Inspection and test control is the program that plans, executes, and documents the inspections and tests used to verify that items and activities conform to specified requirements. NQA-1 Requirement 10 (Inspection) and Requirement 11 (Test Control) establish the requirements, paralleled by 10 CFR 50 Appendix B Criteria X and XI. The program must cover the full sequence: what is to be inspected or tested, when in the work sequence, by whom, using what methods, against what acceptance criteria, and with what records generated. Inspections discovered to have been omitted or performed by unqualified personnel are treated as if no inspection occurred.
The inspection planning requirement
NQA-1 Requirement 10 requires that inspections be planned and performed by qualified individuals using documented procedures or checklists. The inspection plan must identify: what characteristic or activity is to be inspected, the applicable acceptance criteria, the inspection method, the qualification requirements for the inspector, and the point in the work sequence at which the inspection occurs. Inspection plans are developed during work planning, not during or after execution. A retroactively created inspection plan provides no quality assurance value.
The graded approach applies to inspection planning: not all items require the same inspection intensity. Safety-related components and items subject to code requirements need more rigorous inspection programs than general industrial supplies. The inspection plan for a safety-related valve involves dimensional verification, material verification, NDE examinations, pressure testing, and functional testing at defined hold points. The inspection plan for a consumable supply may involve receipt inspection against a specification and visual examination only.
Graded approach to inspection: Inspection programs should be scaled to the safety significance of the item. Higher significance items require more detailed inspection plans, more qualified inspectors, and more extensive documentation. Applying the same inspection intensity to all items regardless of significance is both inefficient and often insufficient for the highest-significance work.
Hold points and witness points in the inspection sequence
Hold points and witness points are the mechanisms by which the inspection plan enforces quality requirements in the work sequence. A hold point is a mandatory stop, work cannot proceed until the inspection is documented as complete and accepted. A witness point requires notification and the opportunity to observe, but work can proceed if the witness declines or does not respond within the notification period.
Both types of points must be identified in the inspection plan and reflected in the work package or traveller. Any waiver of a witness point must be documented, recording that notification was sent, the response received, and the decision to proceed. Proceeding past a hold point without authorised sign-off is a significant quality event requiring a non-conformance report, and depending on the nature of the work performed after the unsigned hold point, may require reinspection or reversal of subsequent work.
For ASME Section III code work, hold points (designated "H") and witness points (designated "W") are specified in the code requirements and traveller. The Authorized Nuclear Inspector (ANI) is required to witness or sign off on hold points before the traveller can be advanced. These are not discretionary; they are code-required controls that must be satisfied before the code stamp can be applied.
Test control and acceptance criteria
NQA-1 Requirement 11 requires that tests be conducted with calibrated equipment, using approved test procedures, with pre-established acceptance criteria. Test data must be recorded at the time of the test, not reconstructed afterward. A common finding is test data recorded on informal notes and then transcribed into the formal test record, this practice undermines the integrity of the test record, which should reflect measurements as taken, not as remembered.
If a test fails, results do not meet acceptance criteria, a non-conformance report must be initiated before any rework or re-testing begins. The test failure documents the condition of the item as found. Rework performed to address a test failure must itself be documented and the test must be re-executed after rework is complete. Re-testing after rework requires execution of the full test sequence unless the approved procedure specifically authorises a partial re-test with documented justification.
Test equipment must be calibrated and within its calibration interval at the time of the test. M&TE found to be out of calibration after a test was performed requires an impact assessment, evaluating whether the out-of-tolerance condition could have caused test results to appear acceptable when they were not. This assessment is a quality record and must be documented.
Qualification of inspection and test personnel
Inspectors and test personnel must be qualified for the specific inspection method or test type they perform. For non-destructive examination (NDE) methods, radiographic testing, ultrasonic testing, magnetic particle testing, liquid penetrant testing, personnel qualification is typically required to ASNT SNT-TC-1A or NAS 410 standards, which define qualification levels (Level I, II, III), the examination requirements for each level, and recertification intervals.
For other inspection activities, the organisation's QA program defines the qualification basis: what training is required, what examination must be passed, and what on-the-job experience is needed before independent inspection authority is granted. Qualification records must be current, an inspection performed by an individual whose qualification has expired is treated as if the inspection was performed by an unqualified individual, which in practice means the inspection must be repeated.
Maintaining current qualification rosters for all inspection personnel, and tracking upcoming expirations before work is scheduled, is a basic operational requirement of the inspection program. Discovering expired qualifications during an audit or after work has been completed creates significant remediation burden.
Forged Operations embeds hold and witness points directly into digital work packages. Inspectors sign off in real time, the system prevents progression past open hold points, and AI surfaces upcoming inspection milestones across all active work orders before they become bottlenecks.
References
- American Society of Mechanical Engineers. ASME NQA-1-2022: Quality Assurance Requirements for Nuclear Facility Applications, Requirement 10 — Inspection and Requirement 11 — Test Control. New York: ASME, 2022.
- U.S. Nuclear Regulatory Commission. "Criterion X — Inspection and Criterion XI — Test Control." Code of Federal Regulations, 10 CFR 50 Appendix B. Washington, D.C.: NRC.
- American Society for Nondestructive Testing. SNT-TC-1A: Personnel Qualification and Certification in Nondestructive Testing. Columbus, OH: ASNT.
- CSA Group. CSA N286:12(R2018): Management System Requirements for Nuclear Facilities, Clause 7 — Process Implementation. Toronto: CSA Group, 2018.