WHAT IS COMMERCIAL GRADE DEDICATION AND WHEN IS IT REQUIRED FOR NUCLEAR GRADE WELDING CONSUMABLES?
So what precisely is the significance of 10CFR Part 21 and 10CFR 50 Appendix B in the construction of nuclear power generating facilities? They are pretty important, because if they are not followed someone could go to jail … seriously. Title 10CFR Part 21 covers the disclosure to the Nuclear Regulatory Commission of any known defects or noncompliance of the products supplied to the nuclear power plant facility, including welding filer material. It sets the framework and requirements for the reporting of any knowledge of problems to the NRC by certain designated officers of the supplying company.
The second regulation mentioned above – Title 10CFR 50 Appendix B – is a binding set of rules designed to assure the safe operation of the nuclear power plant. In a few choice words, these are the quality assurance criteria for nuclear power plants and fuel reprocessing plants, enveloping activities related to designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying these structures.
Although not all of these activities are related to the manufacture and procurement of welding filler material, the quality assurance criteria that 10CFR 50 Appendix B outlines provide control of important product characteristics. These characteristics “flow-down” from the nuclear constructor or licensee to all subcontractors and material providers. Essentially, the licensee holds the filler metal manufacturer responsible for the same set of quality standards and accountability.
So with all of that being said, how is a supplier of nuclear-grade welding consumables to know if they are in compliance with Title 10 and hence the requirements of the Nuclear Regulatory Commission? Fortunately, there is a recognized standard – ASME NQA-1 –that can be implemented during the manufacturing and procurement process to assure that the legal requirements of the 10CFR have been met. ASME NQA-1, “Quality Assurance Requirements for Nuclear Facilities,” may be used for all safety related applications, whether they be in the within or the not within pressure boundary categories.
The exception is that if the application is within the nuclear pressure boundary and NQA-1 conflicts with Section III, then the requirements of Section III would take precedence. When would a situation like this arise? One possible type of conflict that occurs from time to time is a result of the fact that NQA-1 has been revised on a handful of occasions since its inception in 1978. And each time it was revised, there was a time lapse until each subsequent revision was formally adopted into ASME Section III, which has its own set of quality assurance guidelines. In regard to filler metal manufacturers who are certified Material Organizations, NCA-3800 – Metallic Material Organization’s Quality System Program – is the Article within Section III that applies.
Okay, the reason for the treatise presented above is to set the framework of what “Commercial Grade Dedication” (CGD) is and where it applies. The CGD process is essentially a “band-aid” to legally cover areas where the manufacturing process of a commercial grade (that is, off-the-shelf) item may not strictly meet the requirements of 10CFR 50 Appendix B or 10CFR 21. The extent of the band-aid is determined and approved by the nuclear licensee. That entity develops a set of critical characteristics (inspections, testing requirements, record keeping, etc.) that will provide assurance that the commercial item will meet the legal requirements of 10CFR, even though that product was not originally manufactured for that purpose.
The CGD process is defined and allowed by 10CFR 50 Appendix B and ASME NQA-1 and can be used for any safety-related application that is not within the pressure vessel boundary. Here again, we have another instance when NQA-1 conflicts with Section III, as the NRC has determined that material supplied under CGD could not be considered equivalent to that supplied under the quality requirements of ASME Section III, NCA-3800.1 Therefore, CGD may not be used in applications within the pressure boundary, but it can be used for safety-related applications not within the pressure boundary.
Now you may be wondering what codes and regulations apply for non-safety-related applications at nuclear facilities. After all, nuclear power plants are obviously huge facilities with many different welding applications besides those that are related only to safety. If this item is non-safety-related, then 10CFR 50 Appendix B and 10CFR Part 21 do not apply and we do not have to use either CGD or Section III. A constructor can literally buy any old stuff right off the shelf, and it would be permissible as long as it meets whatever other laws may apply (like local building codes).
1 U.S. Nuclear Regulatory Commission Information Notice 96-40.
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About the Author: Regis Geisler III is a registered Professional Engineer, Specials Certification Engineer and AWS Certified Welding Inspector who has worked the last eleven years at The Lincoln Electric Company, 22800 Saint Clair Avenue, Cleveland, OH 44117-8542, 216-481-8100, Fax: 216-486-1751, www.lincolnelectric.com. For questions or comments on this column, contact Regis at firstname.lastname@example.org.