welding operators are properly qualified and are using qualified procedures for the welds being performed;

t) Verifying, as appropriate, that the method and extent of weld repairs to welds and base material are in compliance with ASME BPV Code requirements;

u) Verifying, as appropriate, that weld joint preparation is in compliance with design and welding documents and ASME BPV Code requirements;

v) Verifying completed welds comply with Code requirements;

w) Verifying that only calibrated examination, measurement and testing equipment are utilized during construction, and that such equipment meets the requirements of the Certificate Holder’s quality program;

x) Verifying all Code-required heat treatment and non-destructive examinations are performed using accepted/approved procedures. Non-destructive examination procedures shall be demonstrated to the satisfaction of the AI;

y) Verifying non-destructive examination personnel are qualified as required by Code and the Certificate Holder’s quality program;

z) Verifying non-destructive examination reports meet Code requirements;

aa) Reviewing and accepting non-conformance dispositions and verifying corrective actions performed. Also, verifying non-conformances are closed in accordance with the Certificate Holder’s quality program;

bb) Verifying all records are complete, accurate, maintained and retained as required by Code and the Certificate Holder’s quality program;

cc) Verifying the Certificate Holder’s representative has accurately completed and certified the Manufacturer’s Data Report form prior to AI certification. The AI’s National Board Commission number and endorsement(s) shall be recorded on the Manufacturer’s Data Report;

dd) Verifying all Code requirements have been met before authorizing ASME Certification Mark;

ee) Verifying the stamping meets Code, is correct, and has been applied to the correct item, including proper attachment of nameplates;

ff) Verifying the National Board NB symbol and National Board registration number are applied to any item registered with National Board;

gg) The AI must participate in joint reviews of Certificate Holders to which the AI is assigned. When this is not possible or practicable, a substitute AI may participate.




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Duties and responsibilities instructions are provided to the inspectors in the work instruction IO001A.

2.7.2 Authorized Nuclear Inspector (ANI) duties

In addition to the duties listed in 2.7.1 the ANI shall also carry out the activities required by Section III NCA-5000 that include but are not limited to:

a) Monitoring the Quality Assurance Program and verify conformity;

b) Verifying that the Design Specification and Design Report are available, properly certified by Certifying Engineer in accordance with ASME requirements and that are on file;

c) Verifying, when it is necessary to cut the materials into two or more pieces, that the Certificate Holder’s controls are such that responsible personnel transfer the identification in order to maintain traceability of material;

d) Verifying that the Certificate Holder’s personnel are examining all cut edges, as required by the Code;

e) Verifying that welding procedures conform to ASME Code Section III and IX;

f) Verifying, during construction, that the welding controls only permit the use of welding procedures and qualified welders and operators;

g) In case of repairs, verifying that only properly qualified procedures, welders and operators are used;

h) Verifying that heat treatments have been correctly performed and properly documented;

i) Verifying that required nondestructive examinations and tests have been performed by qualified personnel and that the results are properly documented and meet Code requirements. NDE procedures and acceptance standards shall be in accordance with the Code;

j) Verifying that all the required inspections have been performed prior to closure for testing;

k) Verifying that the responsible representative of the Certificate Holder has signed the Data Report and verifying it is accurate and correct before signing it;

l) Verifying, prior to stamping, to the best of their knowledge and belief that the item is in compliance with the Code. Additionally, verifying that the nameplate stamping is correct and that the nameplate has been properly attached;

m) Inspecting, where applicable, all items that are reported on Data Reports and also those that are constructed using methods other than welding.




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n) In case of potential exposure to occupational related ionizing radiation, the ANI has the duty to advice their supervisor to receive health physics training prior any exposure.

o) it is an obligation for the inspector to attend the ASME Survey of the Certificate Holders.

Duties and responsibilities instructions are provided to the nuclear inspectors in the work instruction IO002A.

2.7.3 Repair Inspector (RI) Duties

The Repair Inspector’s duties for inspections of repairs and alterations are covered in the NBIC and shall include, but are not limited to, the following:

a) Recording daily inspections performed for verification, witnessing activities, and/or monitoring activities in the Inspector Diary;

b) Verifying the repair organization has a valid Certificate of Authorization covering the scope of activities to be performed at the location;

c) Verifying that the repair organization has the necessary NBIC, editions, addenda, and referenced standards and code cases to cover the work planned;

d) Monitoring the repair organization’s accepted quality program on a continual basis;

e) Verifying that any revisions to the repair organization’s quality program continue to meet NBIC requirements before implementation;

f) Notifying the repair organization and his Supervisor of any non-conforming conditions;

g) Verifying all applicable design drawings, specifications, and instructions for each job are complete and reflect the work to be performed;

h) Verifying design calculations are complete, meet designated code and quality program requirements as applicable for the work to be performed, and are certified. The Repair Inspector is not responsible for the accuracy of calculations;

i) Verifying that design calculations for each job are on file and available for review;

j) Verifying only intended and acceptable material is used for repairs and alterations;

k) Verifying that material is identified, documented, and remains traceable in accordance with the repair organization’s quality program;

l) Verifying existing material is compatible with the specified welding procedures to be used;




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m) Verifying Code required documentation for material (partial data reports, material test reports, certificate of conformance) is available for review for each job. The Repair Inspector shall review material test reports and/or other materials documentation to ensure Code compliance;

n) Reviewing and accepting the method and extent of material defect repairs, prior to work being performed;

o) Designating inspection points at stages of repair or alteration that will provide meaningful results to verify NBIC and quality program requirements are met;

p) Performing inspections at designated inspection points;

q) Performing internal inspections whenever access permits and when required by the NBIC. When access is not afforded based on configuration, the Repair Inspector shall use other means to verify NBIC compliance. For example, the use of mirrors or other devices should be considered;

r) Performing all external inspections to verify NBIC compliance;

s) Witnessing all pressure tests and proof tests as required by the NBIC;

t) Verifying that welding/brazing procedure specifications, procedure qualification records, and welder/welding operator qualifications (including continuity records) are in compliance with NBIC requirements;

u) Verifying welds are made using qualified procedures and qualified personnel for the welds being performed;

v) Verifying that the method and extent of weld repairs to welds and base material are in compliance with the NBIC;

w) Verifying that weld joint preparation is in compliance with design and welding documents and NBIC requirements;

x) Verifying completed welds comply with NBIC requirements;

y) Verifying that only calibrated examination, measurement, and testing devices are utilized during repairs/alterations and that such equipment meets the requirements of the repair organization’s quality program;

z) Verifying all code required heat treatment and non-destructive examinations or alternative methods as allowed by the NBIC are performed. Non-destructive examination methods shall be demonstrated to the satisfaction of the Inspector;

aa) Verifying non-destructive examination personnel are qualified as required by the NBIC and the repair organization’s quality program;

bb) Verifying non-destructive examination reports meet NBIC requirements;

cc) Reviewing and accepting, as applicable, non-conformance dispositions




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and verifying corrective actions. Also, verifying non-conformances are properly closed in accordance with the repair organization’s quality program;

dd) Verifying, when required, routine repairs are acceptable to the jurisdiction where the item is installed;

ee) Verifying the repair organization quality program describes the process for identifying, controlling, and implementing routine repairs when applicable;

ff) Verifying, when required, the repair falls within the allowed categories for routine repairs listed in the NBIC;

gg) Verifying, when required, and accepting repair methods;

hh) Reviewing documentation for routine repairs as specified in the quality program;

ii) Verifying NBIC requirements were met prior to signing the NBIC R-1 form;

jj) Verifying all records are complete, accurate, maintained, and retained as required by the NBIC and the repair organization’s quality program;

kk) Verifying the repair organization’s representative has accurately completed and certified the appropriate R-Form prior to Repair Inspector certification. The Repair Inspector’s National Board Commission number and commission/endorsement designator shall be recorded on the R-Form;

ll) Verifying all NBIC requirements have been met before authorizing NBIC symbol stamping;

mm) Verifying that stamping meets the NBIC, is correct, and has been applied to the correct item, including proper attachment of nameplates;

nn) The Repair Inspector must participate in joint reviews for repair organizations to which the Repair Inspector is assigned. When this is not possible or practicable, a substitute Repair Inspector may participate.

oo) The Repair Inspector shall refer to his assigned Supervisor each unsafe condition and/or conflicts he observe.

Duties and responsibilities instructions are provided to the repair inspectors in the work instruction IO001A.

2.7.4 Bound Diary

2.7.4.1 All Inspectors (AI, RI and ANI) shall record details and all the necessary remarks, and especially all conditions of breaches of requirements and applicable specifications, relating to their inspection activities in the Bound Diary (DOC004A). The Bound Diary is C&P property and it is the responsibility of each Inspector and Supervisor to ensure it is appropriately maintained.




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The following information shall be recorded as a minimum by the inspector:

a) Manufacturer Certificate Holder’s identification;

b) Shop or field location;

c) Date of inspection;

d) Description of the item inspected (Serial number as a minimum);

e) Type of observations made;

f) Clear indication of nature and extent of inspector’s activities;

g) Reference to C&P Manual inspector duty;

h) Delete

i) Results of inspection (as a minimum: acceptable or not acceptable);

j) Record the NCCR issued, and the related corrective action verification;

k) Record the Monitoring activities;

l) Inspector National Board Commission Number and commission/endorsement designator, signature and date.

2.7.4.2 The Inspector shall use one, or more, page to record each day’s, or portion of a day’s, inspection activities. Each visit shall require a new page in the diary.

2.7.4.3 The Bound Diary must be always available at the location of inspection (shop, field or site). When field or site activity is completed or when the contract is terminated the Bound Diary shall be returned to C&P Head Office and will be maintained on file for 5 years as a minimum. Completed Bound Diary shall be returned to the C&P home office when all items of which inspection are recorded are completed and Manufacturer’s Data Report has been issued.

2.7.4.4 The Bound Diary is issued for each Client and each shop and covers all applicable Code Section. Separate Bound Diary for nuclear and non-nuclear inspections may be used. The inspector shall identify, in the cover page of the bound diary, if it is applicable to the nuclear or non-nuclear inspections.

2.7.4.5 All entries in the Bound Diary shall be carried out during the inspection, with a copy being sent to the C&P Head Office for use by the appointed Supervisor in the performance of their duties.




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2.7.4.6 The Bound Diary shall also be made available on request for ASME review during Surveys and investigations.

2.7.5 Monitoring

2.7.5.1 A duty of the Inspector is monitoring compliance with the Certificate Holder accepted Quality Control Program / Quality Assurance Program as described in the Certificate Holder Quality Control Manual / Quality Assurance Manual. The Inspector shall verify that the program, as described in the Certificate Holder Manual, has been implemented and maintained. The Inspector shall monitor each section of the Certificate Holder Manual at least once a year where the Certificate holder is active. A Certificate holder is considered active when at least one code related inspection has been carried out during the past year. The whole Quality Control System monitoring shall be completed within the year starting from first visit of the year. If no additional inspections are anticipated within the final three months of the year, then the Inspector shall complete the monitoring of any outstanding sections of the Quality Control System at that point or establish a plan (agreed with their Supervisor and the Certificate Holder) to complete the monitoring before the end of the year.

2.7.5.2 The inspector will record the monitoring in the Bound Diary monitoring page and fill in the Monitoring Record Form (OP007A) and distribute it to his Supervisor and to the Certificate Holder. The Bound Diary daily pages shall be used to record of the job(s) selected as audit templates, the objective evidence, any findings and all non-conformities. When non-conformities arise the inspector shall issue a Non-Conforming Condition Report (QU006A) and distribute it to the Certificate Holder and his Supervisor. The necessary corrective action shall be verified and accepted by the Inspector to ensure compliance with the Code requirements.

2.7.5.3 The inspector shall send a copy of the monitoring page of the Bound Diary to his supervisor three months before the end of the year for evaluation by the supervisor of the monitoring status.

2.8 Audits of Supervisors and Inspectors

2.8.1 Audits of Supervisors

The ATM, has the responsibility to annually schedule the audits of the activities performed by all C&P Authorized Nuclear Inspector Supervisors and Authorized Inspector Supervisors to verify compliance with the provisions of Part 1, 4 and 5




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of ASME QAI-1, NB-263/RCI-1 and applicable Code sections. The ATM shall issue the “Inspector and Supervisors Audit Schedule” (QU010A) as described in 2.8.2 below for each supervisor assigned by C&P. Each Supervisor shall be audited at least once a year, as planned by the ATM on the Annual Supervisor Audit Plan, or anytime there is a doubt that the Supervisor may not be effectively performing their specified duties. The audits shall be performed by an auditor, selected by the ATM, holding the same commission and endorsements as the Supervisor being audited. The selected auditor shall conduct the audit using the checklist CL008A “Supervisor Audit Checklist”. The supervisor to be audited shall be advised at least five days in advance by the auditor of the upcoming audit and which location (i.e. home office, site, by phone). The auditor shall inform the ATM about the result of the audit sending him the checklist CL008A signed by him and by the audited supervisor. The audits may be performed directly by the ATM according to QAI-1 1-1.2.5 (d) and 5-1.2.5 (d).

The ATM shall notify the National board, in writing, that the required QAI-1 and National Board Audits have been performed as part of the annual Commission/Endorsement renewal process.

No two Supervisors are permitted to audit each other, to avoid conflict of interest.

2.8.2 Audit of Inspectors

The audit of Inspectors shall be performed by the Supervisor assigned to the particular Inspector and be conducted/reported according to the “Authorized Inspector Audit Report” (OP003A) or “Authorized Nuclear Inspector Audit Report” (OP004A) as appropriate. The planning of the audit is as scheduled in the “Inspectors and Supervisors audit schedule” (QU010A), the Inspector is to be advised of the audit at least five days in advance. The Supervisor shall inform the affected Certificate Holder about the audit and request free access and cooperation to conduct the audit.

If an Inspector is active (at least one inspection performed since the last audit or designation) but have no other inspection activities within 1 year the Audit shall be performed at the following first inspection activity of the Inspector.

The “Inspectors and Supervisors audit schedule” (QU010A) is issued by the ATM at 18-month interval and updated monthly in order to keep the audit program under control. The ATM will distribute the “Inspectors and Supervisors audit schedule” to the supervisor for knowledge by e-mail. requiring a receipt by acknowledgment letter or email by return.




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2.8.3 Audit of ANI

The Authorized Nuclear Inspector Supervisor shall audit the performance of each active ANI assigned to him.

Audits, of active ANI (at least one inspection performed since the last audit or designation), shall be performed at least twice a year at the active shop or site to which he is assigned. When an Inspector is assigned to more than one active shop or site, at which Code activities are being performed, or have been performed since the previous audit, the ANI shall be audited at least once a year at each active shop. When an ANI is assigned to an inactive shop, he shall be audited at that shop when the shop come active.

An active shop is one Certificate Holder that has used its ASME Certificate of Authorization during the previous certification period.

The Audit schedule is issued by the ATM as described in para 2.8.2

2.8.4 Audit of AI/RI

The Authorized Inspector Supervisor shall audit the performance of each active Inspector Assigned to him at least once a year at approximately 12 months intervals at a shop or field site location where the Inspector is assigned. Requirements of para 2.8.2 are also applicable.



3. Document Control Edition 2 Rev. 2

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3 DOCUMENT CONTROL

3.1 Manual content and approval

This Manual defines goals and quality policies. It makes a clear distinction between responsibilities of different activities and it describes the work methods. The Manual is prepared, and approved and its implementation ensured by the ATM. The issue number and revision index is addressed at the top of each page of the Manual. The Manual is revised as a whole whenever a change is incorporated.

3.2 Manual Distribution

The current version of this Manual is formally distributed to all C&P personnel, Inspectors, Supervisors and administrative staff by the Administrative Manager. A copy of the Manual can be found on the C&P Server for ready access by C&P home office based staff, and a hard copy original is retained in the office for Head Office based personnel. All home based inspectors and supervisors have the controlled copy of the Manual available in the C&P web site through a password.

Administrative Manager uses a Manual Distribution Matrix MDM (DOC001A) to identify the personnel to be informed that a new or revised document has been issued. He is responsible for formal communication (i.e. electronically by email) to these personnel and requiring a receipt by acknowledgment letter or email by return. A copy of the communication and acknowledgements shall be kept on file.

Prior to implementation of a new issue or revision of this Manual is carried out a copy of this Manual is submitted to ASME for acceptance. A copy of the Manual will be sent to NB for approval. Controlled copies are sent as follow, one Controlled copy shall be sent by e-mail to the NB and one controlled copy shall be uploaded in the caconnect for ASME record. NB controlled copy have the copy number indicated hand written, signed and dated, on the cover page by AM.

This Manual has been written in English only. In case of translation in other language it shall be considered for information only and cannot be taken as reference.

All Forms, in the last applicable revision are listed in App.2, are available for use in a dedicated folder of the C&P Server accessible only by authorized personnel. Forms to be used by the inspectors and supervisors are also available for use in the C&P web site through a password.

3.3 Document control

All documents concerning the C&P Quality Program are reviewed and approved as per following table.



3. Document Control Edition 2 Rev. 2

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Document: Prepared by: Reviewed by: Approved by:

Manual ATM AM ATM

Procedure/work instruction ATM AM ATM

Code of Conduct (DOC022N) Management Representative

AM Management Representative

Manual Distribution Matrix (DOC001A) AM AM ATM

Note 1: When it comes necessary to call upon an expert for preparation and/or review of documents, procedures, work instructions etc., the ATM is responsible to verify that the level of competency is acceptable.

3.4 Revision of Documents

Revisions to the Quality Program Documents, including this Manual, follow the same process as the original issuance. The modified parts of the document are highlighted in blue bold and any deleted words are substituted by the word deleted in blue bold between brackets. The superseded documents are removed from C&P web site but retained as a historic record by the AM.

The ATM may decide to issue a new Edition of the Manual in which case the revision is brought back to zero and the edition number advanced by one.

The ATM shall review the ASME and NB websites every six months to identify if there have been any changes in the Code, QAI-1, NB-369, NB-263/RCI-1, NB-360 or NB-381. Whenever there are any changes in the Code, or any other specification affecting the Quality Program, the ATM shall review these to determine any impact upon the Quality Program and amend it as appropriate. The ATM shall record his review in the form QU008A “Code Change Review Log”.

Any revision of the Manual or concerning documents will be effective and implemented from the date of approval by the NB and date of acceptance by ASME, whichever is later.

Forms may be revised individually and the new revision number shall be shown in the list. Forms may be changed in format and content may be added without revision to the list, provided no information or data are removed from the form.

The revised forms will be included in the next revision of the Quality Program Manual. The revised forms shall be approved by the ATM before implementation.

3.5 Access to Code Books

All inspectors and supervisors have the ability to remotely access electronic copies of relevant Codes and standards via TechStreet Enterprise. The ATM shall ensure that access permissions are obtained and communicated by email to all new Inspectors.



4. Training Edition 2 Rev.2

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4 TRAINING

4.1 Training Policy

It is the responsibility of the ATM to provide for indoctrination and training of all personnel responsible for implementing the quality program, as a minimum the personnel to be indoctrinated and trained shall include:

- All Inspectors and Supervisors;

- The AM and the personnel supporting them in performing their duties concerning the quality program.

- Management Representative

- Auditors

The indoctrination and training shall be commensurate with the existing competence of involved personnel and their specific involvement in the quality program. The Management Representative is responsible for the indoctrination of a new ATM.

It is C&P policy that where a suitably competent person develops and approves a training document or program, that person will not be required to complete the defined qualification criteria, i.e. complete the examination. A suitable note with justification of their competence shall be recorded within their training record.

4.2 Indoctrination

The ATM is responsible for preparing specific courses dedicated to the C&P Quality Program (e.g. addressing the manual, procedures and applicable work instructions) and also any subsequent changes to it. The course duration shall be of a minimum of 8 hours. In case the course is based only to revised part of the Manual the minimum duration course may be reduced to 2 hours at ATM discretion. If persons involved have more than 2 year experience as inspector, duration may be reduced as determined by the ATM.

The proficiency achieved and maintained by C&P personnel shall be evaluated through examinations prepared by the ATM, or an individual delegated by them, comprising at least 10 questions covering all part of the relevant course. A minimum passing grade of 70% shall be required. In case the course is based only to revised part of the Manual the minimum examination question may be reduced to 4 at ATM discretion.

In case of non-pass grade the individual can retake the examination after two weeks in which he shall undertake self-study with Manual and course material made available to him by the ATM. If the individual does not pass the examination again, he shall take a new C&P Quality program course with new examination after at least one month from the second examination taken.




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Indoctrination schedules, course topics, verification of successful completion of examinations shall be retained on file by the AM as described in para 5 of this Manual.

4.3 Training

Inspectors and Supervisors shall be qualified according to on-job-training, experience and technical knowledge in relation to inspection activities to be performed.

The following paragraphs of this Manual define C&P’s policy regarding provision of continuous and on-job-training for all personnel involved with inspection activities in order to keep them up to date with field experiences, technological development and any modifications or changes in the Codes, regulations or specifications.

Participation in the C&P Annual Seminars (as described in para 4.5.10 of this Manual) is one of the requirements of continuous training.

4.4 ATM qualification

The ATM shall be qualified to the minimum education and experience listed in Table 4.1.

Evidence of education and experience shall be outlined in a C&P CV, signed by the ATM, and accepted by the Management Representative. This shall be filed by the AM.

Table 4.1 Title Minimum education

required Minimum experience required

ASME Technical Manager (ATM)

Technical high school diploma or, Technical University Degree

The ATM shall have:

• Five years in ASME Boiler and Pressure Vessel Code related work such as inspection under the provisions of the ASME Code, or administration of shop inspection service under the ASME Code

• One year experience as ASME Supervisor with B or NS endorsements

• A valid National Board In-service Commission and an R endorsement

The Management Representative is responsible for the designation, in writing, of the ATM after a satisfactory review of their education and experience.

4.5 Inspectors and Supervisors Qualification

4.5.1 Education and Experience

Prospective Inspectors and Supervisors shall satisfy the education and experience requirements as described in this section. Evidence of education and experience




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shall be outlined in a C&P CV, signed by the individual to be qualified accepted by the ATM and filed by the AM. The ATM has the right to question/verify the accuracy of the CV and take action against false declaration.

4.5.2 Qualification Requirements for Commission

A prospective Inspector shall have a high school education (12 years or equivalent educational system) and shall have a minimum of 5 credits points based upon the combination of education and experience as indicated in the Table 4.2 below.

Table 4.2

Education (1 Credit Minimum, 4 Credits Maximum) Credit Points Credit Points

Bachelor’s Degree or Higher in Engineering, Technology, Science, or Mathematic from an accredited institution.

3

Two (2) Year Degree or Certificate in Engineering, Technology, Science, or Mathematic from an accredited institution.

2

Graduation from an accredited technical school in subjects that include, but not limited to, Manufacturing; Building Construction; Construction Technology; Heating Ventilating and Air Conditioning; and Industrial Technology.

2

Completion of an accredited Power Engineering certification program. 2

Completion of an Accredited Apprenticeship Program, for example boilermaker, steamfitter or pipefitter.

2

Completion of an accredited military or merchant marine training program in the area of marine or stationary boilers, pressure vessels or nuclear reactors.

2

Completion of Certified Welding Inspector (CWI) certification program from the American Welding Society or an equivalent certification.

2

Certification as an American Petroleum Institute API-510 or API-570 Inspector. 2

Completion of a total of 80 hours of Classroom Technical Training in Boiler, Pressure Vessel or Piping Inspection.

Acceptable technology courses include such subjects as Quality Systems, Engineering, Fabrication Methods, Non-destructive Examination; courses on the knowledge, understanding and general structure of the NBIC or the ASME BPV Code or National Board courses on In-service Inspection (IC Course) or Inspection of ASME BPV Code items (AI Course).

1




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Experience (1 Credit Minimum, 4 Credits Maximum)

• One (1) credit point may be assigned for each year of experience associated with the pressure equipment industry in the categories below:

• Engineering or design review.

• Manufacturing, including fabrication methods or processes, in either shop or field.

• Operation of boiler(s) exceeding 50,000 lbs. of steam per hour total capacity.

• Performance of repairs, alterations, or maintenance of boilers or pressure vessels.

• Quality control systems related to boiler or pressure vessel manufacturing, repair, or alteration in either shop or field.

• Inspection of boilers or pressure vessels either inservice or during construction including either shop or field.

• NDE examiner of boiler and pressure vessels meeting ASNT Level II or III (qualified by examination) or equivalent qualifications.

• Note: Credit for concurrent experience in two or more categories will be limited to the experience in one category. For example, consider an individual who has been employed by a repair organization for two years as a quality control manager. The individual has also been qualified, during the same period, as a Level II NDE examiner. The allowable credit for experience is two years only. The two years’ experience as a quality control manager and the two years’ experience as a Level II NDE examiner are not additive: they are concurrent and the allowable credit is two years.

4.5.3 Qualification Requirements for Endorsements

Qualification requirements for endorsements are shown in Table 4.3 and Table 4.4. Provisional Inspectors and Supervisors seeking an endorsement shall fulfill the prescribed experience requirements (see tables 4.3 and 4.4) and take the appropriate National Board course, as detailed in Table 4.5, and pass the examination following the course.

Records of satisfactory completion of course examinations shall be verified by the ATM.

Table 4.3 Endorsement Designator

Endorsement Title

Qualifications

N Authorized Nuclear Inspector

• Holds the Authorized Inspector commission (AI) and subsequently either shall have been engaged for at least one (1) year in ASME BPV Code related work or shall have been engaged for at least one (1) year as an Inspector Trainee of nuclear items under the direct supervision of an Authorized Nuclear Inspector.

• Satisfactory completion of the National Board Nuclear Inspection course.




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Table4.4 Endorsement Designator

Endorsement Title

Qualifications

B Authorized Inspector Supervisor

• Holds the Authorized Inspector Commission (AI) and subsequently either shall have been engaged for at least two (2) years in ASME BPV Code related work such as inspection under the provisions of the ASME BPV Code or shall have been engaged for at least two (2) years in the administration of shop inspection services under the ASME BPV Code.

• Satisfactory completion of the National Board Inspector Supervisor course.

• Service with at least three shop review teams as a member or as an observer.

NS Authorized Nuclear Inspector Supervisor

• Holds the N endorsement and subsequently either shall have been engaged for at least two (2) years of diversified inspection experience in the construction of ASME BPV Code Sec on I; Sec on III, or Sec on VIII pressure equipment,

• or shall have been engaged for at least two (2) years in the administration of shop inspec on services under the referenced ASME BPV Code sections.

• Satisfactory completion of the National Board Authorized Nuclear Supervisor course.

• Service at least two nuclear surveys team as a member or as an observer or,

• Service as a member or observer on one ASME nuclear survey team, plus documented satisfactory completion of a course promulgated by ASME on the conduct of nuclear surveys and administration of ASME nuclear program.

Table 4.5

Title National Board course required

Inservice commissione IS Inservice inspection

Authorized Inspector Authorized Inspector Commission Course (AI)

Repair Inspector Repair Inspector Course (R)

Authorized Nuclear Inspector Authorized Nuclear Inspector Course (N)

Authorized Inspector Supervisor Inspector Supervisor Course (B/O)

Authorized Nuclear Inspector Supervisor Authorized Nuclear Inspector Supervisor Course (NS)

4.5.4 On the Job Training

Prospective Inspectors shall receive on-the-job training under the direct supervision of an Authorized Inspector as outlined in table 4.6.

The supervisor shall record the on-the-job training on the form OP001A (AI On the Job Training record) or OP002A (ANI On the Job Training record) as appropriate.

The Supervisor shall send the record to the ATM for review and acceptance.

All forms are filed by AM and retained as a record of the training.




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TABLE 4.6

Title Training required

Authorized Inspector

Eighty (80) hours of on-the-job training under the direct supervision of an inspector in fabrication and inspection of pressure-retaining items certified in accordance with the ASME BPV Code at either a shop or a field fabrication site that holds an active ASME Certificate of Authorization.

Authorized Nuclear Inspector

Twenty (20) hours on-the-job training in fabrication and inspection of

pressure-retaining items certified in accordance with the ASME BPV Code

at either a shop or a field fabrication site that holds an active ASME

Nuclear Certificate of Authorization.

The ATM has the authority to request any additional on-the-job-training whenever he believes it to be necessary.

When the prospective Inspector has previously worked as a Commissioned Inspector with another ASME Authorized Inspection Agency, the ATM may accept some or all of this experience and waive all or part of the specified on-the-job-training requirements. Records documenting successful completion of NB examination by the prospective Inspector and any evidence of satisfactory continuing education, shall be reviewed and accepted by the ATM and filed by the ATM, as per section 5 of this manual.

Where applicable, the ATM shall place a record on file, with the AM, justifying the waiving of some or all of the specified on-the-job training requirements.

4.5.5 Designation

The ATM is responsible for issuing the appropriate application documentation to the NB, as per Table 4.7 below or as modified by the National Board, for the issuance of a NB card with the required Commission and/or Endorsements no later than two (2) years after passing the appropriate National Board examination. Failure to do so may result in the Inspector having to resit the examination, and possibly the course, again.

Before signing and submitting the application, the ATM shall assess the prospective Inspector or Supervisor in accordance with Check List CL001A (Check List Authorized Inspector designation) or Check List CL006A (Check List Repair Inspector designation) or CL002A (Check List Authorized Nuclear Inspector designation) or CL003A (Check List Authorized Inspector Supervisor designation) or CL004A (Check List Authorized Nuclear Inspector Supervisor designation) as appropriate.

The ATM shall certify that the designated Inspectors and Supervisors meet the required experience and training requirements of QAI-1 part 1 and/or 5 and NB-263/RCI-1 as appropriate.

Once the NB card is received, and the prospective inspector has received the C&P quality program course described in para 4.2 of this Manual and satisfactorily completed the related examination the ATM designates the Inspector in writing and provides the name, office address, email address, office phone, and mobile phone of their assigned Supervisor.




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In the designation letter the ATM shall inform the inspectors that they shall contact their supervisor whenever they are unable to readily resolve any question concerning their duties and that they have the authority and the duty to refuse to sign any Data Reports involving nonconformance with the ASME Code.

The above written notice of Supervisor contact details shall be recommunicated to each Inspector annually or whenever there is a change in the contact details or assigned Supervisor with “Inspector Assignments” (DOC002A).

When the ATM is to be designated as inspector and/or supervisor the Management Representative takes the responsibilities of the ATM. The MR if necessary will call upon experts with same level of competency of the ATM.

TABLE 4.7 Commission required NB application required

AI/IS NB-120-2 / NB-120-1

Endorsement required NB application required

R NB-120-3

B NB-171-4

N NB-171-1

NS NB-171-6

Change of Employment NB-216-1

Reinstatement NB-216-2

4.5.6 Renewal of the Commission/Endorsement

National Board commissions expire annually on December 31. Each endorsement expires annually concurrently with the National Board Commission.

To be eligible for renewal, the Inspectors and Supervisors shall continue to be in the regular employment of C&P srl.

The ATM shall submit a request to the NB for renewal of all commission(s) and/or endorsement(s) after reviewing and verifying, using the Renewal of Commission/Endorsement Checklist (CL009A), that each Inspector and Supervisor has maintained proficiency by performing or supervising inspection-related activities, and has met the continuing education requirements of 4.5.11. The ATM shall as a minimum verify:

• Evidence of attendance at the C&P ASME annual seminar;

• Satisfactory results of annual Inspector Audits and/or Annual Supervisor audits;

• Evidence satisfactory completion of the National Board Continuing Education courses relevant to each commission and/or endorsement that is held by the Inspector/Supervisor.

http://www.nationalboard.org/SiteDocuments/Commissioned%20Inspectors/NB-216-2.pdf




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Inspectors and Supervisors shall only perform inspections or supervisory activities within the scope of any commission or endorsement that they hold.

4.5.7 Reinstatement of Commission/Endorsement

4.5.7.1 Inspectors and Supervisors whose commission(s) and/or endorsement(s) have not been renewed for more than two (2) years may have their commission(s) and/or endorsement(s) reinstated, provided the Inspector or Supervisor and ATM complete the Application for Reinstatement, under the Commissions and Certifications tab on the NB website, and that the Inspector or Supervisor has:

a) completed relevant continuing education course(s) (See Para 4.5.11) for each commission and/or endorsement to be reinstated within the twelve (12) months prior to the submittal date of the Application for Reinstatement;

b) Been actively employed by an organization that is directly involved in the boiler and pressure vessel industry and shall submit a work history showing verifiable qualifying work experience. (Examples of qualifying work experience include design, construction, manufacturing, repair, quality control, instructing, auditing, non-destructive examination, operation, or inspection of boilers, pressure vessels, or piping or other pressure-retaining items).

4.5.7.2 An Inspector or Supervisor whose commission(s) and/or endorsement(s) has not been renewed for more than two (2) years and who cannot meet the requirements of 4.5.7.1 shall retake and pass the National Board examination for each commission and/or endorsement to be reinstated. The Inspector or Supervisor shall provide verification of passing the National Board examination(s) by completing the appropriate sections of the Application for Reinstatement.

4.5.7.3 An Inspector or Supervisor whose commission(s) and/or endorsement(s) have not been renewed for a period of less than two (2) years, may have their commission(s) and/or endorsement(s) reinstated provided:

a) The Inspector or Supervisor has completed a continuing education course(s) (as per para.4.5.11) for each commission and/or endorsement requiring renewal within the 12 months prior to the submittal date of the Application for Reinstatement;

The Application for Reinstatement shall be evaluated by the National Board staff and approved by the Executive Director. In each instance the ATM shall certify, on behalf of C&P, that the Inspector or Supervisor has met all the requirements as stated on the Application for Reinstatement prior to submitting the application.




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4.5.8 Change of Employment

4.5.8.1 An Inspector or Supervisor, whose commission(s) or endorsement(s) that have not been renewed for a period of less than two (2) years and who has changed employment, may have their commission(s) or endorsement(s) transferred from a previous employer to C&P provided the Inspector or Supervisor and the C&P ATM complete the Application for Change of Employment, and:

a. The Inspector or Supervisor completes a continuing education course(s) (see Para. 4.5.11) within the 12 months prior to the submittal date of the Application for Change of Employment for each commission and endorsement to be transferred. The completion of the continuing education courses shall be documented on the Application for Change of Employment;

b. The C&P ATM certifies the Inspector or the Supervisor has met the requirements as stated on the Application for Change of Employment;

c. The Inspector or Supervisor shall return the commission card from the previous employer to the National Board;

In the event that the Inspector’s or Supervisor’s commission(s) or endorsement(s) have not been renewed for more than two (2) years, they will be required to seek reinstatement as described in para.4.5.7.

4.5.9 Inspector assignment

After the AM has opened a job for a new Client on ASC, the ATM will assign the Certificate Holder to an appropriate Inspector (considering the required Commissions/Endorsements and Inspector experience and workload into account). The ATM shall complete the “Inspector Assignment” (DOC002A) and distribute it to the applicable Inspectors and Supervisors, who will sign it for acknowledgement and return it to the AM for filing. The ATM shall reissue the “Inspector Assignment” whether there is a change or at least once a year.

4.5.10 Maintenance of Inspector competency

All technical personnel involved in Code activities shall maintain their knowledge base and stay up-to-date on new developments.

It is the responsibility of the ATM, assisted by the Supervisors, to ensure the maintenance of the Inspectors competency. This can be achieved via annual training sessions, seminar, question and answer sessions, work-related discussions, case studies, topics based on problems/solutions raised during the previous year, and any information or updates arising from ASME or the National Board, including Code changes, Code Cases, Interpretations etc.




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C&P Seminars shall generally be held at least annually, and may be conducted on local rather than global basis. The ATM or a Supervisor authorized by him will prepare a questionnaire based on the topics covered, any recent Code changes and general Code questions which will be completed by all Inspectors and Supervisors.

A minimum pass grade of 70% for a minimum of 10 questions will be required.

In case of non-pass grade the individual shall undertake additional training and retake examination. Type and duration of training and number of questions of the re-examination shall be defined by the ATM. During the period between the failed examination and the passing grade examination the activities of the inspector are suspended by the ATM.

Training documentation, including as a minimum training schedules, C&P annual seminar topics and results of examinations shall be retained by the AM for at least 5 years.

4.5.11 Continuing education requirements for commissions/endorsements

Each National Board Commissioned Inspector shall complete a National Board online training course appropriate for each commission and/or endorsement, as described in table 4.8 below

TABLE 4.8

Commission/endorsement hold Required continuing education course

Inservice Commission (IS) Inservice inspection

Authorized Inspector Commission (AI) or B Endorsement

Authorized Inspection: All ASME BPV Code Sections (Excluding Sections III and XI)

N or NS Endorsement Nuclear: ASME BPV Section III, Division 1

R Endorsement Repair Inspection Note 1: Continuing education courses are required to ensure inspectors maintain their knowledge base and stay up-to-date on new developments. Note 2: The chart above shows how the scope of training must track the type of commission/endorsement. As a result, some Inspectors may be required to take more than one continuing education course within each renewal year.

It is the ATM’s responsibility to instruct the Inspectors and Supervisors on which continuing education course they shall take and verify satisfactory completion.



5. Record Retention Edition 2 Rev. 2

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5 RECORD RETENTION

5.1 General

All C&P’s records are collected and maintained by the AM to meet the requirements of QAI-1, NB-369 and NB-381.

All records are made available for review by the Jurisdictional Authorities, ASME and the National Board upon request.

5.2 Record storage

All records required by applicable Code Sections, ASME QAI-1, NB-369, NB-381, this Manual and each completed template document hereto referenced shall be stored in the locked cabinet identified as “ASME DOC”.

To protect the records from damage, loss or deterioration the cabinet shall be away from fire sources, close to a fire extinguisher, away from water sources, and always closed in a dark condition. When not under control of AM, withdrawal shall be controlled through the use of a record register (DOC010A).

The record register and key of the cabinet are kept by the AM.

5.3 Record retention

The Code records are all documents necessary to demonstrate compliance with the applicable editions of the Code Sections, ASME QAI-1, NB-369, NB-381, this Manual .

As a minimum all documents controlled by this Manual shall be retained.

Particular records defined within this Manual, includes those documenting personnel qualifications, education & experience, maintenance of qualifications, designation letters, audit reports and annual management reviews, shall be kept readily available for the current calendar year before being archived in identified folders for at least a further 5 years. Records supporting Inspector qualifications shall be maintained and kept readily available while the Inspector is employed by C&P, they shall then be archived for a minimum of 5 years after the Inspector leaves the employment of C&P.

The AM is responsible for destroying the documents after the periods mentioned above as a minimum.

5.4 Clients’ files

Clients’ documentation, including contract, quotation and as applicable nuclear quality assurance manual, are maintained in a specific folder in a locked cabinet.

ANIS shall forward copies of modified nuclear quality assurance manuals to the office promptly.

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6. Corrective Actions Edition 2 Rev. 2

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6 CORRECTIVE ACTIONS

6.1 Non-conformities

Non-conformity is considered to be any activity or inspection that is not conducted in accordance with the C&P quality program (e.g. this manual and supporting procedures/work instructions).

It is the duty of all C&P personnel to notify the ATM whenever a non-conformity has been discovered, or suspected, by recording it on a Non-conformity Report (NCR) (Form QU001A), describing in detail the finding and referencing the Manual reference, Code paragraph, QAI-1 part or NB requirements that have not been meet.

Any finding in an audit or during the supervision of an Inspector shall also be recorded on a NCR

The ATM shall verify and evaluate any condition identified by them, or reported to them by C&P personnel, to determine if it is a non–conformance and the NCR is numbered and recorded on the NCR Log (DOC023A)

Where it is determined that the non-conformance is valid, the ATM shall instigate, in conjunction with others as necessary, appropriate corrective action to address the non-conforming condition. In the event that the reported non-conformance is not valid, this shall be recorded on the NCR with justification and the reporter shall be advised accordingly. Even in the event the reported non-conformance is determined to be non-valid, some form of corrective action may be necessary to avoid similar misunderstanding in the future, e.g. amend the Manual to clarify a requirement or possibly introduce new or additional training.

Once the corrective action has been identified, and the ATM is satisfied with the proposal, the ATM shall monitor implementation and verify its effectiveness to close the NCR.

This process is documented step by step on the NCR, including final satisfactory closure.

If the disposition doesn’t address the non-conformance to achieve a conforming condition, a new NCR shall be raised and the ATM shall describe the reason why the original action had not been successful and provide a new proposal for resolution of the non-conformance.

6.2 Corrective Action

In all instances, the ATM shall take appropriate corrective action to preclude a repetition of the non-conforming condition and document it on a CAR (Corrective Action Report) (Form QU002A). The CAR is recorded on the CAR Log (DOC024A).

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The ATM shall conduct, or decide who should conduct, the investigation to identify the root cause behind the non-conforming condition.

Once the investigation has been completed, the ATM defines the proposed corrective action to address and correct the non-conforming condition and who is required to implement the corrective action. The corrective action shall include the time for implementation. Once the individual charged to implement the corrective action has completed it, they shall record the details on the CAR and forward this to the ATM. The ATM shall evaluate the completed CAR to determine if the corrective action implementation has been effective and the non-conforming condition eliminated, if it has the CAR can be closed out.

6.3 Reporting to Management Representative

All NCRs and CARs shall be reported to the Management Representative once they have been closed out by the ATM.

The ATM shall prepare an annual report which includes details of all NCRs, their impact on the quality program and the effectiveness of CARs implemented during the previous year. This report will form part of the Annual Management Review Document.

.

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7. Audits Edition 2 Rev. 2

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7 AUDITS

7.1 Audit Process

The C&P quality program is to be periodically audited to verify compliance with specified requirements, including ASME QAI-1 part 1, 4, and 5, NB-381, NB-369, NB-263/RCI-1 and this manual to verify its effectiveness. It is the responsibility of the ATM to prepare an annual audit schedule. The audits shall be conducted by qualified personnel selected by the ATM to ensure they have no direct responsibilities in the areas being audited.

In instances where there are no suitably qualified personnel internally, who do not have direct responsibilities for the areas being audited, the Management Representative shall engage and qualify external resource to audit the areas concerned, e.g. the ATM duties.

7.2 Auditor Qualification

The audits shall be performed by appropriately trained and qualified personnel, according to C&P procedure PR003A. The training requirements are described in this procedure. For each qualified auditor the ATM issues an “Internal auditor certification sheet” (DOC014A). The ATM shall verify the currency of qualifications of potential auditors before selecting them.

7.3 Audit schedule

The ATM is responsible for the scheduling of the internal audits of the full Quality Program. The scheduling shall be undertaken every year and shall be recorded in the Annual Quality Program Audit Plan (QU003A).The audit schedule shall include the parts of the Quality Program to be audited, the appointed Auditors and the scheduled dates for the planned audits.

The frequency of the audits shall be as per table 7.1. The ATM has the authority to plan further audits at their discretion; these would be “unplanned” audits. The ATM shall notify the personnel responsible for the area being audited of the date for the audit at least two days in advance. This notice may be by phone or email and confirmation of this notification is to be recorded in the relevant space in the audit report. A copy of the communication shall be attached to the audit report (Check List CL005A) where appropriate.

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Table 7.1

Part of quality program Frequency Position not allowed as auditor

Organization Annually ATM,

Program description Annually ATM, Supervisors

Document Control Annually ATM

Training Annually ATM

Record Retention Annually AM

Audit/Corrective action Annually ATM

7.4 Audit Plan

The selected auditor shall prepare an audit plan before undertaking the audit (form OP008A, ASME Audit Plan). The audit plan shall include the date of the audit, the roles involved, the activities to be audited, the timings, including opening/closing meetings. The audit plan shall be sent to the audited organization/manager at least two days in advance.

7.5 Carrying out of the Quality Program Audits

The ATM informs, in writing (e-mail), the Internal Auditor of their obligations under the Annual Quality Program Audit Schedule to undertake internal audits. Based on the Audit Schedule issued by the ATM (Annual quality program audit plan QU003A) the Internal Auditor prepares the check list to be used for the audit (Internal Audit Check List CL005A).

The audit shall verify compliance with applicable requirements of QAI-1, applicable NB rules and C&P Quality Program to determine effective implementation of requirements.

The auditor shall collect objective evidence and reference this within the audit report and/or audit check list. They shall also verify the effective treatment of previous audit NC’s or observations.

The audit is carried out following the below steps as listed on Audit Plan:

• The Auditor defines the scopes, extension and criteria;

• The Auditor informs those responsible for the area under audit of the scope and plan for the audit and confirms the audit dates. Once things are arranged, the Auditor issues an email with this information and copies the ATM too;

• An opening meeting among Internal Auditor, those responsible for the area under audit and the related co-workers;

• Previous NC treatment verification;

• Verification of CAR effectiveness (the Auditor shall verify if a similar non-conforming condition occurs after implementation of the disposed CAR);

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• Collects and templates/assesses the template working practice, reviews objective evidence and examines work documents;

• Outcomes processing and check list compilation;

• Closing meeting.

At the closing meeting the audit results shall be presented to those responsible for the area under audit. Any findings shall be reported to the ATM using a NCR, the ATM will open a CAR as described in 6.2.

In instances where identified deficiencies may not require a follow-up audit, the auditor may suggest follow-up by the ATM. Any follow-up audit shall be approved by the ATM and be added to the audit schedule.

The Auditor shall prepare and issue an audit report (OP010A) which will include:

• Date of the audit;

• Description of the audit scope;

• Name and job title of the personnel audited;

• The check list used for carrying out the audit;

• The audit results;

• The status of treatment of Old Non Conformity Reports;

• New Non-Conformity Report list;

• Implementation and effectiveness of Corrective Action Report (previous audit);

• Follow Up actions required;

• Re-Audit (where required);

• Name and signature of the Auditor and of those responsible for the area under audit.

• Statement on the adequacy and effectiveness of implementation of the Quality Program

The Internal Auditor transmits the completed draft audit report to the ATM within 15 days of the closure of the Audit. Once satisfied, the ATM will circulate the audit report to those involved and place a copy on file as a record with the AM.

7.6 Management review

7.6.1 The quality program described in this Manual, and supporting procedures/instructions, shall be periodically reviewed by the ATM, in order to check the adequacy, effectiveness, maintenance of quality standards of C&P and the continuing professionalism of C&P’s personnel. The audit results, provided by Internal Audit Checklist (CL005A), Supervisor Audit Checklist (CL008A) and Inspectors audits (OP003A, OP004A) are brought, by the ATM, to Management

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Representative for review (ATM Report QU007A). The reports of the audits performed by ASME, monitoring of inspection personnel, Non Conformity Reports, Corrective Action Reports, complaints and analysis of causes, the changes of the Quality Program shall be analyzed and reported in the Management Review Report (form QU009A) by the Management Representative. This report shall state an evaluation of current quality program status and eventually defines action to solve sensitive situation that may bring to failure of quality program.

7.6.2 Furthermore the Management Representative shall review the overall activities of C&P to evaluate:

• The adequacy of current insurance and/or financial reserves to cover existing and future liabilities;

• A review to verify available finances and sources of income are free from commercial, financial, or other pressures which could compromise impartiality.

The Management Representative has the responsibility and authority to take action to address issues or circumstances considered to be a potential risk to impartiality; this may include deciding to suspend the service to a particular client if C&P becomes too dependent upon revenue from that source

.



App. 1 List of procedures and work instructions Edition 2 Rev.2

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App.1 LIST OF PROCEDURES AND WORK INSTRUCTIONS

Document no.

Title

IO-001A AUTHORIZED INSPECTOR NON-NUCLEAR INSPECTIONS

IO-002A AUTHORIZED INSPECTOR NUCLEAR INSPECTIONS

IO-003A AUTHORIZED INSPECTOR SUPERVISOR, NUCLEAR AND NON-NUCLEAR

PR002A PROCEDURE FOR ASME TECHNICAL MANAGER QUALIFICATIONI

PR003A INTERNAL AUDITOR QUALIFICATION



App. 2 List of documents and forms Edition 2 Rev.2

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App.2 LIST OF DOCUMENTS AND FORMS

Document no.

Title Rev Date Page

CL001A Checklist Authorized Inspector designation

3 2018/09/26 55

CL002A Checklist Authorized Nuclear Inspector designation

3 2018/09/26 56

CL003A Checklist Authorized Inspector Supervisor designation

3 2018/09/26 57

CL004A Checklist Authorized Nuclear Inspector Supervisor designation

3 2018/09/26 58

CL005A Internal Audit Checklist 3 2018/09/26 59-61

CL006A Checklist Repair Inspector designation

3 2018/09/26 62

CL008A Supervisor Audit Checklist 2 2018/09/04 63-65

CL009A Renewal of the Commission/Endorsement Checklist

1 2018/09/04 66

DOC001A MDM-Manual Distribution Matrix 2 2018/09/04 67

DOC002A Inspector assignment 4 2018/09/26 68

DOC004A Bound Diary template pages 3 2018/09/26 69-73

DOC005A Deleted - - -




DOC010A C&P ASME Record Register 1 2018/09/04 74

DOC014A Internal auditor certification sheet 3 2018/09/04 75

DOC015A AI assignment and AIS Certificate Holder List”

0 2018/06/15 76

DOC016A ANI assignment and ANIS Certificate Holder List

0 2018/06/15 77

DOC023A NCR Log 2 2018/09/04 78

DOC024A CAR Log 1 2018/09/04 79




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OP001A Authorized Inspector on job training record

2 2018/09/04 80

OP002A Authorized Nuclear Inspector on job training record

2 2018/09/04 81

OP003A Authorized Inspector audit report 4 2018/09/17 82-87

OP004A Authorized Nuclear Inspector audit report

3 2018/09/17 88-92

OP005A NS Certificate holder audit report 2 2018/09/04 93-99

OP006A Material organization audit report 3 2018/09/04 100-110

OP007A Monitoring Record Form 2 2018/09/04 111

OP008A ASME Audit Plan 2 2018/09/26 112-113

OP009A Deleted - - -

OP010A Audit Report 0 2018/09/26 114

QU001A Nonconformity report 3 2018/09/04 115-116

QU002A Corrective action report 3 2018/09/04 117

QU003A Annual Quality Program Audit Plan 2 2018/09/04 118

QU004A Deleted - -

QU006A Nonconforming condition Report 1 2018/09/04 119

QU007A ASME Technical Manager Report 1 2018/09/04 120

QU008A Code Change Review Log 1 2018/09/04 121

QU009A Annual Management Review 2 2018/09/04 122-123

QU010A Inspector and Supervisor Audit Schedule

0 2018/09/04 124




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CL001A Checklist Authorized Inspector designation page 1 of 1




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CL002A Checklist Authorized Nuclear Inspector designation page 1 of 1




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CL003A Checklist Authorized Inspector Supervisor designation page 1 of 1




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CL004A Checklist Authorized Nuclear Inspector Supervisor designation page 1 of 1




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CL005A Internal Audit Checklist page 1 of 3




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CL006A Checklist Repair Inspector Designation page 1 of 1




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CL008A Supervisor Audit Checklist page 1 of 3




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of 124

CL009A Renewal of the commission/Endorsement Checklist page 1 of 1




of 124

DOC001A MDM-Manual Distribution Matrix page 1 of 1




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DOC002A Inspector Assignment page 1 of 1




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DOC004A Bound Diary template pages page 1 of 5




of 124





of 124

DOC010A C&P ASME Record Register page 1 of 1




of 124

DOC014A Internal auditor certification sheet page 1 of 1




of 124

DOC015A Authorized Inspector Assignment and AIS Certificate Holder List page 1 of 1




of 124

DOC016A Authorized Nuclear Inspector Assignment and ANIS Certificate Holder List page 1 of 1




of 124

DOC023A NCR Log page 1 of 1




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DOC024A CAR Log page 1 of 1




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OP001A Authorized Inspector on job training record page 1 of 1




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OP002A Authorized Nuclear Inspector on job training record page 1 of 1




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OP003A Authorized Inspector audit report page 1 of 6




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of 124

OP004A Authorized Nuclear Inspector audit report page 1 of 5




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OP005A NS Certificate Holder Audit Report page 1 of 7




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of 124

OP006A Material Organization Audit report page 1 of 11




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of 124

OP007A Monitoring Record Form page 1 of 1




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OP008A ASME Audit Plan page 1 of 2




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OP008A ASME Audit Plan page 2 of 2




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OP010A Audit Report Page 1 of 1




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QU001A Nonconformity report page 1 of 2




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QU001A Nonconformity report page 2 of 2




of 124

QU002A Corrective action report page 1 of 1




of 124

QU003A Annual Quality Program Audit Plan page 1 of 1




of 124

QU006A Nonconforming Condition Report page 1 of 1




of 124

QU007A ASME Technical Manager Report page 1 of 1




of 124

QU008A Code Change Review Log page 1 of 1




of 124

QU009A Annual Management Review page 1 of 2




of 124

QU009A Annual Management Review page 2 of 2




of 124

QU010A Inspector and Supervisor Audit Schedule page 1 of 1