2.3 SITTNER NRC REQUIREMENTS RELATED TO INSPECTION OF COMMERCIAL GRADE DEDICATION

Related to Inspection and Commercial Grade Dedication
H.Y. Park, General Manager, Nuclear Overseas Project Quality Control Department
S. S. Sittner
S. Scott Sittner
Corporate Quality Management Consultant, ANSI-ASME-NQA-1, Certified Lead Auditor, Certified Auditor Trainer
NRC Requirements

DOOSAN Proprietary and Confidential 2
Table of Contents 2, 3
Learning Objectives 4
Objective 1 5
Overview 6,7
Definitions: Defect 7
Definitions: Basic Component, Deviation, Evaluation,
Non-Conformance 8
Definitions: Notification, Substantial Safety Hazard 9
Reporting of Defects Commercial Grade Item (CGI) 10, 11
Dedication 12, 13
Posting 14
Procedures for Notification: Evaluation and Deviations 15, 16
Procedures for Notification: 10 CFR 21, 10 CFR 50.55(e) 17
Failure to Notify 18
Procurement Documents 19
Inspection 20
Records 21
Maintenance and Inspection of Records 22
S. S. Sittner
NRC Requirements: Table of Contents

NRC Requirements: Table of Contents (continued)
Objective 2 24
Inspection CGI: Background 25
Inspection CGI: Objectives 26
Inspection CGI: Requirements 27, 28, 29
Inspection CGI: Objectives 30
Inspection CGI: Background 31
Inspection CGI: Reactive Inspection Requirements 32
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1.) Develop and understanding of 10 CFR 21, the relationship to
procurement and vendors, and responsibilities of licensees for
implementation..
2.) Identify the requirements of Commercial Grade Items (CGIs) in NRC
IPs 43004 and 38703.
NRC Requirements: Learning Objectives

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NRC Requirements: Objective 1
Develop an understanding of 10 CFR 21, the relationship to
Procurement, Vendors, and the responsibilities of licensees
for implementation.

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Overview
10 CFR 21 establishes the requirement to immediately
notify the NRC:
• Of the reasonable potential of substantial safety hazards,
followed by
• Written notification of evaluation results whether the facility,
activity, or basic component supplied to such a facility or
activity contains defects, which could create a substantial
safety hazard.
Exemption: Suppliers of Commercial Grade Items are exempt from
the provisions of this part to the extent that they supply Commercial
Grade Items.
NRC Requirements: 10 CFR 21 Reporting Defects and Noncompliance

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10 CFR 50.55 (e)
Applies to holders of construction permits and COLs under
10 CFR 52, and establishes the requirement to evaluate deviations
and failures to comply to identify defects and failures to comply
associated with substantial safety hazards, and to notify the NRC of
defects which could create a substantial safety hazard.

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Defect:
 A deviation in a basic component that could create a substantial safety
hazard.
 The installation, use, or operation of a basic component containing a defect
.
 A deviation in a portion of a facility subject to the:
• Early site permit
• Standard design certification
• Standard design approval
• Construction permit
• Combined license or manufacturing license requirements of part 50 or part 52, provided the
deviation could create a substantial safety hazard, and the portion of the facility containing
the has been offered to the purchaser for acceptance.
 A condition or circumstance involving a basic component that could
contribute to the exceeding or a safety limit, or
 An error, omission or other circumstance in a design certification, or
standard design approval that could create a substantial safety hazard.

DOOSAN Proprietary and Confidential
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 BASIC COMPONENT: A safety-related item. It includes design,
inspection, testing or consulting services important to safety that
are associated with the component hardware, whether these
services are performed by the component supplier or other.
 DEVIATION: A departure from the technical requirements included
in a procurement document or specified in early site permit
information, a standard design certification or standard design
approval.
 EVALUATION: The process of determining whether a particular
deviation could create a substantial hazard or determining whether
a failure to comply is associated with a substantial safety hazard.
 Non-Conformance: Failure to meet a specification or requirement
of 10 CFR 50, Appendix B.
9

10
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Notification:
• The telephonic communication to the NRC Operations Center and written
transmittal of information to the NRC Document Control Desk.
• Two working days are allotted from notification to phone call to the NRC
• Within 30 days, must provide final report.
Substantial Safety Hazard:
• A loss of safety function to the extent that there is a major reduction in the
degree of protection provided to public health and safety for any facility or
activity licensed or otherwise approved or regulated by the NRC, other than
for export.

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Commercial Grade Item (CGI)
When applied to nuclear power plants licensed pursuant to 10 CFR Part
30, 40, 50 (specifically 50.55(e)), 52, 60, Commercial Grade Item:
• Is a structure, system or component, or part thereof that effects its
safety function, that was not designed and manufactured as a basic
component.
• Does not include items where the design and manufacturing process
require in-process inspections and verifications to ensure that defect
s or failures to comply are identified and corrected (i.e., one or more
critical characteristics of the item cannot be verified).

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Commercial Grade Item (CGI) (continued)
When applied to facilities and activities licensed pursuant to 10 CFR Parts
20, 40, 50 (other than nuclear power plants), 60, 61, 63, 70, 71, or 72,
Commercial Grade Items Means that it is:
 Not Subject to Design or Specification Requirements, that are
unique to those facilities or activities;
 Used in applications other than those facilities or activities; and
 To be ordered from the manufacturer/supplier on the basis of
specifications set forth in the manufacturer’s published product
description (e.g. a catalog).

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DEDICATION
When applied to nuclear power plants licensed pursuant to 10 CFR Part
30, 40, 50, 60 dedication is:
• An acceptance process undertaken to provide reasonable assurance that a
commercial grade item to be used as a basic component will perform its
intended safety function and,
• Deemed equivalent to an item designed and manufactured under a 10 CFR
50, Appendix B, Quality Assurance Program.
The Assurance is achieved by:
• Identifying the critical characteristics of the item and
• Verifying their acceptability by inspections, tests, or analysis performed by the
purchaser or third-party dedicating entity after delivery, supplemented as
necessary by one or more of the following:
 Commercial Grade Surveys
 Product Inspection or Witness and Hold Points at the Manufacturer’s
Facility and
 Analysis of Historical Records for acceptable performance. In all
cases, the dedication process must be conducted in accordance
with the applicable provisions of 10 CFR Part 50, appendix B.

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DEDICATION (continued)
When applied to facilities and activities licensed pursuant to
10 CFR Parts 30, 40, 50 (other than nuclear power plants),
60, 61, 63, 70, 71, or 72, dedication:
 Occurs after receipt when that item is designated for use as
a basic component, if licensee is conducting the dedication a
s opposed to a 3rd party.
The process is considered complete when the item is
designated for use as a Basic Component.

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POSTING
Each individual, partnership, corporation, dedicating entity, or other
entity subject to the regulations in this part shall post current copies of:
• The regulations in 10 CFR 21
• Section 206 of the Energy Reorganization Act of 1974, and
• Procedures adopted pursuant to the regulations in this part.
These documents must be posted in a conspicuous position on any
premises within the United States where the activities subject to
10 CFR 21 are conducted.
NOTE: A similar posting requirement exists for 10 CFR 50.55 (e)

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Procedures for Notification: Evaluations and Deviations
Permit holders and licensees are required to adopt appropriate procedures for
notification of failure to comply (or existence of a defect and its evaluation).
Any facility subject to this regulation must adopt the following appropriate
procedures, including to:
• If such an evaluation cannot be completed within 60 days, an interim report
must be prepared and submitted to the Commission.
• The interim report should:
1.) Describe the deviation or failure to comply that is being evaluated
2.) Should also state when the evaluation will be completed
3.) Be submitted in writing within 60 days of discovery of the deviation or failure to comply
.
• Ensure that a director or responsible officer subject to the regulations of this
part is informed in all cases, within the 5 working days after completion of
the evaluation.

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Procedures for Notification: Evaluations and Deviations (CONTINUED)
• The dedicating entity is responsible for:
1.) Identifying and evaluating deviations.
2.) Reporting defects and failures to comply for the dedicated
item, and
3.) Maintaining auditable records of the dedication process
NOTE: A similar posting requirement exists for 10 cfr 50.55 (e)

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Procedures for Notification: 10 CFRs 21 and 50.55(e)
REQUIREMENT
10 CFR 21
• Initial notification by facsimile to the
NRC Operations Center within 2 days
following receipt of information by the
director or responsible corporate officer
on the identification of a defect or a
failure to comply. Does not apply to
interim reports.
• Written notification to NRC’s Document
Control Desk within 30 days following
receipt of information by the director or
responsible corporate officer on the
identification of a defect or a failure to
comply
REQUIREMENT
10 CFR 50.55(e)
• Initial notification by facsimile to the
NRC Operations Center within 2 days
following receipt of information by the
director or responsible corporate officer
on the identification of a defect or a
failure to comply.
• Written notification shall be submitted to
the NRC Document Control Desk, with
a copy to the appropriate Regional
Administrator and a copy to the
appropriate NRC resident inspector
within 30 days following receipt of
information by the director or
responsible corporate officer of a defect
or a failure to comply.

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Failure to Notify
Failure to notify refers to:
• Any Director or Responsible Officer of an entity (including dedicating entity) who
knowingly and consciously fails to provide the notice required as by 21.21
• Any NRC licensee or applicant for a license (including and applicant for, or holder of,
a permit), applicant for a design certification who fails to provide the notice required
by 21.21, or otherwise fails to comply with the applicable requirements.
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Procurement Documents
Each individual, corporation, partnership, dedicating entity, or other entity
subject to the regulations should ensure that each procurement document for
a facility, or a basic component issued by him, her or it on or after January 6,
1978, specifies that the provisions of 10 CFR Part 21 apply.
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21
Inspection
Each individual, corporation, partnership, dedicating entity, or other entity subject
to the regulations in this part must permit the Commission to inspect records,
premises, activities, and basic components as necessary to accomplish the
purposes of this part.
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Records
REQUIREMENT
10 CFR 21
• Retain evaluations of all deviations and
failures to comply for a minimum of 5
years after the date of the evaluation;
REQUIREMENT
10 CFR 50.55(e)
• Retain records of evaluations of all
deviations and failures to comply under
paragraph for …minimum of 10 years
after the date of the evaluation;
• Retain records of all interim reports to
the Commission…for the minimum time
period of 10 years.
• Maintaining records in accordance with
this section satisfies the recordkeeping
obligations under Part 21.
In coordination with 10 CFR Part 21, the requirements of 50.55 (e) are satisfied when the defect or
failure to comply associated with a substantial safety hazard has been previously reported under
Part 21 or under 50.55(e).
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Maintenance and Inspection of Records
Each individual, corporation, partnership, dedicating entity, or other entity subject to the
regulations in the part must prepare and maintain records, specifically:
• Retain evaluations of all deviations and failures to comply for a minimum of five years
after the date of the evaluation.
Applicants for standard design certification must comply with subparts B and E of Part 52.
The Commission must be granted the opportunity to inspect records pertaining to basic
components that relate to:
• The identification and evaluation of deviations, and
• The reporting of defects and failures to comply, including (any advice given to
purchasers or licensees on the placement, erection, installation, operation,
maintenance, modification, or inspection of a basic component.
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Identify the Requirements of Commercial Grade Items (CGIs)
Using NRC IPs 43004 and 38703
NRC Requirements: Objective 2
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NRC Requirements: Commercial Grade Items (CGI) Requirements
Background
Commercial Grade Dedication is required based on the following:
• Because of the decrease in the number of qualified nuclear-grade vendors,
licensees are increasing the number of commercial grade replacement
parts that they procure and dedicate for use in safety-related applications.
• Since Commercial Grade Dedications have increased in number, the
Nuclear Regulatory Commission (NRC) has developed this inspection
procedure to provide guidance to:
 Assist the inspector in assessing the effectiveness of the
implementation of the licensee’s commercial grade procurement
practices, and
 Provide for early identification of any adverse trends or emerging
problems.
S. S. Sittner

NRC Requirements: “Inspection of Commercial –Grade Dedication Programs”
NRC IP 43004 Objectives
The objective of this portion of the NRC IP 43004 is to verify that the dedicating
entity’s:
• Commercial-Grade Dedication Program satisfies the requirements of
Appendix B to 10 CFR 50, Appendix B, with regard to the procurement
and acceptance of Commercial-Grade Items CGIs) foIs meets the
applicable portions of Appendix B.
• Process for Dedicating CGIs meets the applicable portions of Appendix B.
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NRC Requirements: Inspection of Commercial-Grade Dedication Programs
NRC IP 43004 Requirements
The requirements regarding CGIs are to verify that the dedicating entity has:
• Established adequate controls for performing technical evaluations of items or
services to be dedicated.
• Established adequate controls for the acceptance of a CGI usint the criteria
established in Criterion VII of Appendix B.
• Properly developed and implemented a plan for commercial-grade dedications.
• Established adequate controls for the technical evaluation of the items or services
to be dedicated.
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NRC IP 43004 Requirements (continued)
Additional requirements outlined by the NRC IP 43004 include:
Technical Evaluations identify the necessary technical and quality requirements
That ensure the item will meet the intended design conditions.
• They are conducted and documented by the responsible engineering organization.
• Like-for-Like Commercial-Grade Item Replacement is a replacement of an item
with one that is identical. An equivalency evaluation is needed:
 If differences from the original item are identified in the replacement item,
then the item is not identical, but similar to the item being replaced, and
 To determine if any changes in design, material, manufacturing process,
safety, form, fit, function or interchangeability could impact the alternate
replacement item’s ability to function under all design and ultimately the
component’s ability to perform its required safety function.
In NRC Generic Letter 89-02, NRC staff conditionally endorsed the guidelines contained in EPRI NP-5652, “Guideline for
the Utilization of Commercial-Grade Items in Nuclear Safety- Related Applications (NCIF-07), “that was issued by EPRI in
June 1988 for evaluating Commercial Grad Products for Suitability for use in safety related applications.
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NRC IP 43004 Requirements (continued)
Additional requirements outlined by the NRC IP 43004 include ASME XI, which
provides:
• Rules for the examination, in-service testing and inspection, and repair and
replacement of components and systems in light water cooled and liquid metal
cooled nuclear power plants.
• Rules for inspection and testing of components of gas cooled nuclear power
plants have been deleted in the 1995 Edition.
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NRC Requirements: Commercial Grade Dedication
NRC IP 38703 Objectives
The objective in having this inspection on Commercial Grade Dedication
is to:
• Determine whether the failure of a safety-related structure, system,
component (SSC), or part thereof, to perform its intended safety
function was the result of a deficient Commercial Grade Item (CGI)
Dedication Process.
• Verify that the licensee’s process for dedicating CGIs, as implemented:
 Meets the applicable portions of Appendix B to 10 CFR Part 50,
and
 Provides reasonable assurance that CGIs will perform their
intended safety function.
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NRC Requirements: Commercial Grade Dedication
NRC IP 38703 Background
The need for the NRC IP 38703 is due to:
• The decrease in the number of qualified nuclear-grade vendors:
Licensees are increasing the number of Commercial Grade Replacement
parts that they procure and dedicate for use in safety-related
applications, and
• The increase in Commercial Grade Dedications;
 The Nuclear Regulatory Commission (NRC) has developed this
inspection procedure to provide guidance to assist the inspector in
assessing the effectiveness of the implementation of the licensee’s
commercial grade procurement practices and provide for early
identification of any adverse trends or emerging problems.
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NRC Requirements: Commercial-Grade Dedication
NRC IP 38703 Reactive Inspection Requirements
• Initial Evaluation:
 Review licensees evaluation of failed item;
 If failed item was dedicated, review complete procurement and dedication
process to determine thoroughness
• Further Assessments:
 If it is determined that the dedicated item failed as the result of certain critical
characteristics not being identified and/or properly verified, perform the
following assessments:
 Determine if other CGIs from the same accepted lot or batch as the failed dedicated
CGI have been similarly dedicated and installed in other safety-related applications.
 If possible select and evaluate, as in step 1 above, at least three other dedicated
CGIs having similar applications and critical characteristics as the CGI(s) that resulted
in the identified failures.
 If, after performing step 2 above, it is determined that there were weaknesses in the
commercial grade dedication process, the inspector should perform a more
comprehensive inspection of the licensee’s dedication process.
S. S. Sittner

2.3 SITTNER NRC REQUIREMENTS RELATED TO INSPECTION OF COMMERCIAL GRADE DEDICATION

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