NUREG/CR-6752 

INEEL/EXT-01-01 127

A Comparative Analysis of 

Special Treatment Requirements 

for Systems, Structures, and 

Components (SSCs) of Nuclear 

Power Plants With Commercial 

Requirements of Non-Nuclear 

Power Plants 

Idaho National Engineering and Environmental Laboratory 

U.S. Nuclear Regulatory Commission 

Office of Nuclear Reactor Regulation 

Washington, DC 20555-000 1
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NUREG/CR-6752 

INEEL/IEXT-01-01127 

A Comparative Analysis of 

Special Treatment Requirements 

for Systems, Structures, and 

Components (SSCs) of Nuclear 

Power Plants With Commercial 

Requirements of Non-Nuclear 

Power Plants 

Manuscript Completed: September 2001 

Date Published: January 2002 

Prepared by 

J. H. Phillips, J. L. Edson, M. R Holbrook, 

M. E. Nitzel, A. G. Ware 

Idaho National Engineering and Environmental Laboratory 

Idaho Falls, ID 83415-3129 

D. C. Fischer, NRC Project Manager 

Prepared for 

Division of Engineering 

Office of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

NRC Job Code J2828
ABSTRACT

This report describes a comparative analysis between the special treatment 

requirements applied to systems, structures, and components in nuclear power 

plants and commercial requirements applied to systems, structures, and 

components in non-nuclear power plants. This comparative analysis focused on 

the practices applied to systems, structures, and components in nonsafety related 

applications (balance-of-plant) at nuclear plants with additional information on 

non-nuclear power facilities. Site visit information, other nuclear power plant 

information, and regulatory documents were used to perform a critical process 

evaluation. The typical life cycle of nuclear systems, structures, and components 

was divided into four critical stages, and the processes affecting each of these 

stages were identified. The critical attributes of each of these processes were then 

identified so that the differences between nuclear and balance-of-plant 

approaches could be studied. Evaluations characterized any significant 

differences between the nuclear processes, attributes, and special treatment rules 

(applicable codes and standards) and the corresponding nuclear balance-of-plant, 

or commercial processes, attributes, and applicable codes and standards as they 

relate to providing reasonable confidence of component functionality. 

Component specific commercial codes and standards were reviewed for 33 

different components that are typically required to comply with special treatment 

rules. The conclusions obtained during this project were divided into three 

categories: State and Federal Requirements Commercial Practice; Differences in 

Special Treatment Rules and Commercial Practices; and Use of Commercial 

Codes, Standards, and Practices for RISC-3 Systems, Structures, and 

Components. One conclusion states that commercial standards by themselves are 

not adequate to provide reasonable confidence of functionality; however, using a 

combination of detailed engineering specifications, plant processes and 

procedures, and multilevel quality assurance programs that augment commercial 

requirements, but provide less rigor than that described in Code of Federal 

Regulation 10 Part 50, Appendix B, "Quality Assurance Criteria for Nuclear 

Power Plants and Fuel Reprocessing Plants," might be a potential way to 

establish reasonable confidence of functionality.

iii
CONTENTS 

ABSTRA CT ................................................................................................................................................ iii 

EX ECUTIVE SUM M ARY ......................................................................................................................... xi 

ACRON YM S ............................................................................................................................................ xvii 

1. INTROD UCTION .............................................................................................................................. I 

1.1 Background .............................................................................................................................. 1 

1.2 M ethodology ............................................................................................................................ 2 

2. UTILITYN ENDOR VISITS ......................................................................................................... 3 

2.1 Com m onwealth Edison (CornEd) ........................................................................................ 3 

2.2 San Onofre Nuclear Generating Station (SON GS) .............................................................. 3 

2.3 Sargent & Lundy ............................................................................................................. 3 

2.4 CCI Valves ............................................................................................................................... 4 

2.5 A SCO Solenoid Valves ...................................................................................................... 4 

2.6 Discussions with ITT Barton and Reliance M otors ........................................................... 4 

3. CRITICA L PROCESS EVALUATION ........................................................................................ 5 

3.1 Process Descriptions ........................................................................................................... 5 

3.1.1 Processes Common to All Life-Cycle Stages of a SSC .......................................... 5 

3.1.2 Design Stage ........................................................................................................... 5 

3.1.3 Procurement Stage ................................................................................ ................. 6 

3.1.4 Installation Stage .................................................................................................... 6 

3.1.5 Operation Stage ....................................................................................................... 6 

3.1.6 Table 2 - Critical Process/Attribute Evaluation ...................................................... 7 

4. COMPONENT COMPARATIVE ANALYSIS ........................................................................... 8 

4.1 IS 09001 .................................................................................................................................. 9 

4.2 Centrifugal Pumps ............................................................................................................. 10 

4.2.1 Com m ercial Standard .......................................................................................... 10 

4.2.2 Special Treatment Requirements ......................................................................... 10 

4.2.3 Centrifugal Pump Synopsis .................................................................................. 10 

4.2.4 Commercial Standards Comparison with Nuclear Processes ............................... 10 

4.3 Positive Displacement Pumps ................................................................................................ 11

v
4.3.1 Com m ercial Standard ............................................................................................... 11 

4.3.2 Special Treatment Requirements ............................................................................ 11 

4.3.3 Positive Displacem ent Pum p Synopsis ................................................................ 11 

4.3.4 Commercial Standards Comparison with Nuclear Processes ............................... 11 

4.4 Valves .................................................................................................................................... 12 

4.4.1 Com m ercial Standard .......................................................................................... 12 

4.4.2 Special Treatm ent Requirem ents ......................................................................... 12 

4.4.3 Related Nuclear Guidance ................................................................................... 12 

4.4.4 V alve Synopsis .................................................................................................... 12 

4.4.5 Commercial Standards Comparison with Nuclear Processes ............................... 13 

4.5 Valve Operators ..................................................................................................................... 14 

4.5.1 Com m ercial Standard .......................................................................................... 14 

4.5.2 Special Treatm ent Requirem ents ......................................................................... 14 

4.5.3 V alve Operator Synopsis ..................................................................................... 14 

4.5.4 Commercial Standards Comparison with Nuclear Processes ............................... 14 

4.6 Solenoid Operated Valves .................................................................................................. 14 

4.6.1 Com m ercial Standard .......................................................................................... 14 

4.6.2 Special Treatm ent Requirem ents ......................................................................... 14 

4.6.3 Solenoid Valve Synopsis ..................................................................................... 14 

4.6.4 Commercial Standards Comparison with Nuclear Processes ............................... 15 

4.7 Piping ..................................................................................................................................... 15 

4.7.1 Comm ercial Standard .......................................................................................... 15 

4.7.2 Special Treatm ent Requirem ents ......................................................................... 16 

4.7.3 Piping Synopsis .................................................................................................... 16 

4.7.4 Commercial Standards Comparison with Nuclear Processes ............................... 16 

4.8 Pressure Vessels ..................................................................................................................... 17 

4.8.1 Com m ercial Standard .......................................................................................... 17 

4.8.2 Special Treatment Requirem ents ......................................................................... 17 

4.8.3 Pressure Vessel Synopsis ...................................................................................... 17 

4.8.4 Commercial Standards Comparison with Nuclear Processes ............................... 17 

4.9 Containm ent Penetrations .................................................................................................. 18 

4.9.1 Com m ercial Standard .......................................................................................... 18 

4.9.2 Special Treatm ent Requirem ents ......................................................................... 18 

4.9.3 Containm ent Penetration Synopsis ....................................................................... 18 

4.9.4 Commercial Standards Comparison with Nuclear Processes ............................... 19 

4.10 Tanks ...................................................................................................................................... 20 

4.10.1 Comm ercial Standard .......................................................................................... 20

vi
4.10.2 Special Treatm ent Requirem ents ......................................................................... 20 

4.10.3 Tanks Synopsis ................................................................................................... 20 

4.10.4 Commercial Standards Comparison with Nuclear Processes .............................. 20 

4.11 Heat Exchangers .................................................................................................................... 21 

4.11.1 Com m ercial Standard ......................................................................................... 21 

4.11.2 Special Treatm ent Requirem ents ......................................................................... 21 

4.11.3 Heat Exchanger Synopsis ..................................................................................... 21 

4.11.4 Commercial Standards Comparison with Nuclear Processes .............................. 21 

4.12 Pipe Supports ......................................................................................................................... 22 

4.12.1 Com m ercial Standard ......................................................................................... 22 

4.12.2 Special Treatm ent Requirem ents ......................................................................... 22 

4.12.3 Pipe Support Synopsis .......................................................................................... 22 

4.12.4 Commercial Standards Comparison with Nuclear Processes .............................. 23 

4.13 Vessel and Tank Supports ................................................................................................. 24 

4.13.1 Com m ercial Standard ......................................................................................... 24 

4.13.2 Special Treatm ent Requirem ents ......................................................................... 24 

4.13.3 Vessel and Tank Support Synopsis ..................................................................... 24 

4.13.4 Commercial Standards Comparison with Nuclear Processes .............................. 24 

4.14 Gaskets ................................................................................................................................... 25 

4.14.1 Com m ercial Standard ......................................................................................... 25 

4.14.2 Special Treatm ent Requirem ents ......................................................................... 25 

4.14.3 Gasket Synopsis ................................................................................................... 25 

4.14.4 Commercial Standards Comparison with Nuclear Processes .............................. 25 

4.15 Air Com pressors .................................................................................................................... 26 

4.15.1 Com m ercial Standard ......................................................................................... 26 

4.15.2 Special Treatm ent Requirem ents ......................................................................... 26 

4.15.3 A ir Com pressor Synopsis ..................................................................................... 26 

4.15.4 Commercial Standards Comparison with Nuclear Processes .............................. 27 

4.16 H VA C .................................................................................................................................... 28 

4.16.1 Com m ercial Standard ......................................................................................... 28 

4.16.2 Special Treatm ent Requirem ents ......................................................................... 28 

4.16.3 Related Nuclear Guidance .................................................................................. 28 

4.16.4 HVA C Synopsis ................................................................................................... 28 

4.16.5 Commercial Standards Comparison with Nuclear Processes .............................. 28 

4.17 Rupture Disks ........................................................................................................................ 29 

4.17.1 Com m ercial Standard ......................................................................................... 29 

4.17.2 Special Treatm ent Requirem ents ......................................................................... 29

vii
4.17.3 Rupture Disk Synopsis .......................................................................................... 29 

4.17.4 Commercial Standards Comparison with Nuclear Processes .............................. 29 

4.18 Ion Exchangers ...................................................................................................................... 30 

4.18.1 Com m ercial Standard ......................................................................................... 30 

4.18.2 Special Treatm ent Requirem ents ........................................................................ 30 

4.18.3 Ion Exchanger Synopsis ....................................................................................... 31 

4.18.4 Commercial Standards Comparison with Nuclear Processes .............................. 31 

4.19 Bolts ....................................................................................................................................... 31 

4.19.1 Comm ercial Standard ......................................................................................... 31 

4.19.2 Special Treatm ent Requirem ents ........................................................................ 31 

4.19.3 Bolts Synopsis ..................................................................................................... 32 

4.19.4 Commercial Standards Comparison with Nuclear Processes .............................. 32 

4.20 Anchor Bolts .......................................................................................................................... 33 

4.20.1 Com m ercial Standard ......................................................................................... 33 

4.20.2 Special Treatm ent Requirem ents ........................................................................ 33 

4.20.3 Related Nuclear Guidance .................................................................................. 33 

4.20.4 Anchor Bolts Synopsis .......................................................................................... 33 

4.20.5 Commercial Standards Comparison with Nuclear Processes .............................. 33 

4.21 Lighting .................................................................................................................................. 34 

4.21.1 Com m ercial Standard ......................................................................................... 34 

4.21.2 Special Treatm ent Requirem ents ........................................................................ 34 

4.21.3 Lighting Synopsis ................................................................................................ 34 

4.21.4 Commercial Standards Comparison with Nuclear Processes .............................. 35 

4.22 Alarm s .................................................................................................................................... 35 

4.22.1 Com m ercial Standard ......................................................................................... 35 

4.22.2 Special Treatm ent Requirem ents ........................................................................ 36 

4.22.3 Alarm s Synopsis ................................................................................................... 36 

4.22.4 Commercial Standards Comparison with Nuclear Processes .............................. 36 

4.23 Electrical Switchgear ........................................................................................................ 36 

4.23.1 Com m ercial Standard ......................................................................................... 36 

4.23.2 Special Treatm ent Requirem ents ........................................................................ 36 

4.23.3 Electrical Switchgear Synopsis ........................................................................... 36 

4.23.4 Commercial Standards Comparison with Nuclear Processes .............................. 36 

4.24 M olded Case Circuit Breakers ......................................................................................... 37 

4.24.1 Com m ercial Standard ......................................................................................... 37 

4.24.2 Special Treatm ent Requirements ........................................................................ 37 

4.24.3 M olded Case Circuit Breaker Synopsis ............................................................... 37

VIii
4.24.4 Commercial Standards Comparison with Nuclear Processes .............................. 38 

4.25 Transformers .......................................................................................................................... 39 

4.25.1 Comm ercial Standard ......................................................................................... 39 

4.25.2 Special Treatm ent Requirem ents ......................................................................... 39 

4.25.3 Transform er Synopsis ......................................................................................... 39 

4.25.4 Commercial Standards Comparison with Nuclear Processes .............................. 39 

4.26 M otors .................................................................................................................................... 40 

4.26.1 Comm ercial Standard ......................................................................................... 40 

4.26.2 Special Treatm ent Requirem ents ......................................................................... 40 

4.26.3 M otor Synopsis ................................................................................................... 40 

4.26.4 Commercial Standards Comparison with Nuclear Processes ................................... 40 

4.27 M otor Control Centers ..................................................................................................... 41 

4.27.1 Comm ercial Standard ......................................................................................... 41 

4.27.2 Special Treatm ent Requirem ents ......................................................................... 41 

4.27.3 M otor Control Center Synopsis ........................................................................... 42 

4.27.4 Commercial Standards Comparison with Nuclear Processes .............................. 42 

4.28 Electrical Cabling .......................................................................................................... 43 

4.28.1 Comm ercial Standard ........................................................................................ 43 

4.28.2 Special Treatment Requirem ents ......................................................................... 43 

4.28.3 Electrical Cabling Synopsis ................................................................................ 43 

4.28.4 Commercial Standards Comparison with Nuclear Processes .............................. 43 

4.29 M otor-Generator Units ..................................................................................................... 44 

4.29.1 Comm ercial Standard ......................................................................................... 44 

4.29.2 Special Treatm ent Requirem ents ......................................................................... 44 

4.29.3 M otor Generator Synopsis .................................................................................. 44 

4.29.4 Commercial Standards Comparison with Nuclear Processes .............................. 44 

4.30 Diesel Generators ............................................................................................................. 45 

4.30.1 Commercial Standard ......................................................................................... 45 

4.30.2 Special Treatm ent Requirements ......................................................................... 45 

4.30.3 Diesel Generator Synopsis .................................................................................. 45 

4.30.4 Commercial Standards Comparison with Nuclear Processes .............................. 46 

4.31 Batteries ................................................................................................................................. 47 

4.31.1 Comm ercial Standard ......................................................................................... 47 

4.31.2 Special Treatment Requirements ......................................................................... 47 

4.31.3 Battery Synopsis ................................................................................................... 47 

4.31.4 Commercial Standards Comparison with Nuclear Processes .............................. 48

ix
4.32 Battery Chargers .................................................................................................................... 49 

4.32.1 Commercial Standard ......................................................................................... 49 

4.32.2 Special Treatment Requirements ......................................................................... 49 

4.32.3 Battery Charger Synopsis .................................................................................... 49 

4.32.4 Commercial Standards Comparison with Nuclear Processes .............................. 49 

4.33 Inverters ................................................................................................................................. 50 

4.33.1 Commercial Standard ......................................................................................... 50 

4.33.2 Special Treatment Requirements ......................................................................... 50 

4.33.3 Inverter Synopsis ................................................................................................. 50 

4.33.4 Commercial Standards Comparison with Nuclear Processes .............................. 50 

4.34 Process Instrumentation ................................................................................................... 51 

4.34.1 Commercial Standard ......................................................................................... 51 

4.34.2 Special Treatment Requirements ......................................................................... 51 

4.34.3 Process Instrumentation Synopsis ....................................................................... 51 

4.34.4 Commercial Standards Comparison with Nuclear Processes .............................. 52 

5. SUM MARY AND CONCLUSIONS .......................................................................................... 53 

5.1 Component Comparative Analysis Conclusions ................................................................ 53 

5.2 Overall Project Conclusions (Includes All Tasks) ........................................................... 54 

5.2.1 State and Federal Requirements ........................................................................... 54 

5.2.2 Commercial Practice ............................................................................................ 54 

5.2.3 Differences in Special Treatment Rules and Commercial Practice ...................... 55 

5.2.4 Use of Commercial Codes, Standards, and Practices for RISC-3 SSCs .............. 55 

6. REFERENCES ................................................................................................................................. 57 

7. GLOSSARY ..................................................................................................................................... 64 

Appendix A-Tables ..................................................... A-1 

X
EXECUTIVE SUMMARY

The Nuclear Regulatory Commission (NRC) has recommended that risk

informed approaches to the application of special treatment rules, such as those 

addressing quality assurance, codes and standards, seismic events, environmental 

qualification, environmental conditions, and natural phenomena, be developed. 

One option is to change the regulatory scope for systems, structures, and 

components (SSCs) needing special treatment. This option would not change the 

design bases for a plant or the design-basis accidents that establish the design 

conditions for SSCs. Safety-related SSCs that are of low safety significance 

would move from special treatment to normal industrial (or commercial grade) 

treatment. They would still be expected to perform their design function, but 

without the additional margin, assurance, or documentation currently required for 

safety-related SSCs. 

This report provides a comparative analysis between the special treatment 

rules applied to SSCs in nuclear power plants and commercial requirements 

applied in non-nuclear power plants, or nuclear balance-of-plant (BOP), or both 

in an effort to understand the extent to which commercial processes and 

requirements assure safety-related but low safety significant SSCs will perform 

their design functions. 

Information contained in this .report was gathered during visits to two 

nuclear utilities, one architect/engineering firm, and two component 

manufacturers, and through review of commercial codes and standards. 

Contacted personnel typically included procurement managers, quality assurance 

managers, plant operators, and maintenance engineers. During utility and vendor 

visits, all phases of the SSC life cycle were discussed including component 

design, manufacture, installation, and operation. A review of commonly available 

commercial component codes and standards was performed to determine if they 

addressed the special treatment rules. 

Nuclear power plant documents were used to develop a list of processes 

and attributes that are affected by special treatment rules. The typical SSC life 

cycle was subdivided into four stages: design, procurement, installation, and 

operation. These SSC life-cycle stages were used and typical nuclear power plant 

activities were reviewed to establish the list of processes. Attributes were 

identified and assigned to the appropriate SSC life-cycle stage under the 

applicable process. Processes and attributes were categorized as either critical or 

noncritical based on expert opinion. Processes and attributes that were judged to 

have a significant effect on component functionality were categorized as critical. 

It was found that applying the definition of a critical process or attribute (those 

requirements that are individually or jointly necessary to reasonably ensure 

functionality of a SSC) is difficult because it is easy to think of a scenario or 

example where each process and attribute is necessary to assure functionality. 

Evaluations were performed to characterize any significant differences 

between the nuclear processes, attributes, and special treatment rules (applicable 

codes and standards) and the corresponding nuclear BOP, or commercial 

processes, attributes, and applicable codes and standards, or both as they relate to 

providing reasonable confidence of a component's functionality. Component

xi
specific commercial codes and standards were reviewed for 33 different 

components that are typically required to comply with special treatment rules. 

The codes and standards were obtained from discussions with vendors, standard 

specifications, and the knowledge and experience of the authors. The most 

applicable codes and standards for the individual components were selected. 

Many of them referenced other codes and standards, but it was beyond the scope of this work to review all of these referenced codes and standards. 

Conclusions 

State and Federal Requirements 

1. There are few actual commercial requirements to cover BOP equipment 

and processes. Most importantly, state laws (with the exception of South 

Carolina) require the use of the American Society of Mechanical 

Engineers (ASME) Code for boilers and pressure vessels (e.g., B3 1.1, 

Section 1, or Section VIII), and other pressure boundary equipment. 

2. Most Western states dictate the use of the Uniform Building Code that 

requires seismic analysis. Eastern states use the National Building Code, 

while Southern states use the Standard Building Code. These national 

building codes typically require some seismic analysis and could 

potentially provide an alternative for the seismic special treatment rules. 

However, use of these codes may result in a change to the design basis of 

the plant. 

3. Most requirements and processes for BOP equipment are not implemented 

by state or federal law. Nuclear utilities visited typically apply 

commercially available standards and make limited use of their own 

nuclear processes and manufacturers' recommendations to cover the BOP 

equipment. However, the authors note that these BOP practices may vary 

from plant to plant and should not be construed as equivalent to processes 

applied to safety-related components. 

4. There are no BOP equipment requirements for a quality assurance 

program, although ASME Code Sections 1 and VIII state quality 

requirements for boilers and pressure vessels, and external piping for 

boilers and pressure vessels. Some engineering firms and equipment manufacturers use International Organization for Standardization (ISO) 

9001 as a quality assurance program basis for BOP equipment. As with all 

commercial standards not imposed by local and state laws or ordinances, 

compliance with ISO 9001 is voluntary. Use of this standard is not 

universal in the commercial industry and its implementation has been 

found to vary due to the variety of organizations responsible for certifying 

ISO 9001 programs. 

5. Standards for manufacturing valves (e.g., ASME B 16.34) are not required 

to be used as long as the valves are used within the specified pressure

temperature ratings (see B3 1.1, Section 107). However, some BOP 

equipment manufacturers commonly use these standards.

xii
Commercial Practice

1. Commercial practice varies widely from almost no processes for some 

industries to a higher quality of processes similar to, but not nearly as 

rigorous as those for nuclear safety-related equipment. 

2. Since state or federal law does not cover most processes for BOP 

equipment, utilities use commercially available standards and/or their 

own procedures and practices to cover many of the processes. 

Consequently, the processes may vary widely from plant to plant. 

3. There are no recommendations for BOP motor-operated valve (MOV) 

qualifications that correspond to the recommendations contained in 

Generic Letter (GL) 89-10 and GL 96-05. Therefore, typical commercial 

practices do not focus on demonstration of MOV functionality under 

worst-case conditions and are not concerned with identifying MOV

related performance degradations that may affect the acceptability of 

established control switch settings. 

4. To minimize confusion, the two visited nuclear utilities prefer to use 

many of the nuclear processes for BOP equipment. These utilities 

preferred not to introduce additional procedures or processes. 

5. San Onofre Nuclear Generating Station and Commonwealth Edison 

personnel indicated that plant processes developed from a quality 

assurance program in 10 CFR 50, Appendix B, "Quality Assurance 

Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," are 

selectively used for some BOP equipment. The BOP processes are 

primarily driven by economic concerns, and therefore are typically less 

rigorous than those required for nuclear safety-related processes. For 

example, one utility used its plant modification control process to replace 

an office building HVAC unit. Clearly the controls on this replacement 

would be less than those used for a nuclear safety-related SSC, but 

greater than what would be required in the commercial world. 

Differences in Special Treatment Rules and Commercial Practice 

1. For the majority of the components evaluated there were significant 

differences in the commercial standards and the special treatment rules. 

Many of the commercial standards do not require a Quality Assurance 

program and were not developed to consider all of the life-cycle stages of 

an SSC. The standards were narrowly focused on one process such as 

design. 

2. Many of the commercial standards focused on design requirements, 

manufacturing, or testing. Although the requirements are often different, 

there seemed to be little difference in providing reasonable confidence of 

functionality between commercial standards requirements and the special 

treatment rules for these processes. This does not mean that the 

requirements were the same, that there were no significant physical 

differences in nuclear and commercial products, or that commercial

xiii
standards could be used without plant processes. Even in instances where 

there were no significant differences in a process, commercial standards 

may not be adequate and must be supplemented. For example, a 

commercial standard might adequately require the consideration of 

design requirements, but specific design conditions must be implemented 

by a detailed equipment specification. 

3. The critical nature of some of the processes and attributes is component 

specific. For example, functional testing and design verification are 

much more important for active than for passive SSCs. 

Use of Commercial Codes, Standards, and Practices for RISC-3 SSCs 

I1. Commercial standards by themselves are not adequate to provide 

reasonable confidence of functionality. Implementing measures that use 

a combination of detailed engineering specifications, plant processes and 

procedures, and multilevel QA programs, which provide for less rigor than required by 10 CFR 50, Appendix B, but that augment commercial 

requirements, might be one potential way to establish reasonable 

confidence of functionality. 

2. Most of the process attributes were evaluated as critical for establishing 

reasonable confidence of SSC functionality. However, not all special 

treatment requirements are necessary to achieve reasonable confidence of 

component functionality. This is especially true for the process attributes 

that provide confirmation of component functionality, such as the 

documentation-related process attributes. Many of the special treatment 

rules are from 10 CFR 50, Appendix B. While some sort of quality 

program is needed for reasonable confidence of SSC functionality, a full 

quality assurance program as defined in 10 CFR 50, Appendix B does 

not seem to be warranted for RISC-3 SSCs. 

3. Plant processes will have a significant effect on providing reasonable 

confidence of functionality of components. Determination of the 

adequacy of the commercial standards and reduced plant processes 

would have to be evaluated on a plant-by-plant basis. It was beyond the 

scope of this project to evaluate the adequacy of BOP processes used by 

plants. 

4. Some utility personnel indicated that a form of commercial dedication 

for RISC-3 components would be beneficial. They believed that using 

the original equipment manufacturer and operating history would give 

reasonable confidence of functionality of replacement parts or SSCs. 

5. One critical attribute was the design specification. If this document 

includes detailed requirements (e.g., functional, environmental, loads, 

materials, quality, etc.), then it is more likely that the correct product 

(manufactured according to the design requirements) will be selected. 

For example, if the design requirements state that a solenoid operated valve (SOV) must function in a radiation environment, then a 

commercially available SOV (which would probably have major

xiv
physical differences from a nuclear SOV, including materials not 

designed for radiation environments) would not be selected. 

6. For the NRC to allow the use of commercial practices to procure RISC-3 

replacement SSCs, they would have to rely heavily on the good judgment 

of nuclear utilities and provide minimum requirements for the processes 

used. This may result in relatively little documentation or in-plant testing 

or inspections to provide reasonable confidence of functionality when 

compared to nuclear processes.

xv
ACRI 

AISC American Institute of Steel 

Construction 

ANSI American National Standards Institute 

ASCE American Society of Civil Engineers 

ASHRAE American Society of Heating, 

Refrigeration, and Air Conditioning 

Engineers 

ASME American Society of Mechanical 

Engineers 

ASTM American Society of Testing and 

Materials 

AWS American Welding Society 

AWWA American Water Works Association 

BOP balance-of-plant 

CFR Code of Federal Regulations 

EQ Environmental Qualification 

GDC general design criteria 

GL Generic Letter 

HVAC heating, ventilation, and air 

conditioning 

ICS Industrial Control and Systems 

(NEMA) 

IEEE Institute of Electrical and Electronic 

Engineers 

IESNA Illuminating Engineering Society of 

North 

IP&D instructions, procedures, and drawings 

ISA Instrument Society of America 

ISI in-service inspection 

ISO International Organization for 

Standardization

ONYMS 

IST 

LSS 

MCC 

MCCB 

MIL-SPEC 

MOV 

MSS

NEC 

NEMA 

NFPA 

NRC 

OM 

PTC 

QA 

RG 

SMACNA 

SOV 

SP 

SSC 

TEMA 

UBC 

UL

in-service testing 

low safety significance 

motor control center 

molded case circuit breakers 

military specification 

motor-operated valve 

Manufacturers Standardization 

Society of the Valve and Fittings 

Industry 

National Electric Code 

National Electrical Manufacturers 

Association 

National Fire Protection Association 

Nuclear Regulatory Commission 

operation and maintenance 

Performance Test Code 

quality assurance 

Regulatory Guide 

Sheet Metal and Air Conditioning 

Contractors National Association, Inc. 

solenoid-operated valve 

Standard Practice 

systems, structures, and components 

Tubular Exchanger Manufacturers 

Association 

Uniform Building Code 

Underwriters Laboratory

xvii
A Comparative Analysis of Special Treatment 

Requirements for Systems, Structures, and 

Components of Nuclear Power Plants with 

Commercial Requirements of Non-Nuclear Power 

Plants 

1. INTRODUCTION

The Nuclear Regulatory Commission (NRC) 

has recommended that risk-informed approaches 

to the application of special treatment rules, such 

as those addressing quality assurance, codes and 

standards, seismic events, environmental qualifi

cation, environmental conditions, and natural 

phenomena, be developed. One option is to change 

the regulatory scope for systems, structures, and 

components (SSCs) needing special treatment. 

Safety-related SSCs that are of low safety 

significance would move from special treatment to 

normal industrial (or commercial grade) treatment. 

They would still be expected to perform their 

design function, although without the additional 

margin, assurance, or documentation currently 

required for safety-related SSCs. 

This report provides a comparative analysis 

between the special treatment rules applied to 

SSCs in nuclear power plants and commercial 

requirements applied in non-nuclear power plants 

and nuclear balance-of-plant (BOP) in an effort to 

understand the extent to which commercial 

processes and requirements assure that safety

related but low safety significant SSCs will 

perform their design functions. The scope of this 

review is based on the following special treatment 

requirements, which include supporting 

documentation, such as the NRC Standard Review 

Plan and Regulatory Guides. 

* 10 CFR 50.55a, American Society of 

Mechanical Engineers (ASME) Boiler and 

Pressure Vessel Code Sections ImI and XI, 

Operation and Maintenance (OM) Codes, 

and generic letters related to motor-operated 

valves (MOVs). 

* 10 CFR 50.49 (environmental qualification 

of electric equipment).

10 CFR 50, Appendix A, (General Design 

Criteria [GDC] 1, 2, 4, 45, and 46) and 

Appendices B and S. 

* 10 CFR 100, and Appendix A to Part 100. 

This comparative analysis focused on the 

practices applied to SSCs in nonsafety related 

applications at nuclear plants with additional 

information on non-nuclear power facilities. 

1.1 Background 

In SECY-98-300, the NRC staff recommended 

under Option 2 that risk-informed approaches to 

the application of special treatment requirements 

be developed. This option addressed implementing 

changes to the regulatory scope for SSCs needing 

special treatment. Option 2 did not change the 

design bases for the plant or the design-basis 

accidents that establish the design conditions for 

SSCs. Safety-related SSCs that are of low safety 

significance (RISC-3) would move from special 

treatment to normal industrial (or commercial 

grade) treatment. In SECY-99-256 the staff 

indicated that RISC 3 SSCs would receive 

sufficient regulatory treatment such that the 

functionality of these SSCs would be maintained, 

albeit at a reduced level of assurance, and that this 

level of assurance may be provided by the 

licensee's commercial programs. 

In order to verify that the licensee's 

commercial programs provide an acceptable level 

of assurance that components will meet their 

functional requirements, one needs to understand 

the extent to which normal industrial (or 

commercial grade) treatments, such as design 

standards or practices, provide a basis for assuring

I
that a component's or group of components' 

functional requirements will be satisfied, albeit at 

a reduced level of assurance than would be 

provided by having those components subject to 

the various regulatory special treatment 

requirements. For example, it is necessary to 

understand for various types of components, how 

licensees' processes for procuring commercial 

grade SSCs and the associated commercial 

standards assure the functional capability of the 

component. 

1.2 Methodology 

Information contained in this report was 

gathered through reviewing commercial codes and 

standards, and during visits to two nuclear utilities, 

one architectural engineering firm, and two 

component manufacturers. Contacted personnel 

typically included procurement managers, quality 

assurance managers, plant operators, and 

maintenance engineers. During the utility and 

vendor visits, all phases of the SSC life cycle were 

discussed including component design, 

manufacture, installation, and operation. Nuclear 

power plant documents were used to develop a list 

of processes and attributes that are affected by special treatment rules. To facilitate this activity, a 

process was defined as: 

"... one of several steps needed to be carried 

out in completing the design, procurement, 

installation, or operation of an SSC;" 

and attributes were defined as: 

"...the requirements that may be needed to 

complete the process. Each attribute cannot be 

broken logically into a smaller similar 

attribute, but may contain more than a single 

step or requirement."

The typical SSC life cycle was subdivided into 

four stages: design, procurement, installation, and 

operation. The SSC life-cycle stages were used 

and typical nuclear power plant activities were 

reviewed to establish the list of processes. 

Attributes were identified and assigned to the 

appropriate SSC life-cycle stage under the 

applicable process. Processes and attributes were 

categorized as either critical or noncritical based 

on expert opinion. Processes and attributes that 

were judged to have a significant effect on 

component functionality were categorized as 

critical. It was found that applying the definition of 

a critical process or attribute (those requirements 

that individually or jointly are necessary to 

reasonably ensure functionality of a SSC) is 

difficult because it is easy to think of a scenario or 

example where every process or attribute is 

necessary to assure functionality. 

Evaluations were performed to characterize 

any significant differences between the nuclear 

processes, attributes, and special treatment rules 

(i.e., applicable codes and standards) and the 

corresponding nuclear BOP, or commercial 

processes, attributes, and applicable codes and 

standards, or both as they relate to providing 

reasonable confidence of a component' s 

functionality. Component specific commercial 

codes and standards were reviewed for 33 different 

components to determine if they addressed he 

special treatment rules. The codes and standards 

were obtained from discussions with vendors, 

standard specifications, and the knowledge and 

experience of the authors. The most applicable 

codes and standards for the individual components 

were selected. Many of these codes and standards 

referenced other codes and standards, but it was 

beyond the scope of this work to review all of 

these referenced codes and standards.

2
2. UTILITY AND VENDOR VISITS

To learn the differences in the treatment of 

nuclear safety systems, nuclear balance-of-plant 

(BOP), and commercial (e.g., fossil power plant) 

SSCs with regard to practices (procurement, 

installation, and maintenance) it is important to 

gain knowledge from firms (architectural 

engineers, component vendors, and electric 

utilities) that have experience with both nuclear 

and nonnuclear practices. Discussions were held 

with personnel from two utilities, one architect

engineering firm, and two component 

manufacturers. Contacted personnel typically 

included procurement managers, quality assurance 

managers, plant operators, and maintenance 

engineers. The following sections summarize the 

conclusions obtained from these visits. 

2.1 Commonwealth Edison 

(ComEd) 

Nuclear processes are used for BOP 

equipment and other site processes. ComEd 

representatives noted that creating another process 

that must be followed is not wanted. Relying on a 

single process (e.g., using a modification package 

for BOP components) to perform similar tasks on 

safety-related and nonsafety-related components 

decreases the likelihood of human error. This 

concept is also applied to the procurement of spare 

parts. If an item has both a safety-related and 

nonsafety-related application, a cost analysis is 

performed to determine whether to buy both safety 

and non-safety, only safety, or only nonsafety and 

perform commercial dedication when the 

component is needed in a safety application. 

Environmental qualification (EQ) accounts for 

less than 1% of the parts purchased by ComEd. 

Utility representatives did not believe that it is cost 

effective to dedicate commercial components for 

use in harsh environments. 

If a component is classified as a RISC-3, Low 

Safety Significance (LSS) Safety-Related, ComEd 

has a draft process that is used to effectively 

accept items for safety-related use based on the 

manufacturers application of industry standards.

2.2 San Onofre Nuclear 

Generating Station 

(SONGS) 

San Onofre Nuclear Generating Station 

(SONGS) and ComEd have laboratories that are 

used to commercially dedicate piece parts used in 

safety-related components. These laboratories can 

be used with revised processes to easily dedicate 

commercial components for RISC-3, LSS 

applications. Significant savings would be 

anticipated for ASME pressure boundary and 

seismic components. 

Utility representatives would also like to use 

the nuclear commercial dedication process for 

procurement of RISC-3, LSS components. They 

suggested that the commercial dedication process 

be changed to allow the original equipment 

manufacturer and history to be used as a basis for 

component dedication. 

2.3 Sargent & Lundy 

Sargent & Lundy implemented an 

International Organization for Standardization 

(ISO) 9001 program in 1998 for both nuclear 

safety-related and other work. Sargent & Lundy 

personnel indicated that this implementation was 

easy for the nuclear projects. However, 

implementation for fossil and other types of 

projects was more complicated, since the quality 

programs implemented were more project-specific. 

Members of fossil projects indicated that there 

is little process control at many fossil power 

plants. Areas mentioned included a lack of 

equipment configuration control. For example, 

drawings may not be maintained to reflect the as

built condition. In addition, some equipment is 

used at fossil power plants without formal 

qualification and with little supporting quality 

documentation. 

Nonetheless, Sargent & Lundy has few 

differences between the design controls for nuclear 

projects and other projects. While a fossil project 

typically will write fewer procedures and generate

3
fewer records than a nuclear project, design bases 

are maintained for both. For example, there are no 

differences in the design requirements for 

drawings on either type of project. The only 

difference in the requirements for design 

calculations is that the reviewer of a calculation 

supporting a fossil powered plant does not have to 

be as independent as the reviewer of a calculation 

for a nuclear project. 

The discussions on practices at fossil powered 

plants suggest the existence of a wide variation in 

the meaning of the term "commercial practice." 

2.4 CCI Valves 

CCI is a specialty valve manufacturer that 

produces one-of-a-kind valves to solve specific 

customer needs. CCI's manufacturing processes 

use some commercial codes (ASME B3 1.1 and 

ASME B 16.34) if the customer specifies no codes. 

Therefore, these codes form the basis for CCI's 

lowest quality levels. CCI also uses the same 

documentation traveler system for both 

commercial and nuclear components. There appear 

to be few significant differences between the 

quality of safety-related and nonsafety-related 

components at CCI. However, our observations 

may not be representative of other valve 

manufacturers who produce commonly available 

off-the-shelf valve products. 

CCI uses mostly analysis (and some limited 

testing) to ensure seismic capability for 

commercial applications. Seismic spectra and 

shaker tables are only used to address nuclear 

component seismic requirements. Fraudulent 

components are an industry problem and CCI 

avoids purchasing specific types of parts from 

some countries. For example, care must be 

exercised when purchasing bolting material and 

flanges. 

2.5 ASCO Solenoid Valves 

ASCO maintains a different product line for 

commercial and nuclear components. There are 

some significant differences in the construction of 

nuclear and commercial components. Examples 

include the use of heavier supports for nuclear

seismic components, use of metal instead of 

plastic in nuclear components, the use of different 

elastomers, and the use of larger coils in solenoid 

valves used in nuclear applications. 

The manufacturer can modify commercial 

solenoid valves without changing the model 

number. ASCO believes it would be difficult, if 

not impossible, to commercially dedicate their 

commercial solenoid valves for nuclear application 

due to the materials used and the variability in 

piece parts. ASCO personnel stated that they do 

not endorse or support the use of commercial 

solenoid valves for safety-related applications. 

2.6 Discussions with ITT 

Barton and Reliance Motors 

Telephone conversations held by the NRC 

with ITT Barton (pressure transmitters) and 

Reliance Motors indicated that there was a 

significant difference between nuclear and 

commercial products manufactured by these 

companies. 

ITT Barton personnel noted that piece-part 

substitution is allowed on commercial pressure 

transmitters and that commercial transmitters are 

much less rugged than the nuclear grade 

components. 

Reliance personnel noted that their nuclear 

motors are completely different from their 

commercial products. Nuclear-grade ac motors 

have a unique square-frame motor design where 

the stator is laminated into the frame as opposed to 

being pressed-in. Nuclear-grade motors have 

different insulation materials that are of higher 

quality and use specific varnish on the windings. 

These motors also use a different type of bearing 

grease and the elastomer seals are made of Viton 

as opposed to the Neoprene used in commercial 

motors. In addition, nuclear motors and the 

associated component parts receive additional 

dedication and qualification testing.

4
3. CRITICAL PROCESS EVALUATION

3.1 Process Descriptions 

Nuclear power plant documents were used to 

develop the list of processes that are affected by 

special treatment requirements. The typical SSC 

life cycle was subdivided into the following 

stages: 

1. Design Stage 

2. Procurement Stage 

3. Installation Stage 

4. Operation Stage. 

The SSC life-cycle stages were used and 

typical nuclear power plant activities were 

reviewed to establish the list of processes that are 

described in Section 3.1.1. Attributes were 

identified and assigned to the appropriate SSC-life 

cycle stage under the applicable process. The 

current listing of processes versus SSC life-cycle 

stages is presented in Table 1 (see Appendix A). 

3.1.1 Processes Common to All Life

Cycle Stages of a SSC 

Documentation (Process 1) is the process 

used to construct the "birth to death" historical 

record of an SSC as it progresses through the 

stages of its life cycle. Thus, this process is 

common to all stages of a SSC life cycle as 

indicated in Table 1. Typical nuclear power plant 

licenses require various levels of detail in the 

required documentation depending on the safety 

significance of the SSC being considered. 

Quality Assurance (Process 2) is required in 

all stages of the life cycle of an SSC. This process 

provides for the program, personnel, procedures, 

and management attention that is used to assure 

that all activities (design, installation, 

maintenance, repair, etc.) related to an SSC are 

performed in a manner that maintains the 

appropriate level of performance, quality, and 

safety.

Procedure Control (Process 3) is the process 

used to specify and document how work will be 

done. Procedure control is used in all stages of the 

SSC life cycle. Procedures control and prescribe 

how quality activities are to be accomplished. 

Procedure control is used to specify how the 

design activities are accomplished, specify how 

procurement is accomplished, specify how 

installation is done, and how plants are operated. 

Testing, Inspection, and Examination 

(Process 4) constitutes the process in which the 

SSC is verified to meet its design performance and 

quality requirements. Some of the attributes for 

these processes are common to all stages of the 

SSC life cycle. These include program 

requirements to ensure that the SSC will perform 

as designed, that written procedures have adequate 

acceptance criteria, and that test results are 

documented and evaluated. 

3.1.2 Design Stage 

Design Requirements (Process 5) constitutes 

the process in which the many types of 

information needed to specify the design are 

identified and assembled. These include the 

performance, functions, and operating modes that 

will be required of the SSC. 

Analysis (Process 6) constitutes the 

computational process used to assure the safety 

and functionality of the design. In this process, the 

design is analytically evaluated according to the 

requirements of the applicable codes and 

standards, and it is verified that the design meets 

these requirements. 

Design Verification (Process 7) is the process 

that provides assurance that an SSC will perform 

its functions throughout its required lifetime under 

all anticipated normal, abnormal, and accident 

conditions. These conditions include equipment 

operations, normal and accident environments, and 

external effects such as floods and earthquakes. 

Design verification may include EQ as required by 

10 CFR 50.49.

5
Design Control (Process 8) delineates the 

process by which the activities related to the 

design of an SSC are controlled. The attributes for 

this process are intended to assure that the 

appropriate level of detail is devoted to design 

activities, design acceptability, approval, etc. 

3.1.3 Procurement Stage 

Procurement Initiation (Process 9) 

constitutes the process in which the many types of 

information needed to procure an SSC are 

identified and assembled. These include an 

approved procurement specification, appropriate 

references to regulatory and other requirements, 

qualification requirements, and assurance that 

contractors and vendors have an adequate quality 

assurance program. 

Manufacturing (Process 10) constitutes the 

process in which the SSC is fabricated by the 

vendor. In this process, the information generated 

from the design process is used to produce and 

assemble the SSC. These include the required 

procedures and standards, the state and 

composition of the raw materials, and the methods 

and processes used to transform the raw materials 

into the finished SSC. 

Shipping, Storage, and Handling 

(Process 11) of SSCs may occur in the 

procurement, installation, and operation stages of 

an SSC's life cycle. The attributes of this process 

establish measures that assure proper 

identification, protective measures, and 

environments. This is done so that the SSCs will 

arrive at the installation and operation stages 

without damage and with identifiable components 

so that traceability can be maintained throughout 

the SSC's life cycle. 

Receipt Inspection (Process 12) is the process 

used in the Procurement Stage of a SSC life cycle 

to assure and document that the correct component 

specified and ordered from a manufacturer is 

received at a plant site in good condition. 

3.1.4 Installation Stage 

Installation (Process 13) constitutes the 

process in which the SSC is physically placed into

its operational position in the plant. This includes 

structural attachment for support, functional 

linkages to other SSCs, and electrical, hydraulic, 

or pneumatic connections for actuation and 

control. These include the required procedures and 

standards, and qualification of procedures and 

personnel. 

3.1.5 Operation Stage 

Monitoring (Process 14) constitutes the 

process in which SSC performance is periodically 

evaluated during plant operation. These include 

requirements to evaluate performance and 

component degradations, identify and correct 

nonconformances, and document root causes. 

Repair, Replacement, or Modification 

(Process 15) is the process used in the operation 

stage of the life cycle to correct problems with the 

SSC. Repair activities are performed on existing 

installed SSCs to correct problems. Replacement is 

a process of replacing-in-kind to correct problems. 

Modification is used to replace SSCs with a new 

type of updated or different SSC, For example, a 

valve shown to perform inadequately in service 

would be modified with a different type valve 

shown to provide more satisfactory service. 

Maintenance (Process 16) can be both a 

preventative and corrective process. Preventative 

maintenance processes are used to assure the 

functionality of SSCs. Corrective maintenance 

processes are used to repair and replace SSCs. 

Trending (Process 17) constitutes the process 

in which SSC performance data obtained from the 

monitoring process and component failure data are 

analyzed with respect to time. This analysis 

provides a basis for future retest frequencies and 

helps identify common-cause component 

problems. 

Corrective Actions (Process 18) is the 

program used in the Operation Stage of the life 

cycle to identify problems and the appropriate 

actions necessary to correct the problems. 

Corrective actions are monitored to ensure 

effectiveness.

6
3.1.6 Table 2 - Critical Process/Attribute 

Evaluation 

Appendix A, Table 2 provides a detailed 

listing of each of the 18 processes and their 

associated attributes that are affected by special 

treatment requirements. The table includes a 

reference to the associated special treatment rules, 

the determination of process and attribute 

criticality, and the basis for that determination. 

Most of the process' attributes were found to 

be critical to giving reasonable confidence of SSC 

functionality (see Table 2). However, for most of 

the critical attributes, reasonable confidence could 

be achieved with fewer requirements than stated in 

the special treatment rules. This was true more for 

the attributes giving assurance of functionality, 

such as documentation, than for those that directly 

demonstrate functionality, such as component 

testing. Many of these special treatment rules are 

from 10 CFR 50, Appendix B. While some sort of 

quality program is needed for reasonable 

confidence of SSC functionality, a full 10 CER 50, 

Appendix B program does not seem to be 

warranted for RISC-3 components. 

In a few cases, process attributes contributed 

only a minor increase in confidence of SSC 

functionality. An example of this is management 

reviews of quality activities. While management 

should be aware of quality issues, if the

engineering department has an effective corrective 

action program, this should give reasonable 

confidence of SSC functionality, and the 

management reviews would only add an 

incremental increase in confidence of 

functionality. 

In other cases, a process attribute was judged 

to be noncritical if there were alternate ways to 

satisfy the attribute. An example of this would be 

the design verification process. All of the methods 

cannot be critical since only one of them needs to 

be satisfied. In this case, only the method judged 

to be the lowest level of verification was selected 

as critical, the alternate methods were judged 

noncritical. 

One critical attribute that was assumed to be in 

place was the design specification. If the design 

specification states the functional, environmental, 

and load requirements correctly, then commercial 

practices would lead to a product selection that 

was manufactured according to the design require

ments. For example, if the design requirements 

state that a solenoid-operated valve (SOV) must 

function in a radiation environment, then a 

commercially available SOV with materials not 

designed for radiation environments would not be 

selected. If the existing general design require

ments were used (excluding the requirement that 

the replacement component be nuclear grade), then 

an SSC incapable of functioning properly in a 

nuclear environment would not be procured.

7
4. COMPONENT COMPARATIVE ANALYSIS

The data and information previously compiled 

were used to compare the nuclear processes, 

attributes, and special treatment requirements (i.e., 

applicable codes and standards) for a number of 

component types to those that could be used for 

commercial procurement, installation, 

maintenance, etc. The BOP and commercial codes 

and standards were identified from discussions 

with utilities, vendors, standard specifications, and 

the knowledge and experience of the authors. We 

selected the most applicable codes and standards 

for the individual components. Many of these 

codes and standards referenced other codes and 

standards and it was beyond the scope of this work 

to review all these referenced documents. 

Evaluations were performed to characterize 

any significant differences between the nuclear 

processes, attributes, and special treatment 

requirements (applicable codes and standards) and 

the corresponding BOP and commercial processes, 

attributes, and applicable codes and standards as 

they relate to providing reasonable confidence of 

the component's functionality. These evaluations 

were based on the following important points: 

The components addressed are listed in the 

plant's licensing basis as safety-related 

components and will remain so listed even 

if reclassified as "RISC-3" components. 

It is assumed that the design requirements of 

any components reclassified as "RISC-3" 

will not change. For example, the loads 

(e.g., pressure, thermal, seismic, etc.) and 

environmental requirements originally 

specified as applicable to any given 

component would still be applicable after 

reclassification. 

It was assumed that good engineering 

practice would continue to be applied for 

any components that could be acquired 

using commercial processes and codes and 

standards after classification to "RISC-3." 

Thus, the importance of a comprehensive 

engineering specification for each SSC 

would remain. For example, the

requirements included in the specification 

will be used to determine whether a "catalog 

item" is acceptable for a replacement 

component or whether a vendor's "nuclear 

grade" component must still be used. 

"* The evaluations performed for the 

components included in the subsections 

below were based on consideration of the 

processes that would apply to uses of both 

the special treatment rules and of BOP or 

commercial codes and standards. Thus, 

these evaluations do not represent product

to-product comparisons, such as a nuclear 

grade solenoid valve compared to a 

commercial solenoid valve. 

"* Likewise, the evaluation descriptions do not 

imply or represent a detailed line-by-line 

comparison of nuclear requirements to 

corresponding applicable commercial 

requirements. For example, it was observed 

that the quality assurance (QA) 

requirements of Section mI of the ASME 

Code are more comprehensive than those 

recommended in Section VIII. The 

evaluation conducted was sufficient to 

confirm that significant differences existed 

without performing a complete match-up 

comparison of each specific requirement. 

"* The objective of Task 4 is to identify 

differences that significantly affect 

reasonable confidence of functionality 

between processes required by special 

treatment rules and the requirements of 

component-specific commercial codes and 

standards. In some cases there may be 

differences in the special treatment rule and 

the corresponding commercial code 

requirement; however, in our expert opinion 

some of these differences would not 

significantly affect reasonable confidence of 

the functionality of the component. 

The evaluations contained in the following 

subsections briefly address the differences 

between commercial codes and standards and 

process attributes required by special treatment

8
rules. All components had at least a few 

differences that were judged to significantly affect 

reasonable confidence of functionality. However, 

most components had some processes where the 

identified differences did not significantly affect 

reasonable confidence of functionality. Examples 

of this were more frequently found in the design 

requirements, manufacturing, installation, and 

maintenance processes. These judgments did not 

ignore the fact that the special treatment rule 

requirements and the commercial standard 

requirements are not the same. These judgments 

simply indicate that the differences would not 

significantly affect reasonable confidence of the 

functionality of the component. As an example, 

consider the design requirements process for 

piping. The special treatment rule requirements 

(10 CFR 50.55a) involve Section III of the ASME 

Code whereas the commonly used commercial 

code is ASME B3 1.1. Examination of the piping 

rules contained in both standards show that there 

are differing requirements, for example, stress 

limits. Section Im has limits for four load levels, 

but since these are equal to or greater than the 

B31.1 stress limits, the B31.1 limits should give 

reasonable confidence of functionality. The 

Section Im Class I fatigue rules are also 

significantly different, but again it was concluded 

that the B3 1.1 rules would give reasonable 

confidence of functionality. 

It is recognized that corresponding nuclear 

products and commercial products may differ even 

though a process, such as design requirements, is 

judged to have no differences that significantly 

affect reasonable confidence of functionality when 

commercial standards are used. For example, if 

MIL-SPEC (military specification) MIL-S-4040E 

was followed for SOVs, a specification would be 

developed that identified all the applicable 

conditions of temperature, pressure, seismic 

vibration, etc. A SOV for commercial applications 

would not be specified to operate in conditions 

identical to nuclear applications. The commercial 

SOV would not be required to withstand radiation 

fields; other conditions, such as pressure, 

temperature, and seismic vibrations, may be less 

demanding than those present in a nuclear in

containment environment. Yet when applied to a 

nuclear SOV, the same standard would lead to a 

specification that identified radiation and the other

applicable environmental conditions (e.g., 

temperature, pressure, and seismic vibration, etc.). 

Consequently, the commercial valve will use some 

plastic parts where the nuclear valve uses metal 

parts. In addition, the nuclear valve's elastomers 

will be different because of the requirement to 

endure radiation exposure. Therefore, the two 

valves would be noticeably different even though 

they were designed using the same process, and 

the commercial valve may not be acceptable for 

the nuclear application. 

Analysis of the information contained in the 

following subsections indicate that for all of the 

components evaluated, significant differences 

between the special treatment rule requirements 

and the requirements contained in the component 

specific commercial codes and standards existed 

for most of the critical processes. For example, the 

component specific commercial codes and 

standards reviewed had few, if any, specific 

requirements governing such processes as QA, 

procedural control, and design verification. Similar 

observations were made for most of the other 

critical processes when applied to the components 

evaluated. This indicates that component specific 

commercial codes and standards alone do not 

provide the necessary processes to assure 

reasonable confidence of functionality. The 

evaluations contained in Table 2 also indicate that 

additional measures would be needed to reinforce 

the requirements of commercial codes and 

standards used in the procurement of RISC3 SSCs. 

The utility representatives we contacted stated 

that processes developed to implement nuclear 

codes, standards, and special treatment 

requirements are often selectively used (with 

reduced requirements where appropriate) for BOP 

SSCs to provide reasonable confidence of 

functionality. QA programs that provide 

classifications less rigorous than those required by 

the special treatment rules but with augmented 

requirements above commercial standards could 

be one approach to providing reasonable 

confidence of functionality. 

4.1 ISO 9001 

ISO 9001-94 is an international quality 

standard that is available for application to BOP

9
nuclear and commercial grade components. As 

with all such commercial standards, certification 

of a manufacturer's ISO 9001 program is strictly 

voluntary. Although ISO 9001 uses a different 

numbering system and somewhat different titles, 

the basic aspects of the quality program, such as 

Design Control, are similar to those quality 

program requirements included in 10 CFR 50, 

Appendix B. Comparison of the requirements of 

ISO 9001 versus those of 10 CFR 50, Appendix B 

will show many similarities, but differences also 

exist. For example, some regulatory requirements 

contained in Criterion m (Design Control) of 

10 CFR 50, Appendix B are not addressed at the 

same level of rigor and detail in ISO 9001. In 

some cases these differences may not be critical 

contributors to establishing or maintaining the 

functionality of low risk SSCs. 

As mentioned above, use of an ISO 9001 

Quality Assurance program is voluntary. Adoption 

and certification of ISO 9001 Quality Assurance 

programs have been increasing throughout the.. 

commercial sector, but it has also been observed 

that the implementation of these programs has 

been somewhat uneven and inconsistent. This is 

partly attributed to the variety of organizations 

performing the certification activities. 

4.2 Centrifugal Pumps 

4.2.1 Commercial Standard 

ASME B73-1M, ANSI/API 610, 

NFPA/T3.9.21, UBC, ASCE 7, and NEC. 

4.2.2 Special Treatment Requirements 

* 10 CFR 50.55a (ASME I1I, XI, in-service 

testing [IST], OM) 

0 10 CFR 50, GDC 45 and 46, and 

Appendix B 

* 10 CFR 100, Appendix A 

4.2.3 Centrifugal Pump Synopsis 

Guidance from the chemical, petroleum, or 

fire protection codes could be used as commercial 

pump standards. If the design specification states

the functional, environmental, and load 

requirements, the commercial codes give adequate 

general directions on how to manufacture and test 

a pump. For example, ASME B72- I M and 

Performance Test Code (PTC) 7.1 give 

instructions on functional testing. Commercial 

seismic requirements are covered by standards 

such as the UBC and ASCE 7 that specify seismic 

requirements different than nuclear codes, but 

nevertheless give reasonable confidence of 

functionality. Quality and equipment qualification 

requirements are not thoroughly addressed in 

commercial codes, although ISO 9001 would 

cover quality requirements if specified. A few 

documentation requirements are given in ASME 

B73-1M. It is expected that the pump instruction 

manual would cover installation and in-service 

testing. 

4.2.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: There is no universally used 

commercial standard requiring documentation. 

ASME B73-IM requires documents including 

drawings, performance curves, and an instruction 

manual. 

Ouality Assurance: There is no universally 

used commercial standard requiring a quality 

assurance program. 

Procedures: There is no universally used 

commercial standard requiring the use of 

procedures. 

Testing, Inspection, and Examination: 

ASME B73-IM requires a shop hydro test of 

casings, coverings, and jackets at 1.5 times the 

design pressure. Performance tests are required to 

be conducted in accordance with HI 1.6, "Testing 

for Centrifugal Pumps" of the Hydraulic Institute 

Standards. Commercial standards cover functional 

testing of pumps. No in-service inspection (ISI), 

such as for welds, is required. 

Design Requirements: A design specification 

will exist for each SSC that should include all 

design requirements. No significant differences

10
that would affect the reasonable confidence of 

component functionality were identified. 

Analysis: The seismic analysis methods in 

commercial standards are equivalent static 

methods. 

Design Verification: There is no universally 

used commercial standard requiring design 

verification. 

Design Control: There is no universally used 

commercial standard requiring design control. 

Procurement: There is no universally used 

procurement standard. 

Manufacturing: No significant differences 

that would effect the reasonable confidence of 

component functionality were identified. 

Shipning, Storage. and Handlin : There is 

no universally used commercial standard requiring 

shipping, storage, and handling. 

Receipt Inspection: There is no universally 

used commercial standard requiring receipt 

inspection. 

Installation: Installation instructions are 

included in the manufacturer's instruction manual. 

Monitoring: There is no universally used 

commercial standard requiring monitoring. 

Repair. Replacement, or Modification: 

There is no universally used commercial standard 

requiring repair, replacement, or modification. 

Maintenance: There is no universally used 

commercial standard requiring maintenance. 

Trending: There is no universally used 

commercial standard requiring trending. 

Corrective Action: There is no universally 

used commercial standard requiring corrective 

action.

4.3 Positive Displacement 

Pumps 

4.3.1 Commercial Standard 

ANSI/(NFPA) T3.9.17 R2-1997; 

ANSI(NFPA) B93.95M; API Standards 674, 675, 

and 676; ASME PTC 7.1; UBC; ASCE 7; and 

NEC. 

4.3.2 Special Treatment Requirements 

* 10 CFR 50.55a (ASME III, XI, IST, OM) 

* 10 CFR 50, GDC 45 and 46, Appendix B 

* 10 CFR 100, Appendix A 

4.3.3 Positive Displacement Pump 

Synopsis 

Guidance from the chemical, petroleum, or 

fire protection codes could be used as commercial 

pump standards. If the design specification states 

the functional, environmental, and load 

requirements, the commercial codes give adequate 

general directions on how to manufacture and test 

a pump. For example, ASME B72-IM and 

PTC 7.1 give instructions on functional testing. 

Commercial seismic requirements are covered by 

standards such as the UBC and ASCE 7 that 

specify seismic requirements different from 

nuclear codes, but give reasonable confidence of 

functionality. Quality and equipment qualification 

requirements are not thoroughly addressed in 

commercial codes, although ISO 9001 would 

cover quality requirements if specified. It is 

expected that the pump instruction manual would 

cover installation and in-service testing. 

4.3.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: There is no universally used 

commercial standard requiring documentation. 

Ouality Assurance: There is no universally 

used commercial standard requiring a Quality 

Assurance Program.

11
Procedures: There is no universally used 

commercial standard requiring the use of 

procedures. 

Testing, Inspection, and Examination: 

Commercial standards cover functional testing of 

pumps. No ISI, such as for welds, is required. 

Design Requirements: A design specification 

will exist for each SSC that should include all 

design requirements. No significant differences 

that would affect the reasonable confidence of 

component functionality were identified. 

Analysis: The seismic analysis methods in 

commercial standards are equivalent static 

methods. 

Design Verification: There is no universally 

used commercial standard requiring design 

verification. 

Design Control: There is no universally used 

commercial standard requiring design control. 

Procurement: There is no universally used 

commercial procurement standard. 

Manufacturing: No significant differences 

that would affect the reasonable confidence of 

component functionality were identified. 

Shipping, Storage, and Handling: There is 

no universally used commercial standard requiring 

shipping, storage, and handling. 

Receipt Inspection: There is no universally 

used commercial standard requiring receipt 

inspection. 

Installation: No significant differences that 

would affect the reasonable confidence of 

component functionality were identified. 

Monitoring: There is no universally used 

commercial standard requiring monitoring. 

Repair, Replacement, or Modification: 

There is no universally used commercial standard 

requiring repair, replacement, or modification.

Maintenance: There is no universally used 

commercial standard requiring maintenance. 

Trending: There is no universally used 

commercial standard requiring trending. 

Corrective Action: There is no universally 

used commercial standard requiring corrective 

action. 

4.4 Valves 

4.4.1 Commercial Standard 

American Society of Mechanical Engineers, 1996, Valves - Flanged Threaded and Welding 

End, ASME B 16.34. 

4.4.2 Special Treatment Requirements 

* 10 CFR 50.55a (ASME III, IST, OM, 

Generic Letters (GLs) 89-10, and 96-05) 

0 10 CFR 50, GDC-45 and 46 and 

Appendix B 

* 10 CFR 100, Appendix A 

4.4.3 Related Nuclear Guidance 

ASME Qualification of Active Mechanical 

Equipment Used in Nuclear Power Plants 

(QME-1). 

4.4.4 Valve Synopsis 

Valves are subject to pressure boundary 

requirements of ASME Sections III and XI, in

service testing requirements, quality assurance 

requirements, seismic requirements, and GDC 45 

and 46. When special treatment requirements are 

compared to commercial codes and standards 

(ASME B 16.34) there are significant differences 

in all processes except design requirements and 

manufacturing. ASME B 16.34 does include 

specific pressure test requirements to ensure that 

the pressure boundary integrity is not violated and 

also contains specific manufacturing requirements. 

Even though ASME B 16.34 addresses design and 

manufacturing issues, several special treatment 

requirements are not addressed, and therefore,

12
ASME B 16.34 is not adequate to provide 

reasonable confidence of valve functionality. 

However, other industry quality assurance 

programs and other plant processes may be used to 

provide reasonable confidence of functionality. 

4.4.5 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: ASME B 16.34 does not 

include any requirements that address the 

documentation required for construction of 

commercial valves. 

Ouality Assurance: Annex H of ASME 

B 16.34 specifies that products manufactured using 

this standard be produced using a Quality 

Assurance program that follows the principles of 

ISO 9001. However, Annex H is nonmandatory 

and is provided for information purposes only. 

Procedures: ASME B 16.34 includes 

procedures for radiography (Annex B), magnetic 

particle examination (Annex C), liquid penetran~t 

examination (Annex D), and ultrasonic 

examination (Annex E). These examination 

procedures typically include acceptance criteria. 

However, they do not address other 10 CFR 50, 

Appendix B concerns, such as requiring 

procedural control (other examination standards 

are referenced), ensuring that prerequisites are 

met, or including quality hold points. Procedural 

requirements for valve manufacture are not 

specified. 

Testing. Inspection, and Examination: 

ASME B 16.34 specifies the test requirements for 

surface examinations and shell pressure tests. 

Welds must receive nondestructive examination in 

accordance with the ASME Boiler and Pressure 

Vessel Code, Section VIII, Division I. For valves 

designed to isolate flow, a closure (seat-leakage) 

test is required. However, the valve is not stroked 

under worst-case pressure and flow conditions. No 

in-service testing (IST) is required. ASME B 16.34 

states that the need for periodic inspections is the 

responsibility of the user. 

Desian Requirements: No significant 

differences that would affect the reasonable

confidence of component functionality were 

identified. ASME B 16.34 does include specific 

pressure test requirements to ensure that the 

pressure boundary integrity is not violated. 

Analysis: ASME B 16.34 does not include any 

personnel qualification or checking requirements 

related to the construction of commercial valves. 

Design Verification: ASME B 16.34 does not 

include any requirements that addresses design 

verification during the construction of commercial 

valves. 

Design Control: ASME B 16.34 does not 

include any requirements that addresses design 

control during the construction of commercial 

valves. 

Procurement: ASME B 16.34 requires that 

valve body and bonnet components be constructed 

of materials in accordance with American Society 

of Testing and Materials (ASTM) specifications or 

ASME Boiler and Pressure Vessel Code section IL 

The criteria for selection of materials are not 

considered to be in the scope of ASME B 16.34. 

Manufacturing: No significant differences 

that would affect the reasonable confidence of 

component functionality were identified. 

ASME B 16.34 includes many requirements 

controlling the materials and manufacturing 

process. 

Shipping,. Storage, and Handling: ASME 

B 16.34 does not include any requirements that 

address the shipping, storage, and handling of 

commercial valves. 

Receipt Inspection: ASME B 16.34 does not 

include any requirements that address the receipt 

inspection of commercial valves. 

Installation: ASME B 16.34 does not include 

any requirements that address the installation of 

commercial valves. 

Monitoring: ASME B 16.34 does not include 

any requirements that address the monitoring of 

commercial valve performance once installed in 

the plant.

13
Repair, Replacement, or Modification: 

ASME B 16.34 does not include any requirements 

that address the repair, replacement, or 

modification of commercial valves. 

Maintenance: ASME B 16.34 does not 

include any requirements that address the 

maintenance of commercial valves. 

Trending: ASME B 16.34 does not include 

any requirements that address the performance 

trending of commercial valves. 

Corrective Action: ASME B 16.34 does not 

include any requirements to implement a 

corrective action program for commercial valves. 

4.5 Valve Operators 

4.5.1 Commercial Standard 

Valve specifications were reviewed and 

discussions were held with valve and actuator 

manufacturers to identify commercial codes or 

standards that apply to valve operators. Based on 

these efforts, no commercial codes or standards 

were identified. Valve operators do not form a part 

of the system pressure boundary (ASME B31.1) 

and are not addressed by ASME B 16.34. 

Therefore, no comparison was performed for valve 

operators. 

4.5.2 Special Treatment Requirements 

S 10 CFR 50.49 

0 10 CFR 50.55a (ASME mI, IST, OM, GL 

89-10, GL 96-05) 

* 10 CFR 50, GDC 45 and 46, and 

Appendix B 

0 10 CFR 100, Appendix A 

4.5.3 Valve Operator Synopsis 

Valve operators are subject to pressure 

boundary requirements of ASME Sections III and 

XI, In-service Testing requirements, Quality 

Assurance requirements, seismic requirements, 

environmental qualification requirements, and

GDC 45 and 46. No commercial codes or 

standards were identified. However, it should be 

noted that valve actuator manufacturers, such as 

Limitorque, typically provide specific actuator 

sizing and setting guidelines in their technical 

manuals. 

4.5.4 Commercial Standards 

Comparison with Nuclear 

Processes 

As noted above, no comparison is possible due 

to the apparent lack of commercial codes or 

standards. 

4.6 Solenoid Operated Valves 

4.6.1 Commercial Standard 

MIL-SPEC MIL-S-4040E addressed 

specification and design/production testing of 

electrical solenoids used to actuate various 

devices. The standard requires that a specification 

be supplied by the user as a part of the 

procurement process. The valve portion of a 

solenoid valve is addressed in Section 4.4, Valves. 

4.6.2 Special Treatment Requirements 

* 10 CFR 50.49, Environmental Qualification 

S 10 CFR 50, GDC 1, 2,4, and I0, and 

Appendix B 

0 10 CFR 100, Appendix A 

4.6.3 Solenoid Valve Synopsis 

Solenoid operated valves are typically located 

in areas that are subject to accident conditions and, 

therefore, must meet EQ requirements as well as 

the requirements of GDC 2, GDC 4, and QA. 

When special treatment requirements are 

compared to commercial codes and standards there 

are significant differences in all processes except 

design requirements and design verification. The 

commercial standard reviewed ( MIL-SPEC MIL

S-4040E) requires specifying and verifying all the 

conditions that would be required at a nuclear 

power plant, except for radiation. While radiation 

is not included in the things to be considered, the

14
thoroughness of the standard and the assumed 

existence of a specification will assure that 

radiation will be considered when it is an 

environmental condition for the solenoid. 

4.6.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: Other government documents 

are referenced. However, documentation, 

including the control of documentation that is 

required of the manufacturer and subsequently 

during installation and operation is not addressed. 

Quality Assurance: The reviewed standards do 

not address quality assurance programs. Quality 

assurance is addressed with regard to testing and 

inspections. 

Procedures: The standard does not address 

requirements for procedures. 

Testing, Inspection, and Examination: The 

MIL-SPEC requires inspections and testing to 

assure that the solenoids will perform as required. 

The testing considerations include verifying 

electrical and mechanical characteristics under 

conditions of temperature, sprays, shock, 

vibrations, acceleration, thermal shock, sand and 

dust, and explosions. Visual and mechanical 

inspections are also required. Testing during post 

installation and during the operational phase is not 

addressed. 

Design Requirements: The standard requires 

specifying nearly all the conditions that would be 

required at a nuclear power plant. While radiation 

is not included in the things to be considered, the 

thoroughness of the standard and the assumed 

existence of a specification will assure that 

radiation will be considered when it is an 

environmental condition for the solenoid. 

Analysis: The reviewed standards do not 

address the analysis process. 

Design Verification: Design verification for 

all specified conditions is addressed. While 

radiation is not included in the things to be 

considered, the thoroughness of the standard and

the assumed existence of a specification will 

assure that radiation will be considered when it is 

an environmental condition for the solenoid. 

Design Control: The reviewed standards do 

not address design control attributes. 

Procurement: The standards could lead to 

development of procurement specifications. 

However, other procurement attributes, such as 

control of vendors and approval of procurement 

documents are not addressed. 

Manufacturing: Except for determining how 

many sample are to be tested and the production 

testing, the manufacturing process is not 

addressed. 

Shipping. Storage, and Handling: Shipping, 

storage, and handling is not addressed. 

Receipt: Receipt is not addressed by the 

standard. 

Installation: The standard does not address 

the process of installation. 

Monitoring: The reviewed standard does not 

address the monitoring process. 

Repair. Replacement, or Modification: The 

reviewed standards do not address repair, 

replacement, or modification. 

Maintenance: Maintenance of solenoids is 

not addressed. 

Trending: The standard does not address the 

trending process. 

Corrective Action: Corrective actions are not 

addressed. 

4.7 Piping 

4.7.1 Commercial Standard 

ASME/ANSI B3 1.1

15
4.7.2 Special Treatment Requirements 

* 10 CFR 50.55a (ASME ITI, ISI) 

* 10 CFR 50, Appendix B 

* 10 CFR 100, Appendix A 

4.7.3 Piping Synopsis 

Piping systems and components serve as the 

pressure boundary for the systems needed to 

transport fluids throughout power plants. The 

design requirements for an individual piping 

system are generally governed by the intended 

service (primary coolant system, component 

cooling water, etc.), magnitude of the loads 

imposed, the types of loads expected (thermal 

expansion, seismic, etc.), the environments 

imposed by the routing and location of the system, and other application specific parameters. The 

design requirement differences between the special 

treatment rules applicable to piping and the rules 

contained in commercially available standards do 

not result in a significant reduction of confidence 

in the assurance of piping system functionality. As 

an example, ASME Section UTl does include more 

stringent requirements; however, higher stress 

limits are allowed. Whereas B31.1 has less 

stringent requirements; but the allowable stresses 

are more conservative. On balance, well-designed 

piping systems are routinely designed using both 

approaches. Likewise, the differences in the 

special treatment rules and commercial standards 

addressing the manufacturing operations for piping 

systems and the operations needed to install them 

do not result in a significant reduction of 

confidence in the assurance of piping system 

functionality. However, as detailed in the 

subsections below, significant differences between 

the special treatment rule requirements and the 

available commercial standards do exist in the 

other critical processes. 

4.7.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: There is no universally used 

commercial standard requiring documentation.

Ouality Assurance: There is no universally 

used commercial standard requiring a quality 

assurance program. 

Procedures: B3 1.1 only requires welding 

procedures. 

Testin2, Inspection, and Examination: 

B3 1.1 has manufacturing and installation testing, 

inspection, and examination for welds. No ISI is 

required. 

Design Requirements: No significant 

differences that would affect the reasonable 

confidence of component functionality were 

identified. 

Analysis: B31.1 has no personnel 

qualification or checking requirements. 

Design Verification: There is no universally 

used commercial standard requiring design 

verification. 

Design Control: There is no universally used 

commercial standard requiring design control. 

Procurement: B31.1 requires specified 

material and manufacturing methods. 

Manufacturing: No significant differences 

that would affect the reasonable confidence of 

component functionality were identified. 

Shipping, Storage. and Handling: There is 

no universally used commercial standard requiring 

shipping, storage, and handling. 

Receipt Inspection: There is no universally 

used commercial standard requiring receipt 

inspection. 

Installation: No significant differences that 

would affect the reasonable confidence of 

component functionality were identified. 

Monitorin : There is no universally used 

commercial standard requiring monitoring.

16
Repair. Replacement, or Modification: 

There is no universally used commercial standard 

requiring repair, replacement, or modification. 

Maintenance: There is no universally used 

commercial standard requiring maintenance. 

Trending: There is no universally used 

commercial standard requiring trending. 

Corrective Action: There is no universally 

used commercial standard requiring corrective 

action. 

4.8 Pressure Vessels 

4.8.1 Commercial Standard 

ASME Section VIII. 

4.8.2 Special Treatment Requirements 

* 10 CFR 50.55a (ASME Section III) 

* 10 CFR 50, GDC I and 2, and 

Appendices B and S. 

4.8.3 Pressure Vessel Synopsis 

The design requirements for an individual 

pressure vessel are generally governed by the 

intended service, such as magnitude of the loads 

imposed, the types of loads expected, such as 

pressure, temperature, seismic, etc., and other 

application specific parameters. The design 

requirements differences between the special 

treatment rules applicable to pressure vessels and 

the rules contained in commercially available 

standards do not result in a significant reduction of 

confidence in the assurance of vessel functionality. 

For example, ASME Section mI does include more 

stringent requirements, but higher stress limits are 

allowed. Whereas Section VIII has less stringent 

requirements, but the allowable stresses are more 

conservative. On balance, well designed vessels 

are routinely designed using both approaches. In 

fact, the reactor pressure vessels used in several of 

the early nuclear power plants were designed using 

the Section VIII rules. Likewise, the differences in 

the special treatment rules and commercial 

standards addressing the manufacturing operations

for piping systems and the operations needed to 

install them do not result in a significant reduction 

of confidence in the assurance of vessel 

functionality. However, as detailed in the 

subsections below, significant differences between 

the special treatment rule requirements and the 

available commercial standards do exist in the 

other critical processes. 

4.8.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: ASME Sec VIII does require 

a quality assurance program; however, the level of 

documentation required is generally much less 

than that required by ASME Section m and that 

required under 10 CFR 50, Appendix B. 

Ouality Assurance: ASME Section Vyi, 

Appendix 10 requires a quality assurance program. 

However, the program requirements do not match 

those contained in 10 CFR 50, Appendix B; for 

example, testing is not addressed. 

Procedures: ASME Section VIII, Appendix 

10 requires a quality assurance program that 

includes provisions for procedures that will ensure 

that the latest versions of drawings, design 

calculations, and specifications are available. 

However, 10 CFR 50, Appendix B includes much 

more detailed requirements regarding the contents 

of written procedures and the appropriate approval 

process for procedures. 

Testing. Inspection, and Examination: The 

testing, inspection, and examination requirements 

contained in Section VIII do not address items 

such as personnel qualification, continued training 

and certification, etc. in comparable detail to 

10 CFR 50, Appendix B. 

Design Requirements: No significant 

differences that would affect the reasonable 

confidence of component functionality were 

identified. 

Analysis: Section VIII has no personnel 

qualification or checking requirements.

17
Design Verification: Section VIII has no 

universally design verification requirements. 

Design Control: ASME Section VIII, 

Appendix 10 requires a quality assurance program 

that includes provisions for procedures that will 

ensure that the latest versions of drawings, design 

calculations, and specifications are available. 

10 CFR 50, Appendix B includes much more 

detailed requirements on design control (e.g., 

design interfaces and coordination, design change 

control, etc.). 

Procurement: 10 CFR 50, Appendix B 

requires that vendors provide components under a 

10 CFR 50, Appendix B quality assurance 

program. Section VIII of the ASME Code does not 

have similarly stringent requirements. If ISO 9001 

is used, then the topics in the special treatment rule 

roughly have corresponding ISO 9001 attributes. 

Manufacturing: No significant differences 

that would affect the reasonable confidence of 

component functionality were identified. 

Shipping. Storage, and Handling: Section 

VIII of the ASME Code does not include as 

rigorous requirements on shipping, storage, and 

handling, such as measures to prevent use of 

incorrect parts or components, as those found in 

10 CFR 50, Appendix B. 

Receipt Inspection: The guidelines contained 

in Section VmII are not comparable to the level of 

detail contained in 10 CFR 50, Appendix B. These 

differences are mainly in the areas of the level or 

record keeping required. 

Installation: No significant differences that 

would affect the reasonable confidence of 

component functionality were identified. 

Monitoring: Section VIII of the ASME Code 

contains no guidance on this topic that is 

comparable to the requirements of 10 CFR 50, 

Appendix B. 

Repair, Replacement, or Modification: 

Section VIm of the ASME Code contains some 

guidance on the repair of material defects; 

however, these requirements are not comparable to

the level of detail contained in 10 CFR 50, 

Appendix B. 

Maintenance: Section VII of the ASME 

Code contains no guidance on this topic 

comparable to that included in 10 CFR 50, 

Appendix B. 

Trending: Section VIII of the ASME Code 

contains no guidance on this topic comparable to 

that included in 10 CFR 50, Appendix B. 

Corrective Action: Section VIII of the ASME 

Code contains no guidance on this topic 

comparable to that included in 10 CFR 50, 

Appendix B. 

4.9 Containment Penetrations 

4.9.1 Commercial Standard 

ASME Section VII was reviewed and no 

electrical commercial penetration standard could 

be found. Section VIII requirements for nozzles 

and nozzle reinforcements are somewhat related to 

containment penetrations, but there are many 

differences. 

4.9.2 Special Treatment Requirements 

a 10 CFR 50.55a (ASME Section II and 

Section XI) 

* 10 CFR 50, GDC 1, 2, and 4, and 

Appendices B and S. 

4.9.3 Containment Penetration 

Synopsis 

Containment penetrations are subject to 

pressure boundary requirements of ASME Code 

Sections IH and XI, QA requirements, GDC 1, 

GDC 2, and GDC 4. Containment penetrations 

provide for integrity of the containment structure 

for both mechanical and electrical penetration. No 

directly applicable commercial standard was found 

for the mechanical and electrical penetrations. 

Section VIII was reviewed because nozzles and 

nozzle reinforcements are somewhat similar to a 

mechanical penetration. There were significant 

differences in all of the critical processes for the

18
containment penetrations. The commercial 

standard is not adequate to provide reasonable 

confidence of functionality. However, alternate 

QA programs and other plant processes could be 

used to provide reasonable confidence of 

functionality. 

4.9.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: ASME Section VIII does 

require a quality assurance program; however, the 

level of documentation required is generally much 

less than that required by ASME Section III and 

that are required under a 10 CFR 50, Appendix B 

quality assurance program. 

Ouality Assurance: ASME Section VIII, 

Appendix 10 requires a quality assurance program. 

However, the program requirements do not match 

those contained in 10 CFR 50, Appendix B; for 

example, testing is not addressed. 

Procedures: ASME Section VIII, Appendix 

10 requires a quality assurance program that 

includes provisions for procedures that will ensure 

that the latest versions of drawings, design 

calculations, and specifications are available. 

However, 10 CFR 50, Appendix B includes much 

more detailed requirements regarding the contents 

of written procedures and the appropriate approval 

process for procedures. 

Testing. Inspection, and Examination: The 

testing, inspection, and examination requirements 

contained in Section VIII do not address items 

such as personnel qualification, continued training 

and certification, etc., in comparable detail to 

10 CFR 50, Appendix B. 

Design Reguirements: Nozzles and 

reinforcements on pressure vessels are similar to 

containment penetrations, but there appear to be 

too many differences to conclude that design 

requirements are similar. 

Analysis: Section VIII has no personnel 

qualification or checking requirements.

Design Verification: Section vm has no 

universal design verification requirements. 

Design Control: ASME Section VIII, 

Appendix 10 requires a quality assurance program 

that includes provisions for procedures that will 

ensure that the latest versions of drawings, design 

calculations, and specifications are available. 

10 CFR 50, Appendix B includes much more 

detailed requirements on design control, such as 

design interfaces and coordination, design change 

control, etc. 

Procurement: 10 CFR 50, Appendix B 

requires that vendors provide components under 

an Appendix B Quality Assurance program. 

Section VIII of the ASME Code does not have 

similarly stringent requirements. 

Manufacturing: Manufacturing requirements 

of Section VIII are roughly similar to the 

containment penetration requirements, but there 

are differences. 

Shipping, Storage. and Handlin : Section 

VIII of the ASME Code does not include as 

rigorous requirements on shipping, storage, and 

handling, such as measures to prevent use of 

incorrect parts or components, as those found in 

10 CFR 50, Appendix B. 

Receipt Inspection: The guidelines contained 

in Section VIII are not comparable to the level of 

detail contained in 10 CFR 50, Appendix B. These 

differences are mainly in the areas of the level or 

record keeping required. 

Installation: There are numerous differences 

in Section VIII and the containment installation 

process. 

Monitoring: Section VIII of the ASME Code 

contains no guidance on this topic that is 

comparable to the requirements of 10 CFR 50, 

Appendix B. 

Repair, Replacement, or Modification: 

Section VIII of the ASME Code contains some 

guidance on the repair of material defects; 

however, these requirements are not comparable to

19
the level of detail contained in 10 CFR 50, 

Appendix B. 

Maintenance: Section VIII of the ASME 

Code contains no guidance on this topic 

comparable to that included in 10 CFR 50, 

Appendix B. 

Trending: Section VIII of the ASME Code 

contains no guidance on this topic comparable to 

that included in 10 CFR 50, Appendix B. 

Corrective Action: Section VIII of the ASME 

Code contains no guidance on this topic 

comparable to that included in 10 CFR 50, 

Appendix B. 

4.10 Tanks 

4.10.1 Commercial Standard 

ANSI/AWWA D 100-96 (Welded Steel Tanks 

for Water Storage). 

4.10.2 Special Treatment Requirements 

1 0 CFR 50, GDC I and 2, and 

Appendices B and S 

4.10.3 Tanks Synopsis 

The design requirements for an individual tank 

are generally governed by the intended service, 

such as water storage; magnitude of the loads 

imposed; the types of loads expected, such as 

pressure, temperature, seismic, etc.; and other 

application specific parameters. The design 

requirements differences between the special 

treatment rules applicable to tanks and the rules 

contained in commercially available standards do 

not result in a significant reduction of confidence 

in the assurance of tank functionality. Likewise, 

the differences in the special treatment rules and 

commercial standards addressing the 

manufacturing operations tanks and the operations 

needed to install them do not result in a significant 

reduction of confidence in the assurance of vessel 

functionality. However, as detailed in the 

subsections below, significant differences between 

the special treatment rule requirements and the

available commercial standards do exist in the 

other critical processes. 

4.10.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: ANSI/AWWA D 100-96 

includes requirements for the documentation of 

welder qualification and weld inspections. In 

addition, the recommendation is made that tank 

drawings certified by a registered professional 

engineer be provided to the purchaser. Other than 

the limited areas cited, ANSJ/AWWA D 100-96 

has no specific documentation requirements. 

Oualitv Assurance: ANSI/AWWA D100-96 

does not include requirements for a quality 

assurance program. 

Procedures: ANSI/AWWA DIOO-96 includes 

the requirement for the qualification of welding 

procedures. Other than the limited area cited, 

ANSJIAWWA DIOO-96 has no specific procedural 

control requirements. 

Testing, Inspection. and Examination: 

ANSI/AWWA D 100-96 addresses testing, 

inspection, and examination only from the 

perspective of shop and field inspection of welds. 

Design Requirements: No significant 

differences that would affect the reasonable 

confidence of component functionality were 

identified. 

Analysis: ANSI/AWWA D100-96 has no 

requirements for personnel qualification, analysis 

checking, or functionality assurance. 

Design Verification: ANSI/AWWA DIOO-96 

has no requirements for design verification. 

Design Control: ANSI/AWWA D 100-96 has 

no requirements for design control. 

Procurement: ANSIIAWWA DIOO-96 

includes recommendations on items that should be 

included in the purchasing specification; however, 

these are not requirements. No requirements for

20
vendor quality assurance programs, vendor 

qualification, etc., are included. 

Manufacturing: No significant differences 

that would affect the reasonable confidence of 

component functionality were identified. 

Shipping, Storage, and Handling: 

ANSI/AWWA D100-96 does not address the 

shipping, storage, and handling of tanks, tank 

sections, or components. 

Receipt Inspection: ANSIIAWWA D100-96 

does not address this topic. 

Installation: No significant differences that 

would affect the reasonable confidence of 

component functionality were identified. 

Monitoring: ANSI/AWWA D100-96 does not 

address this topic. 

Repair, Replacement, or Modification: 

Except for the repair of defective welds, 

ANSI/AWWA D100-96 does not address this 

topic. 

Maintenance: ANSI/AWWA D100-96 does 

not address this topic. 

Trending: ANSI/AWWA D100-96 does not 

address this topic. 

Corrective Action: ANSI/AWWA D100-96 

does not address this topic. 

4.11 Heat Exchangers 

4.11.1 Commercial Standard 

Standards of the Tubular Exchanger 

Manufacturers Association (TEMA), Seventh 

Edition, 1988. The vessel or pressure boundary 

components can be, if specified, manufactured and 

stamped to ASME Code Section VIII. This 

evaluation addresses only the TEMA standard. 

The TEMA provides design information, 

guidelines, brief shipping information, and 

recommended good practices for heat exchangers.

4.11.2 Special Treatment Requirements 

* 10 CFR 50.55a (ASME MI) 

* 10 CFR 50, GDC 1, 2, 45, and 46, and 

Appendix B 

* 10 CFR 100, Appendix A 

The TEMA standard does not address quality 

assurance. If so specified, the vessel can be built to 

Section VIII and stamped, but there are no in

service inspection requirements. The standard 

suggests considering all loading, including seismic 

loads. Equipment qualification would not be 

applicable for this mechanical component. 

4.11.3 Heat Exchanger Synopsis 

Heat exchangers are subject to pressure 

boundary requirements of ASME Code Sections 

III and XI, QA requirements, GDC 1, 2, 4, 45, and 

46. The commercial standards of the TEMA, 

Seventh Edition, 1988, was reviewed. Commercial 

heat exchangers can be ordered to ASME Code 

Section VIII if required by an equipment 

specification. The TEMA standard addressed 

design requirements, analysis, and maintenance. 

These processes must be required by a component 

specification and implemented by plant 

procedures. Quality assurance and the other 

critical processes were not addressed by the 

standard. However, alternate QA programs and 

other plant processes could be used to provide 

reasonable confidence of functionality. 

4.11.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: The TEMA standard only 

addresses drawings and requires the manufacture 

to furnish copies of the ASME Manufacture's Data 

Report for stamped exchangers. 

Oualitv Assurance: The TEMA standard 

requires no program. 

Procedures: The TEMA standard does not 

address the detailed shop operations and leaves 

this to the discretion of the manufacturer.

21
Testing, Inspection, and Examination: 

There are no specific requirements for inspection 

or testing. The purchaser should specify the 

inspection, testing, or examination that should be 

accomplished on the heat exchanged. 

Design Requirements: The TEMA standard 

does have detailed design requirements and 

recommendations. 

Analysis: The TEMA standard provides 

detailed analysis recommendations. 

Design Verification: The TEMA standard 

does not address verification. 

Design Control: The TEMA standard does 

not address design control. 

Procurement: A specification sheet example 

is provided as a recommendation, but little detail is 

provided on how to complete the specification 

sheet. 

Manufacturing: Inspections points, personnel 

qualification, permitted materials, welding and 

joining are not discussed, but would be covered by 

ASME Code Section VmI for a stamped vessel. 

Shipping, Storage, and Handling: 

Preparation for shipping of heat exchangers is 

covered briefly, but the TEMA standard does not 

cover many of the attributes. 

Receipt: The TEMA standard does not cover 

receipt of heat exchangers. 

Installation: Clearances, foundations, bolting, 

and leveling are discussed, but not all attributes are 

addressed by the TEMA standard. 

Monitoring: The TEMA standard does not 

address monitoring. 

Repair, Replacement, or Modification: The 

TEMA standard does not address repair and 

replacement or modification. 

Maintenance: An extensive section on 

maintenance is included in the TEMA standard.

Trending: The standard does not address 

trending. 

Corrective Action: This area is not addressed 

by the standard. 

4.12 Pipe Supports 

4.12.1 Commercial Standard 

ASME B31.1, MSS SP-58, AISC Manual of 

Steel Construction, and MSS SP-89. 

4.12.2 Special Treatment Requirements 

0 10 CFR 50.55a (ASME Section III, 

Subsection NF) 

* 10 CFR 50, Appendix B 

a 10 CFR 100, Appendix A 

4.12.3 Pipe Support Synopsis 

Piping supports are generally constructed of 

standard components such as spring hangers with 

associated standard clamps and fittings, which are 

fabricated from structural steel members or a 

combination of standard components and 

structural steel members such as a snubber 

attached to a structural steel column anchored to 

the floor. The design requirements for an 

individual support are generally governed by the 

magnitude of the loads imposed, the types of loads 

expected, such as thermal expansion, seismic, etc., 

the location of the support, and other application 

specific parameters. The differences in design 

requirements between the special treatment rules 

applicable to pipe supports and the rules contained 

in commercially available standards do not result 

in a significant reduction of confidence in the 

assurance of pipe support functionality. Likewise, 

the differences in the special treatment rules and 

commercial standards addressing the 

manufacturing operations to fabricate the support 

and the operations needed to install the support do 

not result in a significant reduction of confidence 

in the assurance of pipe support functionality. 

However, as detailed in the subsections below, 

significant differences between the special 

treatment rule requirements and the available

2?
commercial standards do exist in the other critical 

processes. 

4.12.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: There is no universally used 

commercial standard requiring documentation. In 

fact, documentation is not specifically required by 

B31.1 except in the area of weld records. 

Similarly, the AISC Steel Manual and MSS 

Standard Practices (SPs) do not specifically 

require documentation. 

Ouality Assurance: There is no universally 

used commercial standard requiring a quality 

assurance program. B31.1 does not specifically 

require a quality assurance program, and AISC 

does offer a Quality Certification designation. 

However, this is voluntary. MSS SP-89 

recommends that quality control should be 

exercised over the procurement of raw materials, 

fabrication procedures, and dimensions, but these 

are not requirements. 

Procedures: Except for welding, B31.1 does 

not require use of written procedures. The other 

commercial standards are similar in this regard. 

Testing. Inspection, and Examination: MSS 

SP 58 places any requirements for testing, 

inspection, and examination on the purchaser of 

the component. The AISC Code of Standard 

Practice contains no specific testing, inspection, or 

examination requirements. Under AISC, any such 

requirements would have to be specifically stated 

in the owner's specifications. MSS SP-89 does 

include recommendations for three categories of 

tests (design proof tests, qualification tests, and 

calibration tests) for pipe hanger components. 

However, it is not stated that these are required 

tests. MSS SP-89 also recommends that there 

should be an inspection program and suggests in

process inspection points, but again, these are 

recommendations, not requirements. 

Design Requirements: No significant 

differences that would affect the reasonable 

confidence of component functionality were 

identified.

Analysis: B31.1, AISC, and the MSS SPs 

have no personnel qualification or checking 

requirements. 

Design Verification: There is no universally 

used commercial standard requiring design 

verification. Neither B31.1, MSS SP-58, the AISC 

Manual of Steel Construction nor MSS SP-89 

address design verification. 

Design Control: There is no universally used 

commercial standard requiring design control. 

Neither B31.1, MSS SP-58, the AISC Manual of 

Steel Construction nor MSS SP-89 address design 

control. 

Procurement: Neither B3 1.1, MSS SP-58, or 

the AISC Manual of Steel Construction contain 

specific procurement requirements. 

Manufacturing: No significant differences 

that would affect the reasonable confidence of 

component functionality were identified. 

Shipping, Storage, and Handling: Neither 

B3 1.1, MSS SP-58, nor the AISC Manual of Steel 

Construction contain specific shipping, storage, 

and handling requirements. Similarly, MSS SP-89 

only contains very general recommendations for 

packaging, marking, shipping, receiving, and 

storage. 

Receipt Inspection: Neither B3 1.1, MSS 

SP 58, nor the AISC Manual of Steel Construction 

contain specific requirements that address receipt 

inspection. MSS SP-89 only contains very general 

recommendations for packaging, marking, 

shipping, receiving, and storage. 

Installation: No significant differences that 

would affect the reasonable confidence of 

component functionality were identified. 

Monitoring: There is no universally used 

commercial standard requiring monitoring. Neither 

B3 1.1, MSS SP-58, nor the AISC Manual of Steel 

Construction contain specific requirements that 

address this topic. 

Repair, Replacement, or Modification: 

There is no universally used commercial standard

23
addressing repair, replacement, or modification. 

B3 1.1 and MSS SP-58 provide limited guidance 

on weld repairs. The AISC Manual of Steel 

Construction contains no specific requirements 

that address this topic. 

Maintenance: There is no universally used 

commercial standard addressing maintenance. 

Neither B31.1, MSS SP-58, nor the AISC Manual 

of Steel Construction contain specific 

requirements that address this topic. 

Trending: There is no universally used 

commercial standard requiring trending. Neither 

B31.1, MSS SP-58, nor the AISC Manual of Steel 

Construction contain specific requirements that 

address this topic. 

Corrective Action: There is no universally 

used commercial standard addressing corrective 

action. Neither B3 1.1, MSS SP-58, nor the AISC 

Manual of Steel Construction contain specific 

requirements that address this topic. 

4.13 Vessel and Tank Supports 

4.13.1 Commercial Standard 

AISC Manual of Steel Construction. 

4.13.2 Special Treatment Requirements 

* 10 CFR 50.55a (ASME Section III, 

Subsection NF) 

* 10 CFR 50, Appendix B 

* 10 CFR 100, Appendix A 

4.13.3 Vessel and Tank Support 

Synopsis 

Vessel and tank supports are generally 

fabricated from either structural steel members or 

plate steel components, depending on the 

configuration of the vessel or tank (leg, column, or 

skirt supported, etc.). The design requirements for 

an individual support system are generally 

governed by the magnitude of the loads imposed, 

the types of loads expected,(thermal expansion, 

seismic, etc.), the location of the vessel or tank,

and other application specific parameters. The 

design requirements differences between the 

special treatment rules applicable to vessel or tank 

supports and the rules contained in commercially 

available standards do not result in a significant 

reduction of confidence in the assurance of pipe 

support functionality. Likewise, the differences in 

the special treatment rules and commercial 

standards addressing the manufacturing operations 

to fabricate the support and the operations needed 

to install the support do not result in a significant 

reduction of confidence in the assurance of pipe 

support functionality. However, as detailed in the 

subsections below, significant differences between 

the special treatment rule requirements and the 

available commercial standards do exist in the 

other critical processes. 

4.13.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: There is no universally used 

commercial standard requiring documentation. 

The AISC Steel Manual does not specifically 

require documentation. 

Oualitv Assurance: There is no universally 

used commercial standard requiring a quality 

assurance program. AISC does offer a Quality Certification designation; however, this is 

voluntary. 

Procedures: AISC does not require use of 

written procedures. 

Testing, Inspection, and Examination: The 

AISC Code of Standard Practice contains no 

specific testing, inspection, or examination 

requirements. Under AISC, any such requirements 

would have to be specifically stated in the owner's 

specifications. 

Design Requirements: No significant 

differences that would affect the reasonable 

confidence of component functionality were 

identified. 

Analysis: AISC has no personnel qualification 

or checking requirements.

24
Design Verification: There is no universally 

used commercial standard requiring design 

verification. The AISC Manual of Steel 

Construction does not address design verification. 

Design Control: There is no universally used 

commercial standard requiring design control. The 

AISC Manual of Steel Construction does not 

address design control. 

Procurement: The AISC Manual of Steel 

Construction contains no specific procurement 

requirements. 

Manufacturing: No significant differences 

that would affect the reasonable confidence of 

component functionality were identified. 

Shipping. Storage, and Handling: The AISC 

Manual of Steel Construction contains no specific 

shipping, storage, or handling requirements. 

Receipt Inspection: The AISC Manual of 

Steel Construction contains no specific 

requirements that address receipt inspection. 

Installation: No significant differences that 

would affect the reasonable confidence of 

component functionality were identified. 

Monitoring: There is no universally used 

commercial standard requiring monitoring. The 

AISC Manual of Steel Construction contains no 

specific requirements that address this topic. 

Repair. Replacement. or Modification: 

There is no universally used commercial standard 

requiring repair, replacement, or modification. The 

AISC Manual of Steel Construction contains no 

specific requirements that address this topic. 

Maintenance: There is no universally used 

commercial standard requiring maintenance. The 

AISC Manual of Steel Construction contains no 

specific requirements that address this topic. 

Trending: There is no universally used 

commercial standard requiring trending. The AISC 

Manual of Steel Construction contains no specific 

requirements that address this topic.

Corrective Action: There is no universally 

used commercial standard requiring corrective 

action. The AISC Manual of Steel Construction 

contains no specific requirements that address this 

topic. 

4.14 Gaskets 

4.14.1 Commercial Standard 

Gaskets are designed and manufactured to 

ASME Standard 16.21, Nonmetallic Flat Gaskets 

for Pipe Flanges, ASME Standard ASME B 16.20

1998, Metallic Gaskets for Pipe Flanges, Ring

Joint, Spiral-Wound, and Jacketed; ASME 

B 16.20a- 1994 Addenda to B 16.2, and ASME 

B 16.20b-1997 Addenda to B 16.20. The gaskets 

can, if specified, be manufactured to Section VIn, 

but is not required. Therefore, this evaluation will 

only address the B 16 series of ASME standards. 

4.14.2 Special Treatment Requirements 

* 10 CFR 50, GDC 1, 2,45, and 46, and 

Appendix B 

* 10 CFR 100, Appendix A 

4.14.3 Gasket Synopsis 

Gaskets are subject to QA, seismic, and all of 

the GDCs, since these components provide 

pressure boundary integrity for piping systems, 

heat removal systems, and vessels. The 

commercial standards provide adequate design 

requirements when specified in design 

specifications using specific plant application 

design requirements. The other critical processes 

are not addressed. However, alternate QA 

programs and other plant processes could be used 

to provide reasonable confidence of functionality. 

4.14.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: The standards address 

marking of gaskets to indicate material type, 

flange size, etc., but do not address other 

documentation.

25
Ouality Assurance: Standard B 16.20 

mentions ISO 9000 in Nonmandatory Annex A, 

Quality System Program. 

Procedures: The standards do not address 

procedures. 

Testing. Inspection, and Examination: The 

standards do not address the testing, inspection, 

and examination of gaskets. 

Design Requirements: The standards provide 

design information about gaskets. 

Analysis: Analysis is not mentioned in the 

standards. 

Design Verification: Design verification is 

not mentioned in the standards. 

Design Control: The standards do not address 

design control. 

Procurement: The standards do not address 

procurement. 

Manufacturing: Dimensions, tolerances, and 

materials are mentioned, but no detailed 

manufacturing information is provided on gaskets. 

Shipping, Storage, and Handling: Shipping, 

storage, and handling requirements are not 

mentioned in the standards. 

Receipt Inspection: Receipt inspection of 

gaskets is not mentioned in the standard. 

Installation: Gasket compression and 

tolerances are mentioned in the standards. 

Monitoring: Monitoring is not mentioned in 

the standards. 

Repair, Replacement, or Modification: 

Repair, replacement, or modification requirements 

are not mentioned in the standards. 

Maintenance: The standards do not address 

maintenance of gaskets.

Trending: Trending is not mentioned in the 

standards. 

Corrective Action: Corrective action is not 

mentioned in the standards. 

4.15 Air Compressors 

4.15.1 Commercial Standard 

American Society Mechanical Engineers, 

1995, Safety Standard for Air Compressor 

Systems, ASME B 19.1. This standard provides 

safety guidelines for the design, installation, and 

operation of air compressor systems. Several other 

component-specific standards are referenced, but 

are not addressed in this analysis. 

4.15.2 Special Treatment Requirements 

* 10 CFR 50.55a (ASME mI, IST, OM) 

* 10 CFR 50, GDC 45 and 46 and 

Appendix B 

* 10 CFR 100, Appendix A 

4.15.3 Air Compressor Synopsis 

Air compressor systems are typically designed 

to ASME B 19.1. They are also subject to the 

quality, seismic, and equipment qualification 

special treatment rules and may be subject to 

pressure boundary requirements of ASME 

Section III. When special treatment requirements 

are compared to commercial codes and standards 

(ASME B 19.1) there are significant differences in 

all processes. For example, while ASME B 19.1 

includes extensive air compressor equipment 

performance requirements to address safety in all 

areas of air compressor operation, it assumes that 

the compressor is designed in accordance with 

recognized standards and specifications. 

Verification of design capacity is not required. 

System performance requirements and seismic 

issues are not addressed. Test requirements are left 

up to the manufacturer. Therefore, ASME B 19.1 is 

not adequate to provide reasonable confidence of 

valve functionality. However, other industry 

quality assurance programs and other plant

26
processes may be used to provide reasonable 

confidence of functionality. 

4.15.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: ASME B 19.1 does not 

include any requirements that addresses the 

documentation associated with the design, 

installation, or operation of air compressor 

systems. 

Ouality Assurance: ASME B19.1 does not 

include any requirements that addresses the quality 

assurance process associated with the design, 

installation, or operation of air compressor 

systems. 

Procedures: ASME B 19.1 requires that 

comprehensive maintenance and operating 

procedures be implemented. These procedures 

should be based on the manufacturer's 

recommendations. ASME B 19.1 does not address 

procedural quality control issues or the use of 

acceptance criteria. 

Testing, Inspection, and Examination: 

ASME B 19.1 specifies that testing should be 

performed in accordance with the manufacturer s 

recommendations. Test records are required to be 

maintained and reviewed regularly. However, the 

standard does not address the test program 

development, qualification of test personnel, the 

test methods to be used, the types of testing to be 

performed, or the acceptance criteria to be applied. 

Design Requirements: ASME B19.1 includes 

extensive air compressor equipment performance 

requirements to address safety in all areas of air 

compressor operation. These requirements focus 

on the proper design of the safety equipment such 

as pressure relief devices, high temperature 

shutdown devices, protective guards, and over

speed controls, and the air piping systems. 

ASME B 19.1 assumes that qualified engineers in 

accordance with recognized standards and 

specifications design the compressor itself. System 

performance requirements and seismic issues are 

not addressed.

Analysis: ASME B 19.1 does not include any 

personnel qualification or checking requirements 

related to the design, installation, or operation of 

air compressor systems. 

Design Verification: ASME B 19.1 does not 

include any requirements to verify the design 

adequacy of the air compressor equipment except 

to verify that manufacturer's recommendations 

and all appropriate safety codes have been met 

regarding safety and protection of personnel. 

Design Control: ASME B 19.1 does not 

include any requirements that address the design 

control process associated with air compressor 

systems. 

Procurement: ASME B 19.1 does not include 

any requirements that address the procurement 

process associated with air compressor systems. 

Manufacturing: ASME B 19.1 does not 

include any requirements that address the 

manufacturing of air compressor systems. 

Shipping. Storage, and Handling: 

ASME B 19.1 does not include any requirements 

that address the shipping, storage, and handling 

processes associated with air compressor systems. 

Receipt Inspection: ASME B 19.1 does not 

include any requirements that address receipt 

inspections of air compressor systems. 

Installation: ASME B 19.1 does not include 

any requirements that address installation of air 

compressor systems. 

Monitoring: ASME B 19.1 notes that 

operational and maintenance records can be an 

important diagnostic tool. However, the standard 

only requires that records be kept and that they be 

reviewed regularly. ASME B 19.1 does not require 

a formal monitoring program that identifies 

equipment degradation and performs root cause 

analysis. 

Repair, Replacement, or Modification: 

ASME B 19.1 does not include any requirements 

that address the repair, replacement, or 

modification of air compressor systems.

27
Maintenance: ASME B 19.1 requires that a 

maintenance program be implemented that 

addresses routine maintenance, preventive 

maintenance, troubleshooting, and overhaul using 

the manufacturer's instructions as the basis. 

ASME B 19.1 does not address qualification of 

replacement parts. 

Trending: ASME B 19.1 does not include any 

requirements that address the performance 

trending of air compressor systems. 

Corrective Action: ASME B 19.1 does not 

include any requirements to implement a 

corrective action program for air compressor 

systems. 

4.16 HVAC 

4.16.1 Commercial Standard 

UBC, ASCE 7, ASHRAE 52, UL 900, 

SMACNA, NFPA 90A, and AWS D .1. 

4.16.2 Special Treatment Requirements 

& 10 CFR 20 

* 10 CFR 50.49 

* 10 CFR 50, GDC 45 and 46, and 

Appendix B 

* 10 CFR 100, Appendix A 

4.16.3 Related Nuclear Guidance 

0 ASME Nuclear Power Plant Air-Cleaning 

Units Components (ASME N509) and 

Testing of Nuclear Air-Treatment Systems 

(N5 10) for design and testing of HVAC 

equipment. 

4.16.4 HVAC Synopsis 

Nuclear HVAC systems are typically designed 

and tested to ASME Nuclear Codes N509, N5 10, 

and AG- 1. They are also subject to the quality, 

seismic, and equipment qualification special 

treatment rules. Since HVAC systems are 

comprised of a number of components such as

ducting, fans, and filters, several commercial 

standards relate to their construction. Commercial 

seismic requirements are covered by standards 

such as the UBC and ASCE 7 which specify 

seismic requirements different than nuclear codes, 

but nevertheless give reasonable confidence of 

functionality. Quality and equipment qualification 

requirements are not addressed in commercial 

codes, although ISO 9001 would cover quality 

requirements if specified. Testing of filters is 

covered in commercial codes, so if the design 

specification gives the filtration efficiency 

(including radiation) requirements, this area 

should be adequately covered. Guidance on 

welding is given in the American Society of 

Welding codes, but there are no in-service weld 

test requirements. 

4.16.5 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: There is no universally used 

commercial standard requiring documentation. 

Quality Assurance: There is no universally 

used commercial standard requiring a quality 

assurance program. 

Procedures: There is no universally used 

commercial standard requiring the use of 

procedures. 

Testing, Inspection, and Examination: 

ASHRAE 52 and UL 900 give methods for testing 

air cleaning efficiency. SMACNA gives guidance 

on leakage testing. AWS DI.1 gives guidance on 

welding manufacturing, but no ISI is required for 

welds. 

Design Requirements: Commercial HEPA 

(high-efficiency particulate air) filters and 

absorbers are not specifically designed to remove 

radioactive particles. The requirement for 

radioactive particle removal would have to be 

included in the design specification, but there are 

no qualification requirements for equipment such 

as local transmitters, hand switches, limit switches, 

instrumentation, or alarms in commercial practice.

28
Analysis: The seismic analysis methods in 

commercial standards are equivalent static 

methods. 

Design Verification: There is no universally 

used commercial standard requiring design 

verification. 

Design Control: There is no universally used 

commercial standard requiring design control. 

Procurement: There is no universally used 

commercial procurement standard. 

Manufacturing: No significant differences 

that would affect the reasonable confidence of 

component functionality were identified. 

Shipping, Storage. and Handling: There is 

no universally used commercial standard requiring 

shipping, storage, and handling. 

Receipt Inspection: There is no universally 

used commercial standard requiring receipt 

inspection. 

Installation: No significant differences that 

would affect the reasonable confidence of 

component functionality were identified. 

Monitoring: There is no universally used 

commercial standard requiring monitoring. 

Repair. Replacement, or Modification: 

There is no universally used commercial standard 

requiring repair, replacement, or modification. 

Maintenance: There is no universally used 

commercial standard requiring maintenance. 

Trending: There is no universally used 

commercial standard requiring trending. 

Corrective Action: There is no universally 

used commercial standard requiring corrective 

action.

4.17 Rupture Disks 

4.17.1 Commercial Standard 

ASME Section VIII. 

4.17.2 Special Treatment Requirements 

* 10 CFR 50.55a (ASME Section III) 

* 10 CFR 50, GDC I and 2, and 

Appendices B and S 

4.17.3 Rupture Disk Synopsis 

Design requirements for commercial rupture 

disks can be found in Section VIII of the ASME 

Code. A comparison of ASME Section II versus 

Section VIII for rupture disks is very similar to the 

description in Section 6.8.3 for pressure vessels. 

Section VIII requires a quality assurance program, 

but the requirements are not as stringent as those 

in Section mI. Other industry standards or 

individual plant processes may be used to provide 

reasonable confidence of functionality. There are 

sufficient design, manufacturing, and testing 

requirements in Section VIII to provide reasonable 

confidence of functionality. 

4.17.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: ASME Section VIII does 

require a quality assurance program; however, the 

level of documentation required is generally much 

less than that required by ASME Section HII, or 

that required under 10 CFR 50, Appendix B. 

Ouality Assurance: ASME Section VIII, 

Appendix 10 requires a quality assurance program; 

however, the program requirements do not match 

those contained in 10 CFR 50, Appendix B. For 

example, testing is not addressed. 

Procedures: ASME Section VIII, 

Appendix 10 requires a quality assurance program 

that includes provisions for procedures that will 

ensure that the latest versions of drawings, design 

calculations, and specifications are available, but 

10 CFR 50, Appendix B includes much more

29
detailed requirements regarding the contents of 

written procedures and the appropriate approval 

process for procedures. 

Testing, Inspection, and Examina'Lion: The 

testing, inspection, and examination requirements 

contained in Section VIII do not address items 

such as personnel qualification, continued training 

and certification, etc., in comparable detail to 

10 CFR 50, Appendix B. 

Design Requirements: No significant 

differences that would affect the reasonable 

confidence of component functionality were 

identified. 

Analysis: Section VmI has no personnel 

qualification or checking requirements. 

Design Verification: Section VIII has no 

universally design verification requirements. 

Design Control: ASME Section VIII, 

Appendix 10 requires a quality assurance program 

that includes provisions for procedures to ensure 

that the latest versions of drawings, design 

calculations, and specifications are available. 

10 CFR 50, Appendix B includes more detailed 

design control requirements on design interfaces 

and coordination, design change control, etc. 

Procurement: 10 CFR 50, Appendix B 

requires that vendors provide components under 

an Appendix B Quality Assurance program. 

Section VIIJ of the ASME Code does not have 

similarly stringent requirements. 

Manufacturin : No significant differences 

that would affect the reasonable confidence of 

component functionality were identified. 

Shipping, Storage, and Handling: No 

significant differences that would affect the 

reasonable confidence of component functionality 

were identified. 

Receipt Inspection: The guidelines contained 

in Section VIII are not comparable to the level of 

detail contained in 10 CFR 50, Appendix B. These 

differences are mainly in the areas of the level of 

record keeping required.

Installation: No significant differences that 

would affect the reasonable confidence of 

component functionality were identified. 

Monitoring: Section VIII of the ASME Code 

contains no guidance on this topic that is 

comparable to the requirements of 10 CFR 50, 

Appendix B. 

Repair, Replacement, or Modification: 

Section VII of the ASME Code contains some 

guidance on repairing material defects; however, 

these requirements are not comparable to the level 

of detail contained in 10 CFR 50, Appendix B. 

Maintenance: Section VIII of the ASME 

Code contains no guidance on this topic 

comparable to that included in 10 CFR 50, 

Appendix B. 

Trending: Section VIII of the ASME Code 

contains no guidance on this topic comparable to 

that included in 10 CFR 50, Appendix B. 

Corrective Action: Section VIII of the ASME 

Code contains no guidance on this topic 

comparable to that included in 10 CFR 50, 

Appendix B. 

4.18 Ion Exchangers 

4.18.1 Commercial Standard 

The applicable commercial standard was 

ASME PTC 31-1973, Ion Exchange Equipment, 

Performance Test Code. Pressure boundary 

components could be ordered as noncode or 

ASME Code Sections VIII or X. ASME Code 

Section VIII and X are not evaluated since they are 

not required to be used. 

4.18.2 Special Treatment Requirements 

* 10 CFR 50, GDC 1, 2, and 4, and 

Appendix B 

0 10 CFR 100, Appendix A

30
4.18.3 Ion Exchanger Synopsis

Ion exchangers are typically used as 

components to clean up water used in plant 

systems. Ion exchanger components must maintain 

pressure boundary integrity so must be designed 

for seismic conditions, designed to ASME Code 

Section III, and inspected to ASME Section XI. 

GDC 1, 2, and 4 and QA requirements would 

apply. Seismic analysis and ASME Section VIII 

vessel should be adequate to provide reasonable 

confidence of functionality for the pressure 

boundary. The commercial standard, ASME Ion 

Exchange Equipment Performance Test Code 

(ASME PTC31-1973) only addressed testing of 

the ion exchange process. These tests should be 

adequate when implemented by a specification for 

manufacturer and procedures for in-plant testing, 

inspection, and examination of the ion exchange 

process. None of the other processes were 

adequately addressed by the standard. However, 

alternate QA programs and other plant processes 

could be used to provide reasonable confidence.of 

functionality. 

4.18.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: There are no requirements 

for documentation in PCT31-1973. 

Ouality Assurance: There are no quality 

assurance requirements in PCT31-1973. 

Procedures: There are no requirements for 

procedures in PCT31-1973. 

Testing, Inspection, and Examination: 

PCT31-1973 specifically requires tests of ion 

exchanger components. 

Design Requirements: There are no design 

requirements in PCT31-1973. 

Analysis: There are no analysis requirements 

in PCT31-1973. 

Design Verification: There are no 

requirements for design verification in PCT3I

1973.

Design Control: There are no requirements 

for design control in PCT31-1973. 

Procurement: There are no procurement 

requirements in PCT31-1973. 

Manufacturing: There are no manufacturing 

requirements in PCT31-1973. 

Shipping. Storage. and Handling: There are 

no shipping, storage, and handling requirements in 

PCT31-1973. 

Receipt: There are no receipt inspection 

requirements in PCT31-1973. 

Installation: There are no installation 

requirements in PCT31-1973. 

Monitoring: There is nothing that requires 

PCT31-1973 being used for monitoring the 

performance of the ion exchange component. Not 

all of the attributes of this process would be met. 

Repair, Replacement, or Modification: 

PCT31-1973 does not address repair, replacement, 

or modification issues. 

Maintenance: PCT31-1973 does not address 

maintenance issues. 

Trending: There is no requirement for 

equipment trending in PCT31-1973. 

Corrective Action: There is no requirement 

for corrective action in PCT31-1973. 

4.19 Bolts 

4.19.1 Commercial Standard 

ASME Section VIII, ANSI B 18.2.1 

(dimensional requirements only). 

4.19.2 Special Treatment Requirements 

* 10 CFR 50.55a (ASME Section III) 

* 10 CFR 50, Appendix B.

31
4.19.3 Bolts Synopsis

The bolts addressed in this subsection are 

those commonly used in power plants for such 

applications as securing flanged piping component 

connections, attaching valve operators to valve 

bonnets, completing structural connections in 

piping support structural members, etc. Both the 

special treatment rules and commercial standards 

impose material requirements and design rules for 

bolted joints. Thus, the design requirement 

differences between the special treatment rules 

applicable to these bolts and the rules contained in 

commercially available standards do not result in a 

significant reduction of confidence in the 

assurance of bolt (or bolted joint) functionality. 

Likewise, the differences in the special treatment 

rules and commercial standards addressing the 

manufacturing or installation do not result in a 

significant reduction of confidence in the 

assurance of pipe support functionality. However, 

as detailed in the subsections below, significant 

differences between the special treatment rule 

requirements and the available commercial 

standards do exist in the other critical processes. 

4.19.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: The documentation 

requirements of Section VIII are less stringent than 

those imposed by Section IH. 

Ouality Assurance: Appendix 10 of 

Section VIII contains mandatory quality control 

system requirements. Whereas this appendix 

addresses some of the same topics as 10 CFR 50, 

Appendix B, such as authority and responsibility, 

the same elements are not all addressed and 

comparable level of detail is not included in 

Appendix 10 of Section VIII. 

Procedures: Appendix 10 of Section VIII 

contains requirements for procedures that ensure 

that the latest drawings and specifications are 

used; however, these requirements are not 

equivalent to those of 10 CFR 50, Appendix B. 

Testing, Inspection, and Examination: 

Appendix 10 of Section VIII contains

requirements for examination and inspection. 

However, the requirements only specify the 

description of fabrication stages where inspections 

are to be performed. These requirements are not 

equivalent to those of 10 CFR 50, Appendix B. 

Design Requirements: No significant 

differences that would affect the reasonable 

confidence of component functionality were 

identified. 

Analysis: Appendix 10 of Section VIII has no 

personnel qualification or checking requirements 

for analyses. 

Design Verification: Appendix 10 of 

Section VIII has no design verification 

requirements. 

Design Control: Appendix 10 of Section VIII 

does not address design control. 

Procurement: Section VIII of the ASME 

Code does not contain specific procurement 

requirements. 

Manufacturing: No significant differences 

that would affect the reasonable confidence of 

component functionality were identified. 

Shipping, Storage, and Handling: Section 

VIE of the ASME Code does not contain specific 

shipping, storage, and handling requirements. 

Receipt Inspection: Section VmII of the 

ASME Code contains no specific requirements 

that address receipt inspection. 

Installation: No significant differences that 

would affect the reasonable confidence of 

component functionality were identified. 

Monitoring: Section VImI of the ASME Code 

contains no specific requirements that address this 

topic. 

Repair, Replacement, or Modification: 

Neither Section III or Section VIII of the ASME 

Code address repair, replacement, or modification 

of bolting.

32
Maintenance: Section VIII of the ASME 

Code contains no specific requirements that 

address this topic relative to bolting. 

Trending: Section VIII of the ASME Code 

contains no specific requirements that address this 

topic relative to bolting. 

Corrective Action: Section VIII of the ASME 

Code contains no specific requirements that 

address this topic relative to bolting. 

4.20 Anchor Bolts 

4.20.1 Commercial Standard 

Standard Industry Practices, ISO 9001 (the 

major manufacturer's catalog consulted listed the 

company as ISO 9001 certified). 

4.20.2 Special Treatment Requirements 

0 10 CFR 50, Appendix B. 

4.20.3 Related Nuclear Guidance 

American Concrete Institute ACI-349 series 

(Reinforced Concrete Design for Thermal 

Effects on Nuclear Power Plant Structures, 

Embedment Design Examples, Evaluation 

of Existing Nuclear Safety Related Concrete 

Structures, and Code Requirements for 

Nuclear Safety Related Concrete Structures 

& Commentary) for anchor bolt design. 

NRC IE Bulletins, such as 79-02, provide 

the NRC staff position for anchor bolt 

design. 

4.20.4 Anchor Bolts Synopsis 

The anchor bolts addressed in this subsection 

are those commonly referred to as concrete anchor 

bolts. These fasteners may be of a type that are 

located during construction ("cast in place") or of 

the wedge or sleeve type that are inserted in a hole 

drilled in the concrete floor or wall at the desired 

location subsequent to concrete placement. These 

bolts are most often used to secure components 

such as piping support base plates, electrical 

cabinets, pump supports, etc., to the plant building

structure. Both the special treatment rules and 

commercial standards impose material 

requirements and design rules for bolted joints. 

Thus, the design requirement differences between 

the special treatment rules applicable to these bolts 

and the rules contained in commercially available 

standards do not result in a significant reduction of 

confidence in the assurance of bolt (or bolted 

joint) functionality. Likewise, the differences in 

the special treatment rules and commercial 

standards addressing manufacturing do not result 

in a significant reduction of confidence in the 

assurance of pipe support functionality. 

Parameters such as edge distance, embedment 

depth, etc., that are shown in both the nuclear and 

commercial codes and standards generally agree 

with the manufacturer's installation instructions; 

thus, no significant differences in installation 

requirements that would affect the confidence of 

anchor bolt functionality were identified. 

However, as detailed in the subsections below, 

significant differences between the special 

treatment rule requirements and the available 

commercial standards do exist in the other critical 

processes. 

4.20.5 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: There is no universally used 

commercial standard requiring documentation. 

Ouality Assurance: There is no universally 

used commercial standard requiring a quality 

assurance program. 

Procedures: Manufacturer's installation 

procedures are available; however, there is no 

requirement for the used of documented and 

controlled installation procedures. 

Testing. Inspection, and Examination: 

There is no universally used commercial standard 

requiring a testing, inspection, or examination 

program for anchor bolts. No ISI is required. 

Design Requirements: No significant 

differences that would affect the reasonable 

confidence of component functionality were 

identified.

33
Analysis: There are no universally applicable 

standards governing the analysis of anchor bolts, 

personnel qualifications, or checking 

requirements. 

Design Verification: There is no universally 

used commercial standard requiring design 

verification. 

Design Control: There is no universally used 

commercial standard requiring design control. 

Procurement: B31.1 requires specified 

material and manufacturing methods. 

Manufacturing: There were no significant 

differences that would affect the reasonable 

confidence of component functionality identified. 

Shipping. Storage, and Handling: There is 

no universally used commercial standard requiring 

shipping, storage, and handling. 

Receipt Inspection: There is no universally 

used commercial standard requiring receipt 

inspection. 

Installation: There were no significant 

differences that would affect the reasonable 

confidence of component functionality identified. 

Monitoring: There is no universally used 

commercial standard requiring monitoring. 

Repair, Replacement, or Modification: 

There is no universally used commercial standard 

requiring repair, replacement, or modification. 

Maintenance: There is no universally used 

commercial standard requiring maintenance. 

Trending: There is no universally used 

commercial standard requiring trending. 

Corrective Action: There is no universally 

used commercial standard requiring corrective 

action.

4.21 Lighting 

4.21.1 Commercial Standard 

The Illuminating Engineering Society of North 

(IESNA) Lighting Handbook provides reference 

and application information for lighting, UL 

Standards 676, 844, 1598, and 1994 that address 

underwater, hazardous locations, nonhazardous 

locations, and low-level and marking lighting 

systems. SAE J 95 and J 96 address headlamps 

and flashing warning lamps for industrial 

equipment. 

4.21.2 Special Treatment Requirements 

0 10 CFR 50.49 

* 10 CFR 50, GDC 1, 2, and 4, and 

Appendix B 

a 10 CFR 100, Appendix A. 

4.21.3 Lighting Synopsis 

Some lighting is located in areas that are 

subject to accident conditions. That lighting must 

meet EQ requirements as well as the requirements 

of GDC 2, GDC 4, and QA. When special 

treatment requirements are compared to 

commercial codes and standards there are 

significant differences in all processes except 

design requirements, maintenance, and trending. 

The IESNA Lighting Handbook contains basic 

lighting requirements that must be met by all 

lighting systems, and design requirements 

addressed by the combination of the reviewed 

standards (1ESNA Lighting Handbook, UL 

Standards 676, 844, 1598, and 1994) should lead 

to a full set of design requirements. Maintenance 

of lighting systems is covered in Chapter 32 of the 

IESNA Lighting Handbook, which also contains 

information, charts, and figures, etc., that support trending light output. This information is used to 

plan for the maintenance and/or replacement of 

system components.

34
4.21.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: The reviewed standards to 

do not address documentation requirements. 

Ouality Assurance: The reviewed standards 

do not address quality assurance programs. 

Procedures: Procedures are not identified. 

Manufacturing facilities are certified to be 

acceptable suppliers of equipment using plant 

inspections and the acceptance of the facility's 

quality assurance program. 

Testing. Inspection, and Examination: All 

the reviewed UL standards require testing to 

certify the equipment. Certificates indicating that 

the equipment meets the requirements of each 

standard are affixed to each unit. Routine testing 

during the operational phase is not addressed. 

Design Requirements: The IESNA Lighting 

Handbook contains basic lighting requirements. 

that all lighting systems must meet. The design 

requirements addressed by the combination of the 

reviewed standards should lead to a full set of 

design requirements. 

Analysis: The reviewed standards do not 

address the analysis process. 

Design Verification: Testing required by the 

UL standards provides for design verification of 

safety related lighting. However, seismic events 

are not included. 

Design Control: The reviewed standards do 

not address design control attributes. 

Procurement: The standards could lead to 

development of procurement specifications. 

However other procurement attributes, such as 

control of vendors and approval of procurement 

documents are not addressed. 

Manufacturing: The manufacturing process 

is not addressed by the reviewed standards.

Shipping, Storage, and Handling: The 

reviewed standards do not address the shipping, 

storage, and handling of lighting equipment. 

Receipt: The reviewed standards do not 

address receipt inspection of lighting equipment. 

Installation: The reviewed standards do not 

address installation of lighting equipment. Special 

considerations in lighting systems installation are 

generally detailed in the installation documents 

that are not included in the reviewed standards. 

Monitoring: The reviewed standards do not 

address the monitoring process. 

Repair, Replacement, or Modification: The 

reviewed standards do not address the 

programmatic aspects of repair, replacement, or 

modification of lighting systems. 

Maintenance: Maintenance of lighting 

systems is covered in Chapter 32 of the IESNA 

Lighting Handbook. 

Trending: The IESNA Lighting Handbook 

contains information, charts, and figures, etc., that 

show trending in light output. This information is 

used to plan for the maintenance and replacement 

of system components. 

Corrective Action: Examples are given in the 

IESNA Lighting Handbook that show how 

trending information is used to plan for the 

maintenance and replacement of system 

components. The reviewed standards do not 

address the corrective action process. 

4.22 Alarms 

4.22.1 Commercial Standard 

Commercial codes and standards that relate to 

control room applications were not identified. 

NFPA 101 addresses alarms related to life safety 

systems. ANSIIUL 294 address alarms as they 

relate to access control systems. However, these 

codes are not considered applicable to industrial 

process control applications.

35
4.22.2 Special Treatment Requirements 

* 10 CFR 50, GDC 1, 2, and 4, and 

Appendix B 

a 10 CFR 100, Appendix A 

4.22.3 Alarms Synopsis 

Alarms are not located in areas that are 

subjected to accident conditions and, therefore, are 

not required to meet EQ requirements. However, 

alarms must meet the requirements of GDC 2, 

GDC 4, and QA. Commercial codes and standards 

that relate to control room applications were not 

identified. NFPA 101 addresses alarms related to 

life safety systems. ANSIFUL 294 address alarms 

as they relate to access control systems. However, 

these codes are not considered to be applicable to 

industrial process control applications. 

4.22.4 Commercial Standards 

Comparison with Nuclear 

Processes 

No codes or standards applicable to industrial 

process control applications were identified. 

4.23 Electrical Switchgear 

4.23.1 Commercial Standard 

Institute of Electrical and Electronic Engineers (IEEE) 1015 and C37.13 are application guides for 

low voltage circuit breakers, while C37.010 is an 

application guide for high voltage circuit breakers. 

IEEE C37.09 is a test procedure for high-voltage 

circuit breakers. 

4.23.2 Special Treatment Requirements 

0 10 CFR 50, GDC 1, 2, 4, and 10, and 

Appendix B 

* 10 CFR 100 Appendix A 

4.23.3 Electrical Switchgear Synopsis 

Electrical switchgear is not typically located in 

areas that are subjected to accident conditions, and 

is therefore not required to meet EQ requirements.

However, electrical switchgear must meet the 

requirements of GDC 2, GDC 4, and QA. When 

special treatment requirements are compared to 

commercial codes and standards there are 

significant differences in all processes except 

design requirements, design verification, and 

maintenance. The combination of commercial 

standards reviewed (IEEE 1015, C37.13, C37, 

010, and C37.09) includes design requirements 

needed to assure functionality. Verification of 

these design requirements is also included by 

standards that address testing requirements. IEEE 

standards such as 1015 provide recommended 

maintenance for circuit breakers and address the 

significant attributes of this process. 

4.23.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: IEEE 1015 states that 

maintenance records should be maintained and 

IEEE C37.09 states that test reports should be 

written and also provides some guidance regarding 

the content of the reports. Other documentation 

requirements are not addressed in the standards 

reviewed. 

Quality Assurance: The reviewed standards 

do not address quality assurance programs. 

Procedures: IEEE 1015 references testing and 

maintenance procedures for low-voltage circuit 

breakers and IEEE C37.09 is a test procedure for 

some ac high-voltage circuit breakers. These 

standards do identify that test procedures should 

be used. However, procedures for processes such 

as manufacturing and installation are not 

addressed. 

Testing, Inspection, and Examination: The 

reviewed standards do not address attributes such 

as control of test equipment, program 

development, independent assessments and 

verification, and test frequencies. 

Design Requirements: IEEE standards such 

as 1015, C37.10, and C37.13 are application 

standards that could lead to development of 

performance specifications. IEEE C37.09 

identifies design tests that could be required. The

36
combination of these would include design 

requirements needed to assure functionality. 

Analysis: The standards reviewed are not 

significantly related to analyses. IEEE C37.10 

does provide some system analysis that is 

necessary to properly identify some technical 

details, such as short circuit current and X/R 

ratios. 

Design Verification: IEEE standards such as 

C37.09 provide for design and production tests. 

IEEE C37.010 states that for breakers applied to 

locations with known seismic activity the 

withstand requirements of C37.81 (seismic 

qualification of metal-enclosed Class 1 E breakers) 

should be specified. 

Design Control: The reviewed IEEE 

standards do not address design control attributes. 

Procurement: IEEE standards such as 1015, 

C37.10, and C37.13 are application standards that 

could lead to development of procurement 

specifications. However, other procurement 

attributes, such as control of vendors and approval 

of procurement documents are not addressed. 

Manufacturing: IEEE standards such as 

C37.09 provide for production testing. However, 

other aspects of manufacturing are not addressed. 

Shipping, Storage, and Handling: The 

standards reviewed do not address this process. 

Receipt: IEEE standards such as C37.09 

provide for acceptance testing. Otherwise, receipt 

inspection is not addressed. 

Installation: The standards reviewed do not 

address having procedures and qualified personnel 

for installing the circuit breakers. 

Monitoring: Testing to determine if 

performance degradation has occurred is included 

in IEEE standards such as conformance testing in 

IEEE C37.09. However attributes such as root 

cause analysis, corrective action, and identification 

of conditions adverse to operability are not 

addressed in the reviewed standards.

Repair, Replacement, or Modification: The 

standards reviewed address repair, replacement 

and modifications. 

Maintenance: IEEE standards such as 1015 

provide recommended maintenance for circuit 

breakers and address the significant attributes of 

this process. 

Trending: Trending of test results is not 

addressed by the standards reviewed. 

Corrective Action: Corrective action is not 

addressed by the standards reviewed. 

4.24 Molded Case Circuit 

Breakers 

4.24.1 Commercial Standard 

IEEE 1015 is an application standard for low 

voltage circuit breakers, including molded case 

circuit breakers that addresses rating and testing, 

selection considerations, acceptance, and 

maintenance. UL 489 addresses construction, 

ratings, and testing of molded case circuit 

breakers. The UL standard is particularly 

concerned with those things that could involve a 

risk of fire, electric shock, or injury to people. 

4.24.2 Special Treatment Requirements 

S 10 CFR 50, GDC 1, 2,4, and 10, and 

Appendix B 

* 10 CFR 100 Appendix A 

4.24.3 Molded Case Circuit Breaker 

Synopsis 

Molded Case Circuit Breakers (MCCB) are 

not typically located in areas that are subjected to 

accident conditions and, therefore, are not required 

to meet EQ requirements. However, MCCB must 

meet the requirements of GDC 2, GDC 4, and QA. 

When special treatment requirements are 

compared to commercial codes and standards there 

are significant differences in all processes except 

design requirements and maintenance. The 

combination of commercial standards reviewed 

(IEEE 1015 and UL 489) will provide information

37
that leads to development of performance 

specifications. The combination of these would 

provide design requirements needed to assure 

functionality. IEEE 1015 provides recommended 

maintenance for circuit breakers and addresses the 

significant attributes of the maintenance process. 

4.24.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: IEEE 1015 states that 

maintenance records should be maintained. Other 

documentation requirements are not addressed in 

the standards reviewed. 

Ouality Assurance: The reviewed standards 

do not address quality assurance programs. 

Procedures: IEEE 1015 references testing and 

maintenance procedures for low voltage circuit 

breakers. UL 489 identifies tests that should be 

run, their acceptance criteria, and the testing 

sequence. No actual procedures are provided. 

These standards identify that test procedures 

should be used. However, procedures for 

processes such as manufacturing and installation 

are not addressed. 

Testing, Inspection, and Examination: UL 

489 only addresses testing to verify that the circuit 

breakers will perform as specified. Acceptance and 

periodic in plant testing is not addressed. IEEE 

1015 addresses tests that verify over-current, short 

circuit, and shunt trips. Visual examinations and 

personnel training are also addressed. Control of 

test equipment is not addressed. Attributes such as 

program development, independent assessments, 

and verification, and test frequencies are not 

specifically identified. 

Design Requirements: Standards such as 

IEEE 1015 and UL 489 provide information that 

could lead to development of performance 

specifications. The combination of these would 

provide design requirements needed to assure 

functionality. 

Analysis: The standards reviewed are not 

significantly related to analyses. IEEE 1015 does 

provide some system analysis that is necessary to

properly identify some technical details, such as 

short circuit current and X/R ratios. 

Design Verification: UL 489 provides for 

design verification tests and IEEE 1015 describes 

tests to verify trip settings, however seismic 

conditions are not addressed in these tests. 

Design Control: The reviewed standards do 

not address design control attributes. 

Procurement: The reviewed standards could 

lead to development of procurement 

specifications. However, other procurement 

attributes, such as control of vendors and approval 

of procurement documents are not addressed. 

Manufacturing: UL 489 provides some 

construction details and tests to verify the design 

meets significant requirements. However, 

attributes related to control of the manufacturing 

process are not addressed. 

Shipping. Storage, and Handling: The 

standards reviewed do not address this process. 

Receipt: The standards reviewed do not 

address this process. 

Installation: The standards reviewed do not 

address this process. 

Monitoring: Testing to determine if 

performance degradation has occurred is included 

in IEEE 1015. However, attributes such as root 

cause analysis, corrective action, and identification 

of conditions adverse to operability are not 

addressed in the reviewed standards. 

Repair, Replacement, or Modification: The 

standards reviewed do not address this process. 

Maintenance: IEEE 1015 provides 

recommended maintenance for circuit breakers 

and addresses the significant attributes of this 

process. 

Trending: Trending of test results is not 

addressed by the standards reviewed.

38
Corrective Action: Corrective action is not 

addressed by the standards reviewed. 

4.25 Transformers 

4.25.1 Commercial Standard 

IEEE C57,12.00, C57.12.01 and C57.12.26 

and ANSI C57.12.22 provide general requirements 

for pad mounted, dry type and liquid immersed 

transformers. IEEE C57.93 addresses installation 

of liquid immersed transformers; IEEE C 57.94 

addresses installation, application, operation, and 

maintenance of dry type transformers; and IEEE 

C57.12.91 addresses testing of dry type 

transformers. 

4.25.2 Special Treatment Requirements 

10 CFR 50, GDC 1, 2,4, and 10, and 

Appendix B 

* 10 CFR 100, Appendix A 

4.25.3 Transformer Synopsis 

Transformers are not typically located in areas 

that are subjected to accident conditions and, 

therefore, are not required to meet the 

requirements of EQ. However, transformers must 

meet the requirements of GDC 2, GDC 4, and QA. 

When special treatment requirements are 

compared to commercial codes and standards there 

are significant differences in all processes except 

design requirements and maintenance. The 

combination of commercial standards reviewed 

(IEEE C57.12.00, C57.12.01, C57.12.26, 

C57.12.91, C57.93, and C 57.94 and ANSI 

C57.12.22) would provide information that could 

lead to development of performance 

specifications. IEEE C57.12.00, C57.12.01, and 

C57.12.91 address ratings, configuration, short 

circuit requirements, dielectric, impedance, and 

construction. Seismic requirements are addressed 

as an unusual service condition in IEEE C57.12.00 

and C57.12.01. Maintenance of liquid immersed 

transformers is addressed in IEEE C57.93 and for 

dry type transformers in IEEE C57.94.

4.25.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: IEEE C57.12.91 addresses a 

test report. Otherwise, the reviewed standards do 

not address other types of documentation or 

control of documentation. 

Ouality Assurance: The reviewed standards 

do not address quality assurance programs. 

Procedures: Testing requirements are defined 

but no actual procedures are addressed. 

Testing. Inspection. and Examination: The 

reviewed standards either directly address or 

reference other standards that address both design, 

and routine testing of transformers. Control of test 

equipment and personnel training is not addressed. 

Attributes such as program development, 

independent assessments, and verification, and test 

frequencies are not identified. 

Design Requirements: IEEE C57.12.00, 

C57.12.01, and C57.12.91 address ratings, 

configuration, short circuit requirements, 

dielectric, impedance, and construction. Seismic 

requirements are addressed as an unusual service 

condition in IEEE C57.12.00 and C57.12.01. 

Analysis: The reviewed standards do not 

address the analysis process. 

Design Verification: Testing to verify design 

parameters is generally addressed in IEEE C57.12 

and C57.12.01, and specific tests are identified in 

IEEE C57.12.91. However, testing or analysis to 

verify seismic design considerations is not 

addressed. 

Design Control: The reviewed standards do 

not address design control attributes. 

Procurement: The standards could lead to 

development of procurement specifications. 

However, other procurement attributes, such as 

control of vendors and approval of procurement 

documents are not addressed.

39
Manufacturing: Manufacturing is not 

addressed by the reviewed standards. 

Shipping, Storage, and Handling: All the 

reviewed standards, except IEEE C57.12.91, 

address shipping and storage considerations such 

as electrical configuration and orientation. 

Procedures for identification and control of 

equipment are not generally addressed. 

Receipt: The documentation aspects of receipt 

are not addressed by the reviewed standards. 

Installation: Installation instructions, 

documentation, and personnel qualification are not 

addressed in the reviewed standards. 

Monitoring: The reviewed standard does not 

address the monitoring process. 

Repair, Replacement, or Modification: The 

reviewed standards do not address repair, 

replacement, or modification of transformers. 

Maintenance: Maintenance of liquid 

immersed transformers is addressed in 

IEEE C57.93 and for dry-type transformers in 

IEEE C57.94. 

Trending: The reviewed standard does not 

address the trending process. 

Corrective Action: IEEE C57.93 and C57.94 

address drying of the core insulation. However, the 

reviewed standards do not address the corrective 

action process. 

4.26 Motors 

4.26.1 Commercial Standard 

IEEE 112 addresses testing of polyphase 

induction motors, IEEE 432 provides a guide for 

insulation maintenance of rotating machinery, and 

IEEE 841 addresses motors in the petroleum and 

chemical industry that are in severe duty 

situations. ANSI C50.41 and National Electrical 

Manufactures Association (NEMA) MG 2 provide 

guidance oriented more toward manufacturing and 

application of motors.

4.26.2 Special Treatment Requirements 

S 10 CFR 50.49 

10 CFR 50, GDC 1, 2, 4, and 10, and 

Appendix B 

* 10 CFR 100 Appendix A 

4.26.3 Motor Synopsis 

Motors may be located in areas that are subject 

to accident conditions and those must meet EQ 

requirements as well as the requirements of 

GDC 2, GDC 4, and QA. When special treatment 

requirements are compared to commercial codes 

and standards there are significant differences in 

all processes except design requirements and 

maintenance. The commercial standards reviewed 

(IEEE 112, 432, and 841, ANSI C50.41 and 

NEMA MG 2) provide information from which 

design requirements could be specified. The 

combination of these would include design 

requirements needed to assure functionality. 

IEEE 432 provides recommended maintenance for 

motors and addresses the significant attributes of 

the maintenance process. 

4.26.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: The IEEE standards do not 

address documentation. However, ANSI C50.41 

does address general documentation requirements 

as well as documentation of motor data, 

performance curves, performance data, motor 

accessories, test reports, drawings, and instruction 

manuals. Other documentation requirements are 

not addressed in the standards reviewed. 

Quality Assurance: The reviewed standards 

do not address quality assurance programs. 

Procedures: While specific tests are identified 

in IEEE 112 and 432, procedures are more general 

and not detailed. Procedures for processes other 

than testing, such as manufacturing, are not 

provided and procedure control and approval are 

not addressed.

40
Testing. Inspection, and Examination: All 

the reviewed standards have some requirements 

for testing, inspection, and examination. These 

tests include nearly all phases of an electrical 

motor. Control of test equipment and personnel 

training is not addressed. Attributes such as 

program development, independent assessments, 

and verification, and test frequencies are not 

specifically identified. 

Design Requirements: Standards such as 

IEEE 842, ANSI C50.42, and NEMA MG 2 

provide information from which design 

requirements could be specified. The combination 

of these would include design requirements 

needed to assure functionality. 

Analysis: The standards reviewed are not 

significantly related to analyses. IEEE 112 and 

ANSI C50.41 provide guidance for calculating 

some motor performance characteristics using data 

gathered during the specified tests. 

Design Verification: Testing as described 

above will provide verification of motor 

performance characteristics during normal 

operations. However, these tests do not address 

Environmental qualification and verification of the 

ability to withstand seismic events. 

Design Control: The reviewed standards do 

not address design control attributes. 

Procurement: The reviewed standards could 

lead to development of procurement 

specifications. However, other procurement 

attributes, such as control of vendors and approval 

of procurement documents are not addressed. 

Manufacturing: ANSI 50.41 and NEMA 

MG 2 provide some construction details and tests 

to verify the design meets significant 

requirements. However, attributes related to 

control of the manufacturing process are not 

addressed. 

Shipping. Storage, and Handling: The 

standards reviewed do not address this process. 

Receipt: The standards reviewed do not 

address this process.

Installation: NEMA MG 2 addresses some 

aspects of installation, such as safety in machine 

installation. Safety considerations of protection, 

grounding, wiring connections, flammable 

materials, rotating parts, maximum speed of drive 

components, and lifting are addressed. 

Qualification of personnel and procedures, proper 

anchors, and alignment of the motor to the load are 

not addressed. 

Monitoring: Testing to determine if 

performance degradation has occurred is included 

in IEEE 112. However, attributes such as root 

cause analysis, corrective action, and identification 

of conditions adverse to operability are not 

addressed in the reviewed standards. 

Repair. Replacement, or Modification: The 

standards reviewed do not address this process. 

Maintenance: IEEE 432 provides 

recommended maintenance for motors and 

addresses the significant attributes of this process. 

Trending: Trending of test results is not 

addressed by the standards reviewed. 

Corrective Action: Corrective action is not 

addressed by the standards reviewed. 

4.27 Motor Control Centers 

4.27.1 Commercial Standard 

ANSI C37.50 addresses low-voltage circuit 

breakers used in enclosures; NEMA Industrial 

Control and Systems (ICS) 2.3 provides 

instructions for handing, installation, operation, 

and maintenance of motor control centers; and 

NEMA ICS 1 has general applicability to 

industrial control and systems, including Motor 

Control Centers (MCCs). 

4.27.2 Special Treatment Requirements 

* 10 CFR 50, GDC l, 2, and 4, and 

Appendix B 

* 10 CFR 100 Appendix A

41
4.27.3 Motor Control Center Synopsis 

Motor Control Centers (MCC) are not 

typically located in areas that are subjected to 

accident conditions and, therefore, are not required 

to meet EQ requirements. However, MCCs must 

meet the requirements of GDC 2, GDC 4, and QA. When special treatment requirements are 

compared to commercial codes and standards there 

are significant differences in all processes except 

design requirements, installation, and 

maintenance. While the combination of 

commercial standards reviewed (ANSI C37.50, 

NEMA ICS 1, and NEMA ICS 2.3) does not 

provide specific details, consideration for 

performance requirements, including 

environmental and seismic conditions, is 

addressed. Design requirements for circuit 

breakers are discussed separately in this report. 

NEMA ICS I requires installation in accordance 

with the NEC, which among other things requires that personnel be qualified to perform their tasks. 

NEMA ICS 2.3 includes extensive instructions-for 

installation of MCCs including the requirement to 

follow the manufacturer's instructions. 

Maintenance of MCCs is addressed in NEMA 

ICS 1 and NEMA ICS 2.3. 

4.27.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: NEMA ICS I defines 

standards for naming and symbols on drawings. 

Otherwise, the reviewed standards do not address 

other types of documentation or control of 

documentation. 

Ouality Assurance: The reviewed standards 

do not address quality assurance programs. 

Procedures: Testing procedures are provided in ANSI C.37.50 and NEMA ICS I. The reviewed 

standards do not address other types of procedures 

or control of procedures. 

Testing, Inspection, and Examination: 

ANSI 37.50 identifies extensive design and 

production tests. Routine testing and examination, 

such as would be performed during the operational 

phase, are not addressed. Control of test equipment

and personnel training are not addressed. 

Attributes such as program development, 

independent assessments, verification, and test 

frequencies are not identified. 

Design Requirements: While specific details 

are not provided, consideration for performance 

requirements, including environmental and seismic 

conditions, is addressed. Design requirements for 

circuit breakers are discussed separately in this 

report. 

Analysis: The reviewed standards do not 

address the analysis process. 

Design Verification: ANSI C37.50 verifies 

design parameters for circuit breakers and 

NEMA ICS 1 addresses testing to verify 

performance requirements. However, testing or 

analysis of MCCs to verify the ability to withstand 

seismic events is not included. 

Design Control: The reviewed standards do 

not address design control attributes. 

Procurement: The standards could lead to 

development of procurement specifications. 

However other procurement attributes, such as 

control of vendors and approval of procurement 

documents are not addressed. 

Manufacturin : ANSI C37.50 addresses 

production testing of low voltage circuit breakers. 

However, the manufacturing process is not 

addressed by the reviewed standards. 

Shipping, Stora2e, and Handling: NEMA 

ICS 1 addresses storage and handling and NEMA 

ICS 2.3 addresses handling of equipment. 

Shipping is not addressed. Procedures for 

identification and control of equipment are not 

addressed. 

Receipt: Some visual inspection of MCCs is 

addressed in NEMA ICS 2.3. The planning and 

documentation aspects of receipt are not addressed 

by the reviewed standards. 

Installation: NEMA ICS 1 requires 

installation in accordance with the NEC, which 

among other things requires that personnel be

42
qualified to perform their tasks. NEMA ICS 2.3 

includes extensive instructions for installing 

MCCs, including the requirement to follow the 

manufacturer's instructions. 

Monitoring: The reviewed standard does not 

address the monitoring process. 

Repair, Replacement, or Modification: The 

reviewed standards do not address the 

programmatic aspects of repair, replacement, or 

modification of MCCs. 

Maintenance: Maintenance of MCCs is 

addressed in NEMA ICS 1 and NEMA ICS 2.3. 

Trending: The reviewed standards do not 

address the trending process. 

Corrective Action: ANSI C37.50 only 

addresses actions resulting from production test 

failures and NEMA ICS 2.3 only addresses 

maintenance after a fault has occurred. The 

reviewed standards do not address the corrective 

action process. 

4.28 Electrical Cabling 

4.28.1 Commercial Standard 

IEEE 576 and 1185 address installation of 

electrical cables in the petroleum/chemical 

industry and power generating stations, 

respectively; NEMA WC-3, 5, 7, and 8 address the 

manufacturing of cables; the NEC provides 

requirements for assuring public safety in the 

selection, installation, and termination of cables. 

4.28.2 Special Treatment Requirements 

* 10 CFR 50.49 

& 10 CFR 50, GDC 1, 2,4, and 10, and 

Appendix B 

* 10 CFR 100 Appendix A 

4.28.3 Electrical Cabling Synopsis 

Electrical Cables is typically located in areas 

that are subject to accident conditions and,

therefore, must meet EQ requirements as well as 

the requirements of GDC 2, GDC 4, and QA. 

When special treatment requirements are 

compared to commercial codes and standards there 

are significant differences in all processes except 

installation. Of the commercial standards reviewed 

(IEEE 576 and 1185, NEMA WC-3, 5, 7, and 8, 

the NEC), IEEE 576 and 1185 and the NEC 

provide installation requirements, including cable 

pulling requirements, protection of cables (conduit 

and cable trays), conduit fill requirements, and 

termination requirements. The NEC also addresses 

qualification of personnel. These standards address 

the significant attributes of the installation process. 

4.28.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: The reviewed standards do 

not address documentation. 

Oualitv Assurance: The reviewed standards 

do not address quality assurance programs. 

Procedures: The NEMA standards provide 

procedures for testing cables. However, 

procedures are not provided for manufacturing. 

Procedural controls and approvals are not 

addressed. 

Testing, Inspection, and Examination: The 

NEMA standard addresses testing to assure that 

the cables perform as required. While aging of 

cables is addressed, synergistic effects of 

radiation, moisture, and temperature are not 

considered. Testing for processes other than 

manufacturing, such as receiving inspection, post 

installation, and during operation, are not 

addressed. Control of test equipment and 

personnel training is not addressed. Attributes such 

as program development, independent 

assessments, and verification, and test frequencies 

are not specifically identified. 

Design Requirements: The NEMA standards 

address most design requirements. However, 

nuclear plant accident conditions are not 

addressed.

43
Analysis: The standards reviewed are not 

significantly related to analyses. 

Design Verification: Testing as described 

above will provide verification of motor 

performance characteristics during normal 

operations. However, these tests do not address the 

requirements of environmental qualification. 

Design Control: The reviewed standards do 

not address design control attributes. 

Procurement: The reviewed standards could 

lead to development of procurement 

specifications. However, other procurement 

attributes such as control of vendors and approval 

of procurement documents are not addressed. 

Manufacturing: The NEMA standards 

provide many manufacturing details and tests to 

verify the design meets significant requirements. 

However, attributes related to control of the 

manufacturing process are not addressed. 

Shipping, Storage, and Handling: The 

standards reviewed do not address this process. 

Receipt: The standards reviewed do not 

address this process. 

Installation: IEEE 576 and 1185 and the NEC 

provide installation requirements including cable 

pulling requirements, protection of cables (conduit 

and cable trays), conduit fill requirements, and 

termination requirements. The NEC also addresses 

qualification of personnel. These standards address 

the significant attributes of this process. 

Monitoring: The standards reviewed do not 

address routine monitoring of cable conditions. 

Repair, Replacement, or Modification: The 

standards reviewed do not address repair, 

replacement, or modification. 

Maintenance: The standards reviewed do not 

address maintenance. 

Trending: The standards reviewed do not 

address trending of test results.

Corrective Action: The standards reviewed 

do not address corrective actions. 

4.29 Motor-Generator Units 

4.29.1 Commercial Standard 

The commercial standard reviewed was 

NEMA, Standards Publication MG2, "Safety 

Standard for Construction and Guide for Selection, 

Installation, and Use of Electric Motors and 

Generators," 1989. 

4.29.2 Special Treatment Requirements 

* 10 CFR 50, GDC 1, 2, and 4 and 

Appendix B 

* 10 CFR 50.49 

* 10 CFR 100, Appendix A 

4.29.3 Motor Generator Synopsis 

Motor generator components are subject to 

QA, seismic, possibly some EQ requirements, and 

GDC 1, 2, and 4. The commercial standard

NEMA, Standards Publication MG2, "Safety 

Standard for Construction and Guide for Selection, 

Installation, and Use of Electric Motors and 

Generators," 1989, was reviewed. There were little 

significant differences between the special 

treatment requirements and the commercial 

standard for the maintenance process. However, 

the maintenance process must be implemented by 

the plant procedures. There were significant 

differences between the other critical processes 

and the commercial standard. However, alternate 

QA programs and other plant processes could be 

used to provide reasonable confidence of 

functionality. 

4.29.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: Documentation is not 

addressed in this standard. 

Quality Assurance: Quality assurance is not 

addressed in this standard.

44
Procedures: Procedures are not addressed in 

this standard. 

Testing, Inspection, and Examination: 

Testing, inspection, and examination is discussed 

in the standard but not all the attributes are 

required. For example, qualified personnel and 

independent assessments are not addressed. 

Design Reauirements: The standard 

addresses design criteria but no detailed design 

requirements. 

Analysis: Analysis methods are not mentioned 

in the standard. 

Design Verification: Design verification is 

not mentioned in the standard. 

Design Control: Design control is not 

mentioned in the standard. 

Procurement: Procurement is not mentioned 

in the standard. 

Manufacturing: Construction and 

manufacturing of motor-generators are mentioned, 

but items such as personnel qualification, 

permitted materials, repair requirements, are not 

mentioned. 

Shipping. Storage, and Handlin : Shipping, 

storage, and handling is not mentioned in the 

standard. 

Receipt: Receipt of components is not 

mentioned in the standard. 

Installation: Installation is mentioned but not 

items like qualification of procedures and 

personnel. 

Monitoring: Monitoring of vibration, noise, 

periodic inspections and tests are recommended, 

but there is no requirement for root cause 

evaluation to identify and correct adverse 

conditions. 

Repair. Replacement, or Modification: 

Repair is mentioned in the standard, but only 

general concepts are discussed such as

"replacement part be of equal or better than that of 

the original part." Items such as verification and 

inspection of repair are not mentioned. 

Maintenance: Maintenance is mentioned in 

the standard with recommendations to use 

qualified personnel, qualified parts, etc. This meets 

the requirements of the process and attributes. 

Trending: Trending is not mentioned in the 

standard. 

Corrective Action: Corrective actions such as 

developing a program, feedback, obtaining input 

from trending, documenting performance and 

completing actions, and controlling backlog are 

not mentioned in the standard. 

4.30 Diesel Generators 

4.30.1 Commercial Standard 

The National Fire Protection Association, 

1999 Edition, Standard for Emergency and 

Standby Power Systems, NFPA 110, is the overall 

specification standard. This standard provides 

guidelines for the assembly, installation, and 

performance of electrical power systems to supply 

critical essential needs during outages of the 

primary power source. Several other 

subcomponent-specific standards are referenced, 

but are not addressed in this analysis. 

4.30.2 Special Treatment Requirements 

0 10 CFR 50, GDC 45 and 46, and 

Appendix B 

0 10 CFR 50.55a (ASME mI, IST, OM) 

* 10 CFR 100, Appendix A 

4.30.3 Diesel Generator Synopsis 

Diesel generator systems are typically 

designed to NFPA 110. At a nuclear facility, they 

are subject to the quality assurance, seismic, and 

pressure boundary requirements of ASME 

Section III and the in-service testing requirements 

of Section XI. Based on review of NFPA 110, 

commercial codes and standards may be used for

45
designing and testing, inspection, and examination 

of diesel generating systems. For example, 

NFPA 110 contains many testing requirements 

that are similar to the testing perfo,-: ?ýd at nuclear 

facilities. In addition, NFPA 110 intiudes 

equipment performance requirements for all parts 

of the diesel generator system (e.g., design 

performance requirements for the fuel supply 

system, instrumentation and alarms, diesel starting 

equipment, battery chargers, control equipment, 

cooling systems, and electrical generators and 

transfer switches). NFPA 110 also requires that 

diesel generators in seismic risk areas have 

components that are capable of performing their 

intended function during and after being subjected 

to the anticipated seismic shock. However, 

significant differences still exist between special 

treatment requirements and NFPA 110 for all other 

special treatment rule processes. Given that some 

of the remaining processes are critical for 

providing reasonable confidence of component 

functionality, NFPA 110 is not adequate to 

provide that confidence in all areas. However, 

other industry quality assurance programs and 

other plant processes may be used to provide the 

additional necessary confidence. 

4.30.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: In general, documentation 

requirements in NFPA 110 are limited to 

documenting the specifics associated with the 

acceptance testing, periodic testing, and post

maintenance testing. Instruction manuals are 

required to be located near the equipment. A 

routine maintenance and operational test program 

is required to be documented. Written records for 

inspections, test, exercising, operation, and repairs 

are to be maintained on the premises. 

Ouality Assurance: NFPA 110 does not 

include any requirements that address the quality 

assurance process associated with the design, 

procurement, or installation of diesel generators. 

Procedures: NFPA 110 requires that the 

routine maintenance and operation testing program 

be based on the manufacturer's recommendations, 

that one set of procedures be located near the

equipment, and that a second set of procedures be 

kept in a different secure location. NFPA 110 does 

not address the use of quality hold points. 

Testing, Inspection, and Examination: 

NFPA 110 specifies the full load acceptance test 

requirements, including the required test sequence, 

the parameters to be recorded, and acceptance 

criteria that must be met. The implementation of a 

routine maintenance and operation testing program 

is required immediately after the completion of the 

initial acceptance test program or after completion 

of any repairs that impact the unit's operational 

reliability. Sample maintenance schedules and 

testing logs are included in the standard. 

Therefore, no significant differences that would 

affect the reasonable confidence of component 

functionality were identified. 

Design Requirements: NFPA 110 includes 

extensive equipment performance requirements for 

all parts of the diesel generator system. For 

example, design performance requirements are 

specified for the fuel supply system, 

instrumentation and alarms, diesel starting 

equipment, battery chargers, control equipment, 

cooling systems, and electrical generators and 

transfer switches. In many cases, specific 

acceptance criteria are included. NFPA 110 

requires that diesel generators in seismic risk areas 

have components that are capable of performing 

their intended function during and after being 

subjected to the anticipated seismic shock. 

Therefore, no significant differences that would 

affect the reasonable confidence of component 

functionality were identified. 

Analysis: NFPA 110 does not include any 

personnel qualification or checking requirements 

related to the design, procurement, or installation 

of diesel generators. 

Design Verification: As noted in the Testing, 

Inspection, and Examination section, NFPA 110 

does include acceptance test requirements that 

serve to verify the design adequacy of the 

equipment. However, this type of testing does not 

verify if the diesel generator system will function 

during seismic events.

46
Design Control: NFPA 110 does not include 

any requirements that address the design control 

process associated with diesel generators. 

Procurement: NFPA 110 does not include 

any requirements that address the procurement 

process associated with diesel generators. 

Manufacturing: NFPA 110 does not include 

any requirements that address the manufacturing 

of diesel generators. 

Shipping, Storage, and Handling: NFPA 

110 does not include any requirements that address 

the shipping, storage, and handling processes 

associated with diesel generators. 

Receipt Inspection: NFPA 110 states that the 

manufacturer provides at least two sets of 

instruction manuals. Receipt inspections are not 

required, but system acceptance is based on load 

test performance. Inspections at the 

manufacturer's facility are not required. 

Installation: NFPA 110 includes several 

installation requirements for diesel generators. 

Some of these requirements address the equipment 

enclosure (heating, cooling, and ventilation), 

mounting requirements to minimize vibration, the 

diesel cooling system, the fuel system, and the 

exhaust system. However, the standard does not 

address personnel qualifications, welding and 

joining requirements, and alignment/joining 

requirements (some of these attributes may not be 

critical for a diesel generator set). 

Monitoring: NFPA 110 requires that periodic 

performance testing be performed and that 

unsatisfactory conditions and corrective actions be 

documented. However, root cause analysis and 

feedback of the root cause analysis results are not 

required. 

Repair, Replacement, or Modification: 

NFPA 110 does not include any requirements that 

address the repair, replacement, or modification of 

diesel generators except to require post

maintenance testing if the maintenance activity 

could affect system functionality.

Maintenance: NFPA 110 requires that a 

routine maintenance program be implemented 

immediately after the completion of the initial 

acceptance test program. NFPA 110 does not 

address the qualification of replacement parts. 

Trending: NFPA 110 does not include any 

requirements that address the performance 

trending of diesel generators. 

Corrective Action: NFPA 110 does not 

include any requirements to implement a 

corrective action program for diesel generators 

except that corrective actions should be 

documented. 

4.31 Batteries 

4.31.1 Commercial Standard 

IEEE 450 addresses maintenance, testing, and 

replacement of lead acid batteries; IEEE 484 

addresses design and installation; and IEEE 485 

focuses on sizing of batteries. These standards, 

when combined, cover the life cycle of batteries. 

4.31.2 Special Treatment Requirements 

* 10 CFR 50, GDC 1, 2, and 4, and 

Appendix B 

* 10 CFR 100 Appendix A 

4.31.3 Battery Synopsis 

Batteries are not typically located in areas that 

are subjected to accident conditions and, therefore, 

are not required to meet EQ requirements. 

However, batteries must meet the requirements of 

GDC 2, GDC 4, and QA. When special treatment 

requirements are compared to commercial codes 

and standards (IEEE 450, 484 and 485) there are 

significant differences in all processes except 

monitoring, repair, replacement, or modification, 

trending, and corrective action. IEEE 450 

addresses monitoring of battery performance and 

status. IEEE 450 addresses replacement of 

batteries. Batteries are not repaired or modified. 

The applicable attributes of the repair, 

replacement, or modification process are 

addressed. IEEE 450 addresses trending of test

47
results in order to provide sufficient time to 

procure replacement batteries. IEEE 450 also 

addresses corrective action for insufficient charge, 

unequal voltages, low electrolyte level, and poor 

connection resistance. 

4.31.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: The reviewed standards 

contain requirements to document the results of 

sizing, testing, and maintenance activities. 

Retrievability and retention of records are not 

addressed. 

Ouality Assurance: The reviewed standards 

do not address quality assurance programs. 

Procedures: Procedures and examples are 

provided in the IEEE standards for sizing, testing, 

and maintenance activities. However, procedures 

are not provided for manufacturing. Procedure 

control and approval are not addressed. 

Testing, Inspection, and Examination: IEEE 

450 addresses testing and inspection of batteries. 

Design verification, acceptance, and performance 

are covered by the tests and inspections of this 

standard. Testing to verify the ability to withstand 

seismic events is not included. Control of test 

equipment and personnel training is not addressed. 

Attributes such as program development, 

independent assessments, and verification, and test 

frequencies are not specifically identified. 

Design Requirements: IEEE 484 and 485 

address design requirements for battery sizing and 

installation. Seismic requirements for battery racks 

are addressed. Seismic requirements for the 

batteries are not addressed. 

Analysis: The standards reviewed are not 

significantly related to analyses. However, 

analyses related to sizing and testing is addressed. 

Analyses related to the design of the battery, such 

as seismic considerations, are not addressed. 

Design Verification: Testing as described 

above will provide verification of battery 

performance characteristics during normal

operations. However, these tests do not address 

seismic requirements of batteries, but do address 

seismic requirements of the battery racks. 

Design Control: The reviewed standards do 

not address design control attributes. 

Procurement: The reviewed standards could 

lead to development of procurement 

specifications. However, other procurement 

attributes, such as control of vendors and approval 

of procurement documents, are not addressed. 

Manufacturing: The reviewed standards do 

not address design control attributes. 

Shipping, Storage. and Handling: Handling 

and storage of batteries is addressed in IEEE 484. 

However shipping, procedures, and control of the 

processes are not addressed. 

Receipt: IEEE 484 identifies visual receiving 

inspections that should be performed. 

Identification of the documentation that should be 

included and control of this documentation is not 

addressed. 

Installation: IEEE 450 and 484 provide 

installation instructions regarding intercell 

connections, cable connections, rack assembly, 

cell mounting, freshening charges, and connection 

to the dc system. Control of procedures and 

qualification of personnel are not addressed. 

Monitorin : IEEE 450 addresses monitoring 

of battery performance and status. 

Repair, Replacement, or Modification: 

IEEE 450 addresses replacement of batteries. 

Batteries are not repaired or modified. The 

applicable attributes of this process are addressed. 

Maintenance: The standards reviewed do not 

address this process. 

Trending: Trending of test results is 

addressed by IEEE 450 in order to provide 

sufficient time to procure replacement batteries. 

Corrective Action: IEEE 450 addresses 

corrective action for insufficient charge, unequal

48
voltages, low electrolyte level, and poor 

connection resistance. 

4.32 Battery Chargers 

4.32.1 Commercial Standard 

IEEE 946 addresses design of dc auxiliary 

power systems and includes battery chargers in the 

scope of the standard. NEMA PE 5 addresses 

design and testing of battery chargers at the 

production facility. 

4.32.2 Special Treatment Requirements 

* 10 CFR 50, GDC 1, 2, and 4, and 

Appendix B 

* 10 CFR 100 Appendix A 

4.32.3 Battery Charger Synopsis 

Battery chargers are not typically located in 

areas that are subjected to accident conditions and, 

therefore, are not required to meet EQ 

requirements. However, battery chargers must 

meet the requirements of GDC 2, GDC 4, and QA. 

When special treatment requirements are 

compared to commercial codes and standards 

(IEEE 946 NEMA PE 5) there are significant 

differences in all processes except design 

requirements and design verification. The 

reviewed standards address design requirements 

for battery chargers. The standards address how 

many chargers are needed, determining the rated 

output, the ac input characteristics, the dc output 

characteristics, supervisory controls and alarms, 

environmental conditions including seismic 

events, and mechanical design. Testing as 

described in the standards will provide verification 

of battery charger performance characteristics 

during normal and unusual operations. While these 

tests do not specifically address seismic 

requirements, NEMA PE 5 states that design tests 

demonstrate that battery chargers conform to the 

PE 5 specifications, which does include seismic 

events.

4.32.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: NEMA PE 5 contains 

requirements for the content of instruction 

manuals. However, other types of documentation 

or control of documentation is not addressed in the 

reviewed standards. 

Ouality Assurance: The reviewed standards 

do not address quality assurance programs. 

Procedures: IEEE 946 provides specific 

formulas and sample calculations for determining 

the rating of the battery charger. However, 

procedures are not provided for manufacturing, 

installation, or testing. Procedure control and 

approval are not addressed. 

Testing. Inspection. and Examination: 

NEMA PE 5 addresses design and production 

testing. Testing to verify the ability to withstand 

seismic events is not specifically included. Testing 

during the installation and operational phase is not 

addressed by the reviewed standards. Control of 

test equipment and personnel training are not 

addressed. Attributes such as program 

development, independent assessments, and 

verification, and test frequencies are not 

specifically identified. 

Design Requirements: The reviewed 

standards address design requirements for battery 

chargers. The standards address how many 

chargers are needed, determining the rated output, 

the ac input characteristics, the dc output 

characteristics, supervisory controls and alarms, 

environmental conditions including seismic 

events, and mechanical design. 

Analysis: The standards reviewed are not 

significantly related to analyses. However, 

analyses related to sizing and testing is addressed. 

Analyses related to the design of the battery, such 

as seismic considerations, are not addressed. 

Design Verification: Testing as described 

above will provide verification of battery charger 

performance characteristics during normal and 

unusual operations. While these tests do not

49
specifically address seismic requirements, NEMA 

PE 5 states that design tests demonstrate that 

battery chargers conform to the PE 5 

specifications, which does include seismic events. 

Design Control: The reviewed standards do 

not address design control attributes. 

Procurement: The reviewed standards could 

lead to development of procurement 

specifications. However, other procurement 

attributes, such as control of vendors and approval 

of procurement documents are not addressed. 

Manufacturin : The reviewed standards do 

not address the manufacturing process. 

Shipping, Storage, and Handling: The 

reviewed standards do not address shipping, 

storage, and handling attributes. 

Receipt: The reviewed standards do not 

address the receipt process. 

Installation: The reviewed standards do not 

address the installation process. 

Monitorin : The reviewed standards do not 

address the monitoring process. 

Repair, Replacement, or Modification: The 

reviewed standards do not address repair, 

replacement, or modification of battery chargers. 

Maintenance: The reviewed standards do not 

address maintenance of battery chargers. 

Trending: The reviewed standards do not 

address the trending process. 

Corrective Action: The reviewed standards 

do not address the corrective action process. 

4.33 Inverters 

4.33.1 Commercial Standard 

UL-924 addresses design requirements, 

performance, and design and production testing of 

inverters. However, seismic considerations are not 

specifically addressed. UL-924 is primarily

concerned with features that affect the risk of fire, 

electric shock, or injury to people. 

4.33.2 Special Treatment Requirements 

* 10 CFR 50, GDC 1, 2, 4, and 10, and 

Appendix B 

* 10 CFR 100, Appendix A 

4.33.3 Inverter Synopsis 

Inverters are not typically located in areas that 

are subjected to accident conditions and, therefore, 

are not required to meet EQ requirements. 

However, inverters must meet the requirements of 

GDC 2, GDC 4, and QA. When special treatment 

requirements are compared to commercial codes 

and standards (UL-924) there are significant 

differences in all processes. UL-924 addresses 

design requirements, performance, and design and 

production testing of inverters. However, 

significant process attributes such as seismic 

considerations control of the processes are not 

addressed. UL-924 is primarily concerned with 

features that affect the risk of fire, electric shock, 

or injury to people. 

4.33.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: UL-924 contains 

requirements for the content of instruction 

manuals. However, other types of documentation 

or control of documentation are not addressed. 

Ouality Assurance: UL-924 does not address 

quality assurance programs. 

Procedures: UL-924 does not address 

procedures, procedure control, or procedure 

approval. 

Testing, Inspection, and Examination: UL

924 addresses manufacturing and production 

testing. Testing to verify the ability to withstand 

seismic events is not specifically included. Testing 

during the installation and operational phase is not 

addressed by the reviewed standards. Control of 

test equipment and personnel training is not

50
addressed. Attributes such as program 

development, independent assessments, and 

verification, and test frequencies are not identified. 

Design Requirements: Design requirements 

for performance and physical/mechanical 

considerations are provided by UL-924. However, 

seismic events are not discussed. 

Analysis: UL-924 does not address the 

analysis process for inverters. 

Design Verification: Testing as described 

above will provide verification of inverter 

performance characteristics during normal and 

some abnormal conditions. The tests described in 

UL-924 do not address seismic events. 

Design Control: UL-924 does not address 

design control attributes. 

Procurement: UL-924 could lead to 

development of procurement specifications. 

However, other procurement attributes, such as 

control of vendors and approval of procurement 

documents are not addressed. 

Manufacturin : Many construction details 

are addressed. Details include frame and enclosure 

considerations, mounting, corrosion resistance, 

insulation, mounting of piece parts, wiring, 

grounding, coil windings, transformers, self

diagnostics, printed circuit boards, and spacing. 

Procedures and control of the manufacturing 

process are not addressed. 

Shipping, Storage, and Handlin : The 

reviewed standard does not address shipping, 

storage, and handling attributes. 

Receipt: UL-924 does not address the receipt 

process. 

Installation: The reviewed standard does not 

address the installation process. 

Monitoring: The reviewed standard does not 

address the monitoring process.

Repair, Replacement, or Modification: UL

924 does not address repair, replacement, or 

modification of battery chargers. 

Maintenance: UL-924 does not address 

maintenance of battery chargers. 

Trending: The reviewed standard does not 

address the trending process. 

Corrective Action: The reviewed standard 

does not address the corrective action process. 

4.34 Process Instrumentation 

4.34.1 Commercial Standard 

ISA S37.6 addresses specification and tests for 

potentiometric pressure transducers. 

4.34.2 Special Treatment Requirements 

0 10 CFR 50.49 

* 10 CFR 50, GDC 1, 2,4, and 10, and 

Appendix B 

* 10 CFR 100, Appendix A 

4.34.3 Process Instrumentation Synopsis 

Process instrumentation is often located in 

areas that are subject to accident conditions and, 

therefore, must meet EQ requirements as well as 

the requirements of GDC 2, GDC 4, and QA. 

When special treatment requirements are 

compared to commercial codes and standards there 

are significant differences in all processes except 

design requirements and design verification. The 

commercial standard reviewed (ISA S37.6) 

provides comprehensive mechanical, electrical, 

and performance requirements. Qualification 

testing, including environments and 

vibration/seismic conditions, will provide 

verification of pressure transducer performance.

51
4.34.4 Commercial Standards 

Comparison with Nuclear 

Processes 

Documentation: The ISA standard provides 

test report forms. However, other types of 

documentation or control of documentation are not 

addressed. 

Quality Assurance: ISA S37.6 does not 

address quality assurance programs. 

Procedures: Testing is to be performed in 

accordance with procedures, and sample data 

sheets are provided. However, specific procedures, 

procedure control, or procedure approvals are not 

addressed. 

Testing, Inspection, and Examination: ISA 

S37.6 addresses acceptance tests and calibrations, 

qualification tests, and manufacturing and 

production testing. Testing during the installation 

and operational phase is not addressed. Control of 

test equipment and personnel training is not 

addressed. Attributes such as program 

development, independent assessments, and 

verification, and test frequencies are not identified. 

Design Requirements: Comprehensive 

mechanical, electrical, and performance 

requirements are provided. 

Analysis: The ISA standard does not address 

the analysis process. 

Design Verification: Qualification testing, 

including environments and vibration/seismic 

conditions, will provide verification of pressure 

transducer performance.

Design Control: ISA S37.6 does not address 

design control attributes. 

Procurement: ISA S37.6 could lead to 

development of procurement specifications. 

However, other procurement attributes, such as 

control of vendors and approval of procurement 

documents are not addressed. 

Manufacturing: ISA S37.6 does not address 

Manufacturing. 

Shipping, Storage, and Handline: The 

reviewed standard does not address shipping, 

storage, and handling attributes. 

Receipt: ISA S37.6 does not address the 

receipt process. 

Installation: The reviewed standard does not 

address the installation process. 

Monitoring: The reviewed standard does not 

address the monitoring process. 

Repair, Replacement, or Modification: 

ISA S37.6 does not address repair, replacement, or 

modification of pressure transducers. 

Maintenance: The reviewed standards do not 

address maintenance. 

Trending: The reviewed standard does not 

address the trending process. 

Corrective Action: The reviewed standard 

does not address the corrective action process.

52
5. SUMMARY AND CONCLUSIONS

5.1 Component Comparative 

Analysis Conclusions 

Section 4.0 highlights the existence of 

significant differences in nuclear processes and 

commercial standards for a number of 

components. We obtained the commercial codes 

and standards from discussions with vendors, 

standard specifications, and the knowledge and 

experience of the authors. We selected the most 

applicable commercial codes and standards for the 

individual components. For the components 

examined, the commercial codes and standards 

were not judged to provide a level of rigor 

equivalent to that provided by the nuclear special 

treatment rules. The evaluation showed that in 

most cases the commercial codes and standards 

focus on limited areas such as approved materials, 

welding procedures and qualification, etc., while 

neglecting the "big picture" as viewed from an 

overall systematic or project view. The application 

of ANSI B3 1.1 for piping design can be used as an 

illustrative example. B3 1. 1 provides requirements 

for acceptable materials, welding qualification and 

weld testing. However, this standard contains only 

the recommendation that a QA program be 

instituted and applied to the piping systems that 

might be constructed under its rules. The 

application of an overall QA program is not a 

requirement. 

Discussions with utility representatives 

combined with the information in Section 4.0 lead 

to the conclusion that commercial codes and 

standards alone do not provide the processes 

necessary to provide reasonable confidence of 

functionality. Several company representatives 

indicated that processes developed to implement 

nuclear codes, standards, and special treatment 

rules are selectively used for BOP equipment to 

provide reasonable confidence of functionality. 

In Table 2, an evaluation was made for each 

individual attribute as to whether the attribute was 

judged to be critical or noncritical to provide 

reasonable confidence of functionality. The 

evaluation is necessarily based on expert opinion. 

The definition of critical included not only that the

SSC would be functional, but also that reasonable 

confidence of functionality could be demonstrated. 

This exercise was very difficult because the 

outcome of the judgment might not be the same 

for every type of SSC, and one could propose a 

scenario or example where every attribute might 

be necessary to provide confidence of 

functionality. Nevertheless, a judgment was made 

for each, and the basis for the judgment was 

described in the right-hand column of the table. 

Seemingly almost identical attributes may have 

been judged critical in one process but not in 

another because of only slight differences in 

requirements and interpretation. The result was 

that 147 attributes were judged critical and 23 

were judged noncritical. 

The overall conclusions from Table 2 

(Appendix A) are that most of the attributes were 

judged critical and that commercial codes and 

standards by themselves were insufficient to 

provide reasonable confidence of SSC 

functionality. However, the critical attributes 

missing in commercial codes and standards could 

be supplied by (1) measures such as utilization of 

detailed engineering specifications, (2) plant 

processes and procedures, (3) multilevel QA 

programs that provide less rigor than 10 CFR 50, 

Appendix B, but augment commercial 

requirements, or (4) a combination of these 

approaches. Therefore, for the NRC to allow the 

nuclear industry to use commercial practices for 

procurement of replacement RISC-3 SSCs, they 

would have to rely heavily on the good judgment 

and internal processes of the nuclear plants, 

realizing that there may be minimal documentation 

or in-service test/inspection results to give 

reasonable confidence of functionality. 

The authors' general evaluation for the 18 

processes is as follows: 

For some mechanical components such as 

pumps and valves, there are ASME 

standards (such as B 16 and B73) which 

manufacturers commonly use for design 

requirements, analysis, and manufacturing 

(Processes 5, 6, and 10). Electrical

53
equipment is typically installed to standards 

such as the NEC. 

"* ISO 9001 or the utilities' own procedures 

are used to specify the degree of quality 

(processes 1, 2, 3, 8, 9, 11, and 12). 

"* The manufacturer's equipment manuals and 

national standards for some components are 

used for installation, inspection, testing, 

maintenance, and repair (processes 4, 13, 

15, and 16). 

"* Processes for which there seem to be no 

generally used commercial standards, 

procedures, or practices, unless indicated by 

a specific utility, are equipment 

qualification, monitoring, trending, and 

corrective action (processes 7, 14, 17, and 

18). 

5.2 Overall Project Conclusions 

(Includes All Tasks) 

5.2.1 State and Federal Requirements 

"* Nuclear safety-related SSCs are regulated 

by the special treatment rules. 

"* There are few actual commercial 

requirements to cover BOP equipment and 

processes. Most importantly, state laws 

(with the exception of South Carolina) 

require the use of the ASME Code for 

boilers and pressure vessels (e.g., B31.1, 

Section I, or Section VmI) and other 

pressure boundary equipment. 

"* Most Western states dictate the use of the 

UBC, which requires seismic analysis. 

Eastern states use the National Building 

Code, while Southern states use the 

Standard Building Code. The national 

building codes typically require some 

seismic analysis and could potentially 

provide an alternative for the seismic 

special treatment rules. However, use of 

these codes may result in a change to the 

design basis of the plant.

Most requirements and processes for BOP 

equipment are not implemented by state or 

federal law. Nuclear utilities visited 

typically apply commercially available 

standards and make limited use their own 

nuclear processes and manufacturers' 

recommendations to cover the BOP 

equipment. However, the authors note that 

these BOP practices may vary from plant to 

plant and should not be construed as 

equivalent to processes applied to safety

related components. 

There are no BOP equipment requirements 

for a quality assurance program, although 

ASME Code Sections I and VIII state 

quality requirements for boilers and 

pressure vessels, and associated external 

piping. Some engineering firms and 

equipment manufacturers use ISO 9001 as a 

quality assurance program basis for BOP 

equipment. As with all commercial 

standards not imposed by state and local 

laws or ordinances, compliance with 

ISO 9001 is voluntary. Use of this standard 

is not universal in the commercial industry 

and its implementation has been found to 

vary due to the variety of organizations 

responsible for certifying ISO 9001 

programs. 

Standards, such as ASME B 16.34, for 

manufacturing valves are not required to be 

used as long as the valves are used within 

the specified pressure-temperature ratings 

(see B31.1, Section 107). However, some 

BOP equipment manufacturers commonly 

use these standards. 

5.2.2 Commercial Practice 

* Commercial practice varies widely, from 

almost no processes for some industries to a 

higher quality of processes similar to, but 

not nearly as rigorous as those for nuclear 

safety-related equipment. 

* Since state or federal law does not cover 

most processes for BOP equipment, utilities 

use commercially available standards, or 

their own procedures and practices, or both

54
to cover many of the processes. 

Consequently, the processes may vary 

widely from plant to plant. 

There are no recommendations for BOP 

motor-operated valve (MOV) qualifications 

that correspond to the recommendations 

contained in Generic Letters (GL) 89-10 

and 96-05. Therefore, typical commercial 

practices do not focus on demonstration of 

MOV functionality under worst-case 

conditions and are not concerned with 

identifying MOV-related performance 

degradations that may affect the 

acceptability of established control switch 

settings. 

"* To minimize confusion, the two nuclear 

utilities we visited prefer to use many of the 

nuclear processes for BOP equipment. 

These utilities preferred not to introduce 

additional procedures or processes. 

"* SONGS and ComEd personnel indicated 

that plant processes developed from 10 CFR 

50, Appendix B are selectively used for 

some BOP equipment. The BOP processes 

are primarily driven by economic concerns, 

and therefore are typically less rigorous than 

those required for nuclear safety-related 

processes. For example, one utility used its 

plant modification control process to replace 

an office building HVAC unit. Clearly the 

controls on this replacement would be less 

than those used for a nuclear safety-related 

SSC, but greater than what would be 

required in the commercial world. 

5.2.3 Differences in Special Treatment 

Rules and Commercial Practice 

For the majority of the components 

evaluated, there were significant differences 

in the commercial standards and the special 

treatment rules. Many of the commercial 

standards do not require a QA program and 

were not developed to consider all of the 

life-cycle stages of an SSC. The standards 

were narrowly focused on one process such 

as design.

Many of the commercial standards are 

focused on design requirements, 

manufacturing or testing. Although the 

requirements are often different, there 

seemed to be little difference in providing 

reasonable confidence of functionality 

between commercial standards requirements 

and the special treatment rules for these 

processes. This does not mean that the 

requirements were the same, that there were 

no significant physical differences in 

nuclear and commercial products, or that 

commercial standards could be used without 

plant processes. Even in instances where 

there were no significant differences in a 

process, commercial standards may not be 

adequate and must be supplemented. For 

example, a commercial standard might 

adequately require the consideration of 

design requirements, but specific design 

conditions must be implemented by a 

detailed equipment specification. 

* The critical nature of some of the processes 

and attributes is component specific. For 

example, functional testing and design 

verification are much more important for 

active than for passive SSCs. 

5.2.4 Use of Commercial Codes, 

Standards, and Practices for 

RISC-3 SSCs 

"* Commercial standards by themselves are 

not adequate to provide reasonable 

confidence of functionality. Measures such 

as using a combination of detailed 

engineering specifications, plant processes 

and procedures, and multilevel QA 

programs that provide for less rigor than 

required for the full 10 CFR 50, Appendix 

B, but augment commercial requirements 

might be one potential way to establish 

reasonable confidence of functionality. 

"* Most of the attributes were found to be 

critical to establish reasonable confidence of 

SSC functionality. However, reasonable 

confidence could be achieved for most of 

the critical attributes with fewer 

requirements than stated in the special

55
treatment rules. This was true more for the 

attributes giving assurance of functionality 

such as documentation than for those that 

directly demonstrated functionality, such as 

SSC testing. Many of the special treatment 

rules are from 10 CFR 50, Appendix B, 

Quality Assurance. While some sort of 

quality program is needed for reasonable 

confidence of SSC functionality, a full 

Appendix B program does not seem to be 

warranted for RISC-3 SSCs. 

Plant processes will have a significant effect 

on providing reasonable confidence of 

component functionality, but the adequacy 

of the commercial standards and reduced 

plant processes would have to be evaluated 

on a plant-by-plant basis. It was beyond the 

scope of this project to evaluate the 

adequacy of BOP processes used by plants. 

Some utility personnel indicated that a form 

of commercial dedication for RISC-3 

components would be beneficial. They 

believed that using the original equipment 

manufacturer and operating history would 

give reasonable confidence of functionality 

of replacement parts or SSCs.

One attribute that was assumed to be in 

place and was judged very critical was the 

design specification. If this document 

includes detailed requirements (functional, 

environmental, loads, materials, quality, 

etc.), then it is much more likely that the 

correct product (manufactured according to 

the design requirements) will be selected. 

For example, if the design requirements 

state that an SOV must function in a 

radiation environment, then a commercially 

available SOV (which would probably have 

major physical differences from a nuclear 

SOV, including materials not designed for 

radiation environments) would not be 

selected. 

For the NRC to allow commercial practices 

to be used for procuring RISC-3 

replacement SSCs, the NRC would have to 

rely heavily on the good judgement of 

nuclear utilities and provide minimum 

requirements for the processes used. This 

may result in relatively little documentation 

or in-plant testing or inspections to give 

reasonable confidence of functionality when 

compared to nuclear processes.

56
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Edition, 1988. 

Tubular Exchanger Manufacturers Association, 

1999, Standards of the Tubular Exchanger 

Manufacturers Association (TEMA), Eighth 

Edition. 

Underwriters Laboratories, Inc., 1999, UL 

Standard for Safety Access Control System 

Units, Fifth Edition, UL-294. 

Underwriters Laboratories, Inc., 2000, "Molded

Case Circuit Breakers, Molded-Case Switches, 

and Circuit-Breaker Enclosures," UL-489. 

Underwriters Laboratories, Inc., 1999, UL 

Standard for Safety Underwater Fixtures,. 

Seventh Edition, UL-676. 

Underwriters Laboratories, Inc., 1995, UL 

Standard for Safety Lighting Fixtures for Use 

in Hazardous (Classified) Locations, Eleventh 

Edition, UL-844. 

Underwriters Laboratories, Inc., 1995, 

"Emergency Lighting and Power Equipment," 

UL-924. 

Underwriters Laboratories, 1986, "Test 

Performance of Air-Filter Units," "UL 900. 

Underwriters Laboratories, Inc., 2000, UL 

Standard for Safety Luminaires," First Edition, 

UL-1598. 

Underwriters Laboratories, Inc., 2000, "UL 

Standard for Safety Low Level Path Marking 

and Lighting System," Second Edition, UL

1994. 

United States Government, Code of Federal 

Regulations: 

10 CFR 50, Appendix A, "General Design 

Criteria for Nuclear Power Plants"

* 10 CFR 50, Appendix B, "Quality 

Assurance Criteria for Nuclear Power Plants 

and Fuel Reprocessing Plants" 

* 10 CFR 50, Appendix S, "Earthquake 

Engineering Criteria for Nuclear Power 

Plants" 

0 10 CFR 50.49, "Environmental 

Qualification of Electric Equipment 

Important to Safety for Nuclear Power 

Plants" 

0 10 CFR 50.55a, "Codes and Standards" 

& 10 CFR 100, "Reactor Site Criteria" 

0 10 CFR 100, Appendix A, "Seismic and 

Geological Criteria for Nuclear Power 

Plants." 

U.S. Nuclear Regulatory Commission, 1984, 

"Environmental Qualification of Certain 

Electrical Equipment Important to Safety for 

Nuclear Power Plants," RG 1.89. 

U.S. Nuclear Regulatory Commission, 1987, 

"Seismic Qualification of Electric and 

Mechanical Equipment for Nuclear Power 

Plants," RG 1. 100 (Draft EE 108-5, Proposed 

Revision 2). 

U.S. Nuclear Regulatory Commission, 1989, 

Generic Letter 89-10, "Safety-Related Motor

Operated Valve Testing and Surveillance 

(Generic Letter No. 89-10); Supplement 1, 

"Results of Public Workshops," 1990; 

Supplement 2, "Availability of Program 

Descriptions," 1990; Supplement 3, 

"Consideration of the Results of NRC

Sponsored Tests of Motor-Operated Valves," 

1990; Supplement 4, "Consideration of Valve 

Mispositioning in Boiling Water Reactors," 

1992; Supplement 5, "Inaccuracy of Motor

Operated Valve Diagnostic Equipment," 1993; 

Supplement 6, "Information on Schedule and 

Grouping, and Staff Responses to Additional 

Public Questions," 1994; Supplement 7, 

"Consideration of Valve Mispositioning in 

Pressurized-Water Reactors," 1996.

61
U.S. Nuclear Regulatory Commission, 1996, 

"Periodic Verification of Design-Basis 

Capability of Safety-Related Motor-Operated 

Valves," Generic Letter 96-05. 

U.S. Nuclear Regulatory Commission, 1997, 

"Standard Review Plan for the Review of 

Safety Analysis Reports for Nuclear Power 

Plants," NUREG-0800, Rev 4. 

U.S. Nuclear Regulatory Commission, 1998, 

Options for Risk-Informed Revisions to 10 

CFR Part 50 B, "Domestic Licensing of 

Production and Utilization Facilities," 

SECY-98-300. 

U.S. Nuclear Regulatory Commission, 1999, 

"Rulemaking Plan for Risk-Informing Special 

Treatment Requirements," SECY-99-256. 

U.S. Nuclear Regulatory Commission, 1973, 

Regulatory Guide 1.36, "Nonmetallic Thermal 

Insulation for Austenitic Stainless Steel." 

U.S. Nuclear Regulatory Commission, 1973, 

Regulatory Guide 1.43, "Control of Stainless 

Steel Weld Cladding of Low-Alloy Steel 

Components." 

U.S. Nuclear Regulatory Commission, 1973, 

Regulatory Guide 1.44, "Control of the Use of 

Sensitized Stainless Steel." 

U.S. Nuclear Regulatory Commission, 1973, 

Regulatory Guide 1.45, "Reactor Coolant 

Pressure Boundary Leakage Detection." 

U.S. Nuclear Regulatory Commission, 1973, 

Regulatory Guide 1.54, "Quality Assurance 

Requirements for Protective Coatings Applied 

to Water-Cooled Nuclear Power Plants." 

U.S. Nuclear Regulatory Commission, 1973, 

Regulatory Guide 1.60, "Design Response 

Spectra for Seismic Design of Nuclear Power 

Plants," Rev. 1. 

U.S. Nuclear Regulatory Commission, 1973, 

Regulatory Guide 1.61, "Damping Values for 

Seismic Design of Nuclear Power Plants."

U.S. Nuclear Regulatory Commission, 1973, 

Regulatory Guide 1.65, "Materials and 

Inspections for Reactor Vessel Closure Studs." 

U.S. Nuclear Regulatory Commission, 1975, 

Regulatory Guide 1.14, "Reactor Coolant 

Pump Flywheel Integrity," Rev. 1. 

U.S. Nuclear Regulatory Commission, 1976, 

Regulatory Guide 1.92, "Combining Modal 

Responses and Spatial Components in Seismic 

Response Analysis," Rev. I. 

U.S. Nuclear Regulatory Commission, 1977, 

Regulatory Guide 1.38, "Quality Assurance 

Requirements for Packaging, Shipping, 

Receiving, Storage, and Handling of Items for 

Water-Cooled Nuclear Power Plants," Rev. 2. 

U.S. Nuclear Regulatory Commission, 1977, 

Regulatory Guide 1.116, "Quality Assurance 

Requirements for Installation, Inspection, and 

Testing of Mechanical Equipment and 

Systems." 

U.S. Nuclear Regulatory Commission, 1978, 

Regulatory Guide 1.29, "Seismic Design 

Classification," Rev. 3. 

U.S. Nuclear Regulatory Commission, 1978, 

Regulatory Guide 1.31, "Control of Ferrite 

Content in Stainless Steel Weld Metal," 

Rev. 3. 

U.S. Nuclear Regulatory Commission, 1978, 

Regulatory Guide 1.33, "Quality Assurance 

Program Requirements (Operation)," Rev. 2. 

U.S. Nuclear Regulatory Commission, 1978, 

Regulatory Guide 1.52, "Design, Testing, and 

Maintenance Criteria for Postaccident 

Engineered-Safety-Feature Atmosphere 

Cleanup System Air Filtration and Adsorption 

Units of Light-Water-Cooled Nuclear Power 

Plants," Rev. 2. 

U.S. Nuclear Regulatory Commission, 1978, 

Regulatory Guide 1.122, "Development of 

Floor Design Response Spectra for Seismic 

Design of Floor-Supported Equipment or 

Components," Rev. 1.

62
U.S. Nuclear Regulatory Commission, 1981, 

Regulatory Guide 1.148, "Functional 

Specification for Active Valve Assemblies in 

Systems Important to Safety in Nuclear Power 

Plants." 

U.S. Nuclear Regulatory Commission, 1985, 

Regulatory Guide 1.28, "Quality Assurance 

Program Requirements (Design and 

Construction)," Rev. 3.

U.S. Nuclear Regulatory Commission, 1997, 

Regulatory Guide 1.12, "Nuclear Power Plant 

Instrumentation for Earthquakes," Rev. 2.

63
7. GLOSSARY

Attributes: the requirements that may be needed to 

complete the process. Each attribute cannot be 

broken logically into a smaller similar attribute, 

but may contain more than a single step or 

requirement. 

Commercial Dedication: process undertaken to 

provide reasonable confidence that a commercial 

grade item to be used as a basic component will 

perform its intended safety function and, in this 

respect, is deemed equivalent to an item designed 

and manufactured under a 10 CFR Part 50, 

Appendix B, quality assurance program. 

Commercial Practice: practice where components 

are specified, ordered, manufactured, delivered, 

installed, operated, tested/inspected, etc., at non

nuclear facilities and for BOP components at 

nuclear power plants. 

Critical Processes/Attributes: those requirements 

that (individually or jointly) are necessary to 

reasonably ensure functionality of a SSC. 

Noncritical Process/Attribute: provides a 

relatively small increase in the assurance of 

component functionality. 

Process: one of several steps needed to be carried 

out in completing the design, procurement, 

installation, or operation of an SSC.

Regulatory Attributes: those requirements of a 

process that ensure that one or more special 

treatment requirements are satisfied. 

Special Treatment Requirements: the 

requirements that are imposed on structures, 

systems, and components that go beyond industry

established requirements for equipment classified 

as commercial grade that provide additional 

confidence that the equipment is capable of 

meeting its functional requirements under design 

basis conditions. This review considered the 

following special treatment requirements: 

* 10 CFR 50.55a, [ASME BPV (Sections mI and 

XI), OM Codes, and generic letters related to 

Motor-Operated Valves (MOVs)]. 

* 10 CFR 50.49, (Environmental Qualification 

of electrical components) 

0 10 CFR Part 50 Appendix A, (GDC 1, 2, 4, 

45, and 46. 

* 10 CFR Part 50 Appendix B, (Quality 

Assurance 

* 10 CFR Part 50 Appendix S (Seismic) 

* 10 CFR Part 100 and Appendix A to Part 100 

(Seismic)

64
APPENDIX A 

TABLES
Table 1. Processes In Life-Cycle Stages' of a SSC. 

Design Stage Procurement Stage. Installation Stage Operation Stage 

1 Documentation 2 

2 Quality Assurance (QA) 2 

3 Procedures 2 

4 Testing, Inspection, and Examination 2 

5 Design Requirements 9 Procurement Initiation 13 Installation 14 Monitoring 

6 Analysis 10 Manufacturing 15 Repair, Replacement, or 

Modification 

7 Design Verification 11 Shipping, Handling[ Storage, and 16 Maintenance 

8 Design Control 12 Receipt Inspection 17 Trending 

18 Corrective Actions 

I. Decontamination & Decommissioning is another stage but is not being addressed because it is beyond the operating life of the SSC. 

2. These processes are common to all life-cycle stages of SSCs; however, some attributes may be unique to specific life-cycle stages.
Table 2. Critical Process/Attribute Evaluation. 

Regulatory (Nuclear) Regulatory Critical or 

Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis 

1 Documentation 

a Maintain sufficient IWA 6000 Critical Without sufficient appropriate records, qualification or applicability of SSC for intended records function cannot be demonstrated. 

50.49 (j) 

RG 1.89 

IEEE 323 

GDC I 

Part 50 App B 

B Type of records to be NCA-1000, 3000 Critical Without sufficient appropriate records, qualification or applicability of SSC for intended retained NB-3000 function cannot be demonstrated, 

NB/NC/ND-4000, 5000, 

7000, App V 

IST A, B & C OM-App I 

50,49 (j) 

RG 1.89 

IEEE 323 

GDC I 

Part 50 App B 

c Inspection records NB-2000 Critical Inspection records must contain the appropriate information (e.g., weld inspection data) to requirements support functionality of the SSC. 

IWA 4000, 6000 

IST A 

Part 50 App B 

d Records shall be IWA 6000 Critical Records must be identifiable and retrievable to properly support the documentation of SSC identifiable and functionality. 

retrievable IST A 

50,49 (0) 

RG 1.89 

IEEE 323 

Part 50 App B
Table 2. (continued). 

Regulatory (Nuclear) Regulatory ,Criticalor 

Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis 

e Record retention IWA 6000 Critical Records supporting the functionality of critical SSCs should be retained for the operating life 

requirements of the SSC to properly document functionality. 

IST A, B & C, OM-App I 

Part 50 App B 

RG 1.28 

f Documented IP&D Part 50 App B Critical Documented instructions, procedures, and drawings directly affect the consistent application of 

requirements. 

g Activities accomplished IWA 4000 Critical Accomplishing activities in accordance with documented instructions, procedures, and 

in accordance with drawings directly affect the consistent application of requirements. 

IP&D OM-App I 

Part 50 App B 

h Acceptance criteria OM-App I Critical Including acceptance criteria in IP&D provides a documented basis for critical parameters 

included in IP&D (e.g., bolt torquing requirements) that directly affect the SSC functionality. 

GL 89-10 d. 

Part 50 App B 

i IP&D issuance & Part 50 App B Critical Issuance of IP&Ds to the correct personnel ensures that critical information affecting the 

revision control confidence of SSC functionality is provided to the proper groups and personnel. 

j Document approval Part 50 App B Critical Issuance of IP&Ds to the correct review personnel ensures that IP&Ds contain critical 

information affecting the confidence of functionality. 

k IP&D distribution & Part 50 App B Critical Distribution of IP&Ds to the correct groups and personnel ensures that critical information 

location affecting the confidence of SSC functionality is provided to the necessary personnel and is 

readily available when needed. 

I IP&D change, review, & Part 50 App B Critical Controlling the IP&D revision, review, and approval process ensures that critical parameters 

approval are included and maintained. 

m Maintain Current SSC 50.55a(b)(3)(ii) Critical Maintenance of critical parameters (e.g., pressure relief set points) is crucial to the correct 

Setup Requirements GL 96-05 functioning of critical systems and components. 

Part 50 App B
Table 2. (continued).

Regulatory (Nuclear) Regulatory Critical or Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis 

2 Quality Assurance 

a Implement Quality NCA-4000, 8000 Critical An appropriate QA program will ensure that activities affecting the functionality of critical Assurance Program SSCs are performed in such a manner that functionality is preserved or enhanced. IST A Documentation of these activities serves to demonstrate the continued functionality. 

GDC I 

Part 50 App B 

RG 1.54, 1.116 

b Documented IP&Ds Part 50 App B Critical Documented instructions, procedures, and drawings directly affect the consistent application of 

requirements. c Coverage for life IST A Critical Records supporting the functionality of critical SSCs should be retained for the operating life 

of the SSC to properly document functionality. Part 50 App B 

d Identification (list) of IST A, B & C Critical Safe operation depends upon the identification of critical SSCs so that their design, covered SSCs procurement, qualification, installation, operation, maintenance, etc. are accomplished in a Part 50 App B manner such that SSC functionality is maintained. e Organizations involved Part 50 App B Critical All organizations that may be involved in the life cycle (e.g., design, analysis, procurement, identified operation, maintenance, etc.) of a critical SSC should be included in the coverag, F he QA plan. 

f Program approach with graded IWA 4000 Critical A maintaining graded approach ensures that the appropriate attention to detail is given to establih•; ind the functionality of critical SSCs. 

Part 50 App B 

g Activities accomplished Part 50 App B Critical Where necessary and/or appropriate, accomplishing activities affecting critical SSCs under 

under conditions controlled controlled conditions (e.g., leak rate testing) can be crucial to maintaining the functionality of the SSC. 

11 Special controls, Part 50 App B Critical The use of special controls and/or processes can be crucial to establishing and maintaining the processes, etc functionality of critical SSCs.

I Personnel 

training/qualification

j Management reviews

NCA-3000

IST A, OM-App I 

Part 50 App B r IPart 50 App B

Critical Proper training and qualification of personnel (e.g., reactor operators, maintenance personnel, etc.) directly affect the functionality of critical SSCs.

Noncritical Management review of activities affecting the functionality of critical SSCs is important. However, assuming that all other critical attributes are accomplished correctly, management 

review would contribute less to maintaining functionality.

I i
Table 2. (continued). 

Regulatory (Nuclear) Regulatory Critical or 

Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis 

k Planned and periodic NCA-3000 Critical The completion of audits on a regular schedule is important to identifying any breakdowns or audits weaknesses in activities affecting the functionality of critical SSCs. 

IST A 

Part 50 App B 

RG 1.28 

1 Audit performance IST A Critical The completion of audits on a regular schedule is important to identifying any breakdowns or weaknesses in activities affecting the functionality of critical SSCs. 

Part 50 App B 

m Documentation & IST A Noncritical Documentation and review of audit results are important. However, assuming that all other 

review of audit results critical attributes are accomplished correctly, the review of audit results could contribute a 

Part 50 App B lesser amount to maintaining functionality. 

n Follow-up action Part 50 App B Critical It is critical that follow-up actions be taken to maintain or restore the functionality of critical 

SSCs whenever the necessity for any such action is identified. 

o Quality Assurance Part 50 App B Critical The orgapization of the QA plan to include all appropriate personnel, organizations, and 

Organization activities has a direct effect on the functionality of the critical SSCs. 

3 Procedures 

a Describe activities Part 50 App B Critical Safe operation depends upon the identification of critical SSCs so their design, procurement, 

affecting quality qualification, installation, operation, maintenance, etc., are accomplished in a manner such that 

SSC functionality is maintained. 

b Require procedural Part 50 App B Critical Accomplishing activities in accordance with documented instructions, procedures, and 

control drawings directly affect the consistent application of requirements. 

c Include acceptance OM-App I Critical Including acceptance criteria in IP&Ds provides a documented basis for critical parameters 

criteria GL 89-10 d. (e.g., pipe wall thickness) that directly affects the SSC functionality. 

Part 50 App B 

d Ensure prerequisites are Part 50 App B Critical Ensuring prerequisite requirements (e.g., assembly order, test set-ups, etc.) are satisfied will 

met have a direct effect on the functionality of some critical components. 

e Include quality hold Part 50 App B Critical Provision of quality assurance inspection hold points in procedures is a critical step in 

points providing a high level of confidence in component functionality.
Table 2. (continued). -r Regulatory (Nuclear) 

Special Treatment 

Processes and Attributes

4 Testing, Inspection, 

and Examination 

(T/I/E)2 

a Identify T/I/E program 

scope 

b Develop T/I/E program 

c Qualified T/l/E 

personnel

Regulatory 

Requirements and 

Guidelines

Critical or 

Noncritical

IT EvaluationnI fQ V o~vaun' nass D: 

NCA-5000 Critical

IWA 2000 

RG 1.65 

IST A, B & C, OM-App I 

GL 89-10 c. 

Part 50 App B 

IWA 2000 

IST A, B & C, OM-App I 

& II 

GL 89-10 c. 

50.55a(b)(3)(ii) 

GL 96-05 

GDC I 

Part 50 App B 

NB/NC/ND-5000 

IWA 2000 

IST A, OM-App I 

Part 50 App B

Critical 

Critical

The identification of the T/I/E program scope is important to ensure that all of the necessary 

components are included and receive the tests, inspections, and examinations that are necessary for reasonable confidence of component functionality. 

The development of the T/I/E program is critical to ensuring that the proper actions are applied to the plant components. The program establishes the requirements and identifies those 

departments thai are responsible for completion of the requirements. However, not all of the 

special treatment requirements for program development are necessary for RISC-3 

components. For example, the program requirements/responsibilities may be located in 

several existing documents instead of being organized into a separate, stand-alone document. 

Unqualified personnel may incorrectly assess component functionality. However, some of the administrative requirements contained in the special treatment rules could be reduced. For 

example, some of the training record retention requirements could be reduced or removed.

S............ ,I-• Y ai Utll.lUIl Di•l•l•
Table 2. (continued). 

Regulatory (Nuclear) Regulatory Critical or 

Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis 

d T/IlE methods identified NB/NC/ND-2000 Critical Having the most effective T/I/E methods identified in the program requirements ensures they are used and provide reasonable confidence of component functionality. IWA 2000 

IST B & C, OM-App I & II 

GL 89-10 c. & f. 

Part 50 App B 

GDC 45 & 46 

e Inspectors perform IWA 2000 Noncritical As long as qualified personnel perform the assessments, having the worker perform the 

independent assessments assessment would have a small effect on reasonable confidence of component functionality. 

IST A, OM-App I 

Part 50 App B ___ 

f Tests performed IAW IST A & B, OM-App I Critical Procedural compliance is critical for ensuring that tests effectively determine component procedures functionality. Therefore, complying with procedures is necessary for providing reasonable 

Part 50 App B confidence of component functionality. 

g Verify each operation Part 50 App B Critical Verifying test results provides assurance that the test conclusions provide reasonable 

where quality is confidence of component functionality. 

necessary 

h Control of test NCA-3000 Critical Improperly controlled test equipment could have a direct effect on the assurance of component 

equipment NB/NC/ND-6000 functionality. 

IST B & C, OM-App I 

Part 50 App B 

i Verify proper IST B & C, OM-App I Critical Proper component installation is critical to component functionality. 

installation 

Part 50 App B 

j Verify specified IST B, OM-App II Critical Verifying component characteristics is important to maintaining reasonable confidence of 

characteristics are component functionality. 

maintained Part 50 App B 

k Preoperational/ IST B & C, OM-App I Critical Testing is important for providing reasonable confidence of component functionality. 

preservice tests Part 50 App B ______________________________________
Table 2. (continued). 

Regulatory (Nuclear) 

Special Treatment 

Processes and Attributes 

I Pressure tests 

in Operational/!Inservice 

tests 

n Design-basis tests

Regulatory 

Requirements and 

Guidelines

NB/NC/ND-3000, 6000 

IWA 5000 

IST C 

Part 50 App B 

GDC 45 & 46 

RG 1.12, 1.14, 1.52 

IST A, B & C OM-App I 

&II 

Part 50 App B 

50.55a(b)(3)(ii) 

GL 96-05 

NB/NC/ND-2000, 5000

GL 89-10 c.

Part 50 App B 

o Post maintenance tests IST B & C OM-App I

GL 89-10 f.

Part 50 App B 

p Document & evaluate IST B & C 

test results OM-App I & 11

GL 89-10 c. 

50.55a(b)(3)(ii) 

GL 96-05

I I Part 50 App B

Critical or 

Noncritical

nvaiuauon

Critical

Critical 

Critical 

Critical 

Critical

00

E~valuation Evaluation Basis 

Testing is important for providing reasonable confidence of component functionality. 

Testing is important for providing reasonable confidence of component functionality. 

Testing is important for providing reasonable confidence of component functionality. 

Testing is important for providing reasonable confidence of component functionality. 

Proper evaluation of test results is important for providing reasonable confidence of 

component functionality.
Table 2. (continued). 

Regulatory (Nuclear) Regulatory Critical or 

Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis 

q Acceptance criteria Section III App VI, Critical Acceptance criteria are needed for proper evaluation of test results and are important for 

NB/NC/ND-5000 providing reasonable confidence of component functionality. 

IWA 3000 

IST B & C, OM-App I 

50.55a(b)(3)(ii) 

GL 96-05 

GL 89-10 c. 

Part 50 App B 

r Flaw characterization IWA 3000 Critical Flaw evaluations are necessary corrective actions to assure functionality. 

Part 50 App B 

s Evaluate retest IST B & C Noncritical Evaluating retesi frequencies has a small effect on the assurance of component functionality. frequencies OM-App I & II 

Part 50 App B 

t T/T/E frequencies IST A, B & C, OM-App I Critical Identification of T/lI/E frequencies is necessary to ensure that functional verifications occur at identified & II the proper intervals before degradation causes a component to be inoperable. Therefore, 

performing actions at the proper frequency provides reasonable confidence of component 

functionality. 

u T/lIE parameters IST A, B & C, OM-App I Critical Identification of T/I/E parameters ensures that the characteristics associated with component identified functionality are verified. Therefore, this action provides reasonable confidence of component 

functionality. 

v Corrective action IST B & C, OM-App I Critical Taking proper corrective actions is important for providing reasonable confidence of 

component functionality. 

50.55a(b)(3)(ii) 

GL 96-05
Table 2. (continued). 

Regulatory (Nuclear) 

Special Treatment 

Processes and Attributes 

5 Design Requirements 

a. Design specification 

b Performance 

requirements 

c Normal operating 

conditions 

d Accident conditions

Regulatory 

Requirements and 

Guidelines

Critical or 

Noncritical 

Evaluation

NCA-3000, App XXIII Critical

IWA 4000 

GDC 1 

Part 50 App B 

NB/NC/ND-7000 

RG 1.45, 1.52, 1.148, 1.14 

1.12 

Part 50 App B 

NB/NC/ND-3000 

GDC 2 & 4 

NB/NC/ND-3000

GDC 2 & 4 

e Natural phenomena NB/NC/ND-3000

f Seismic input spectra

GDC 2 

Part 50 App S 

RG 1.29 

100.23(d) 

Part 100 App A 

Part 50 App S 

RGI.60, 1.122 

100.23(c) 

100.23(d)

Critical 

Critical 

Critical 

Critical 

Noncritical

Part too App A 

g Loads NCA-2000 Critical 

NB/NC/ND-3000 

Part 50 App S Part 100 App A

Evaluation Basis 

There 

component. should Professional be a design specification to identify the operating requirements for the Engineer certification is not critical. 

The design specification should list the performance requirements to ensure functionality. 

The design specification should list the normal operating conditions to ensure functionality. 

The design specification should list the accident conditions to ensure functionality if operation 

of the component is required during and subsequent to the accident. 

The design specification should list the accident conditions to ensure functionality if operation of the component is required during and subsequent to the accident. 

The alternative component can be analyzed using an equivalent static method that is a conservative to dynamic methods in which a spectrum is needed. 

The design specification should list the loading requirements to provide reasonable confidence 

of component functionality.
Table 2. (continued). 

Regulatory (Nuclear) Regulatory Critical or 

Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis 

h Acceptance criteria NB/NC/ND-3000 Critical The design specification should list the acceptance criteria to provide confidence of component 

functionality. 

Part 50 App B 

i Quality Standards Part 50 App B Critical Quality requirements to ensure functionality should be specified in plant procedures or 

documents. 

j Inspection and test NB/NC/ND-3000, 7000 Critical This attribute would only be noncritical if inspection and testing were not required for the 

capability component. 

IST A, B & C 

GDC 45 & 46 

k Operating Limits IST B Critical The pump manufacturer's design limits should be included in the test procedures. 

6 Analysis 

a Personnel qualification OM-App I Critical However, the analysis does not necessarily have to be performed by a Professional Engineer to 

Sect. III APP XXIII provide confidence of component functionality. 

Part 50 App B 

b Checking and Part 50 App B Critical An independent analysis review by a separate reviewer is needed to ensure that the analysis is 

independent verification correct. 

c Safety Assurance NB/NC/ND-3000 Critical Corrosion allowances and analyses are needed. 

Part 50 App B 

Part 50 App S 

d Functionality Assurance RG 1.89 Critical Functionality assurance is needed to provide reasonable confidence of component IEEE 323 functionality. 

Part 50 App B 

Part 50 App S 

Part 100 App A

,>
Table 2. (continued). 

Regulatory (Nuclear) 

Special Treatment 

Processes and Attributes 

e Type of analysis 

f Acceptance criteria 

7 Design Verification 

a List of covered equip 

b Environmental 

conditions 

c Dynamic effects

Regulatory 

Requirements and 

Guidelines 

NB-3000, APP II 

OM-App 11 

Part 50 App S RG 1.60, 1,61, 1.92 

Part 100 App A 

NB/NC/ND-3000 

IST B & C 

Part 50 App B 

50.49 (d) 

RG 1.89, App E 

IEEE 323 

Part 50 App B 

NB/NC/ND-3000 

50.49 (e) 

GDC 4 

RG 1.52; 1.89 

IEEE 323 

Part 50 App B 

NB/NC/ND-3000

GDC 4 

RG 1.45;1.89

IEE~E 323 

Part 50 App B 

Part 50 App S 

Part 100 App A

Critical or 

Noncritical 

Evaluation 

Critical

Evaluation Basis 

The type of analysis should be compatible with the component and loads analyzed.

Critical Meeting allowable limits is critical.

Critical The covered equipment should be identified.

Critical The environmental conditions to be tested should be identified.

Critical The dynamic effects to be tested should be identified.
Table 2. (continued). 

Regulatory (Nuclear) Regulatory Critical or 

Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis 

d Natural Phenomena NB/NC/ND-3000 Critical The natural phenomena to be tested should be identified. 

GDC 2 

RG 1.100 

IEEE 344 

Part 50 App B 

Part 100 App A 

e Test procedures, plans, RG 1.89 Critical A test plan is critical. 

and profiles IEEE 323 

RG 1.100 

IEEE 344 

Part 50 App B 

Part 100 App A 

f Test identical under NB/NC/ND-7000 Noncritical Since j is the minimal alternative, this item is noncritical. 

identical conditions 

Or GL 89-10 c. 

50 49 (f)(1) 

RG 1.89 

IEEE 323 

RG 1.100 

IEEE 344 

Part 50 App B 

Part 100 App A
Table 2. (continued). 

Regulatory (Nuclear) 

Special Treatment 

Processes and Attributes 

g Test identical equipment 

under similar conditions 

Or 

h Test similar equipment 

with supporting analysis 

Or 

i Verify by experience 

with supporting analysis 

Or

Regulatory 

Requirements and 

Guidelines 

GL 89-10 c. 

50.49 (f)(l) 

RG 1.89 

IEEE 323 

RG 1.100 

IEEE 344 

Part 50 App B 

Part 100 App A 

GL 89-10 f. 

50 49 (0(2) 

RG 1.89 

IEEE 323 

1.100 

IEEE 344 

Part 50 App B 

Part 100 AU A 

GL 89-10 f. 

50.49 (0(3) 

RG 1.89 

IEEE 323 

RG 1.100 

IEEE 344 

Part 50 App B 

Part 100 App A

Critical or 

Noncritical 

Evaluation 

Noncritical

Evaluation Basis 

Since j is the minimal alternative, this item is noncritical.

Noncritical Since j is the minimal alternative, this item is noncritical.

Noncritical Sincej is the minimal alternative, this item is noncritical.
Table 2. (continued). 

Regulatory (Nuclear) Regulatory Critical or 

Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis 

j Verify using analysis in 50 49 (0(4) Critical Since this is the lowest level qualification method, it is critical for establishing reasonable 

combination with partial RG 1.89 confidence that the SSC will function during the specified conditions. 

type test data IEEE 323 

RGI.100 

IEEE 344 

Part 50 App B 

Part 100 App A 

k Continuing qualification 50.55a(b)(3)(ii) Critical If components have not been verified to their full design life, continuing qualification is 

GL 96-05 needed. 

RG 1.89 

IEEE 323 

Part 50 App B 

I Modifications during RG 1.89 Critical Control of modifications during qualification is needed to ensure like-for-like is being tested. 

qualification IEEE 323 

Part 50 App B 

8 Design Control 

a Regulatory requirements Part 50 App B III Critical Including regulatory requirements, design bases, and acceptance criteria in IP&Ds provides a and design bases in documented basis for critical parameters (e.g., pipe wall thickness) that directly affects the 

IP&Ds SSC functionality. 

b Quality standards GDC 1 Critical Specification of the applicable quality standards has a direct effect on ensuring the 

specified Part 50 App B functionality of an SSC design. 

c Applicability of Part 50 App B Critical Use of correct and appropriate materials, parts, and equipment has a direct effect on the 

materials, parts, functionality of critical SSCs. 

equipment, and 

processes assured 

d Design interfaces and Part 50 App B Critical All appropriate disciplines (e.g., operations, maintenance, structural analysis, thermal

coordination ensured hydraulics, etc.) must be included in the design process to ensure the intended function and 

continued functionality of critical SSCs. 

e Design verification GL 89-10 c. Critical Design verification makes a direct contribution to the functionality of critical SSCs by 

ensuring that all critical parameters have been considered in the design and all specified GDC I acceptance criteria are met. 

Part 50 App B

,>
Table 2. (continued).

Regulatory (Nuclear) 

Special Treatment 

Processes and Attributes 

f Verification 

independence 

g Prototype testing 

conditions 

h Design control 

applicability 

i Design change control

Regulatory 

Requirements and 

Guidelines 

Part 50 App B

Critical or 

Noncritical 

Evaluation 

Noncritical

Part 50 App B Critical

Part 50 App B Critical

Part 50 App B Critical

j Personnel qualification i Part 50 App B I Critical

k Software qualification Part 50 App B I Noncritical

9 Procurement Initiation

Evaluation Basis 

Complete independence of the person or team performing the design verification can be a valuable contributor to increasing the confidence in a design. However, this attribute contributes less to ensuring functionality assuming that all other aspects of the procedural control and quality program are followed. 

Selection and application of the appropriate test conditions have a direct effect in demonstrating the functionality of critical SSCs. 

Design control of critical SSCs is crucial in preventing unapproved and undocumented design changes and/or component modifications that would have a direct effect on functionality. 

Controlling the design revision, review and approval process ensures that critical parameters are considered and appropriately included in the revised design. 

Proper training and qualification of personnel (e.g., reactor operators, maintenance personnel, design analysts, etc.) directly affects the functionality of critical SSCs. 

Software appropriate to the design function (e.g., piping analysis) should be used. However, this attribute contributes less to ensuring functionality assuming that all other aspects (e.g., design vefificati6n) of the procedural control and quality program are followed. For example, alternate methods such as utilization of hand calculations or verification of results by use of an alternate computer code (e.g., use of ANSYS to verify ABAQUS results) are well known accepted methods to demonstrate software qualification.

a Approved specification Part 50 App B Critical A specification is necessary to augment many standards and codes for specific application at a 

plant. Specific component requirements for temperature and pressure would be contained in the specification. Approvals, review requirements, etc. required by Appendix B would need to be less rigorous for low risk components. b Specifies 

equipment 

qualified Part 50 App B Critical Qualified equipment may be necessary for applications such as seismic, EQ, pressure boundary components. Less rigor could be used for appendix components. For example, 

pressure boundary components may not need to be "N" stamped. c Vendor Qualification Part 50 App B Critical Vendor qualification was mentioned as being critical in providing reasonable confidence of 

functionality for some components. Less rigor could be used for appendix components. For 

d Reference design and Part 50 App B Noncritical example, pressure boundary components may not need to be "N" stam ed. 

regulatory bases 

Just referencing the bases is not sufficient to affect reasonable confidence of functionality. The component specification can require seismic and other special treatment requirement 

conditions. e Contractors/vendors Part 50 App B Noncritical Other quality assurance programs can help provide reasonable confidence of component App B program functionality.

,>
Table 2. (continued). 

Regulatory (Nuclear) Regulatory Critical or 

Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis 

f Equipment/material/ Part 50 App B Critical Equipment not complying with the specification may not operate under accident conditions. 

services compliance For low risk components less strict compliance with the specification should be allowed. 

with specifications 

g Source evaluation and Part 50 App B Critical Source or vendor evaluation and selection may be necessary to provide reasonable confidence 

selection of functionality for some components such as bolting, elastomers, and flanges as indicated by some vendors (CCI Valves and ASCO Valve). For low risk components, less rigor in source and vendor evaluation could be allowed. 

h Evidence of quality Part 50 App B Critical Some evidence of quality should be supplied, but for low risk components less rigor should be 

furnished required. 

10 Manufacturing 

a Inspection Part 50 App B Critical Inspection during manufacture is necessary to provide reasonable confidence of component 

points/procedures functionality. 

b Material control and NCA-3000 Critical Acceptable material control is required to assure reasonable functionality. Material 

certification certification may be less stringent than required by the special treatment rules to provide 

Part 50 App B reasonable confidence of component functionality. 

c Quality and Dimensional NB/NC/ND-3000 Critical Quality and dimensional standards should be applied in the manufacturing process. 

Standards 

GDC I 

Part 50 App B 

d Personnel qualification NB/NC/ND-4000 Critical Qualification of personnel welding and assembling components is necessary for providing 

reasonable confidence of component functionality. Part 50 App B 

e Permitted materials NCA-1000 Critical The materials used must be controlled to provide reasonable confidence of component 

NB/NC/ND-2000 functionality. 

RG 1.36, 1.65, 1.14, 1.31 

Part 50 App B 

f Material processes NB/NC/ND-2000, 4000 Critical The material processes used must be controlled to provide reasonable confidence of 

component functionality. 

RG 1.44 

Part 50 App B
Table 2. (continued).

Regulatory (Nuclear) 

Special Treatment 

Processes and Attributes

g Welding and joining 

lh Configuration 

i Alignment and 

tolerances

j Repair requirements

k Properly marked

Regulatory 

Requirements and

Guidelines I -valuation Basis

NCA-3000 

NB/NCIND-4000 

RG 1.34, 1.43 

Part 50 App B 

NB/NC/ND-3000, 4000, 

App XI 

Part 50 App B 

NB/NC/ND-4000

I Part 50 App B

NB/NC/ND-2000

Part 50 App B 

NCA-8000, 3000 

NB/NC/ND-3000, 4000, 

7000

Part 50 App B 

I Periodic QC assessment Part 50 App B

m Property control 

measures 

n Nonconforming items 

o Acceptance testing

Critical or 

Noncritical 

punhzatt;n

Critical 

Critical 

Critical

Critical 

Critical 

'Critical

Part 50 App B Critical

NCA-3000 

Part 50 App B 

ISTB &C

Critical 

Noncritical

___________________ rvaiuarion iiasis

The welding and joining used must be controlled to provide reasonable confidence of 

component functionality. 

Components must be configured and aligned properly to provide reasonable confidence of 

component functionality. 

Parts must be alignment and assembled correctly to provide reasonable confidence of 

component functionality. 

Parts must be repaired correctly to provide reasonable confidence of component functionality. 

The parts must be identified, but the marking may be less stringent than required by the special treatment rules. For example, the component can be marked other than by an ASME nameplate. 

Periodic audits of the vendor's QA program provide the owner confidence that the components are being manufactured properly. 

Control of material and parts is important to ensure that the component is manufactured 

pro enrly 

Nonconforming items should not be used. 

OMa-l1988, Part 6, paragraph 7.1 (Pumps), and Part 10, paragraph 6.1, requires the owner to obtain a copy of the manufacturer's test report "if available." Since the testing reports are to be supplied "if available," this offers only a small increase in assurance.

,>
Table 2. (continued). 

Regulatory (Nuclear) Regulatory Critical or 

Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis 

11 Shipping, Storage, and 

Handling (S/S/H) 

a Control S/S/H Part 50 App B Critical Not controlling S/S/H could lead to a degradation of the component. Less requirements and 

documentation could be allowed for low risk components. 

RG 1.38 

b S/S/H per procedures Part 50 App B Critical Some components require special shipping, storage, or handling requirements to maintain 

functionality. For example, some lubricants have specified shelf life. These lubricants may be 

necessary to ensure functionality of components such as motor-operated valves. These 

requirements could be reduced for low risk components. 

c Special protective Part 50 App B Critical Protective environments are necessary for functionality for some components, for example, environments components can oxidize (rust). Less rigor in these requirements could be allowed for low risk 

components. 

d Lockout/tagout Part 50 App B Noncritical Lockout/tagout generally is used to protect personnel and is less likely used to protect 

equipment. 

e Identification and Part 50 App B Critical Because of the difference in some commercial components compared with nuclear grade control of material, components, identification and control or material and parts are critical. Vendors (ASCO, 

parts, and components Barton) indicated that there was a significant difference between nuclear and non-nuclear 

components. However, less rigor could be required for low risk components. 

f Maintain traceability Part 50 App B Critical Traceability documentation of a part is critical to prove a material source, part heat treatment, 

testing, inspection, and other attributes necessary to assure functionality. Less rigorous and 

detailed traceability documentation may be needed for low risk components. 

g Measures designed to Part 50 App B Critical Measures to control shelf life are necessary to assure defective parts are not used. Less rigor 

prevent use of incorrect and control could be allowed for low risk components. 

or defective material, 

parts, or components 

h Maintain components Part 50 App B Critical See 11g. 

and equipment in 

qualified condition 

i Parts inventory control Part 50 App B Critical Parts control is similar to I lc above in that inventory control is related to component storage 

I Ienvironment that may be necessary for component functionality. 

j Consumable control Part 50 App B Critical Items such as grease or oil should be controlled since these lubricants will affect reasonable 

confidence of component functionality. Low risk components may require rigor for control of 

consumable items.
Table 2. (continued). 

Regulatory (Nuclear) Regulatory Special Treatment Requirements and 

Processes and Attributes Guidelines 

12 Receipt Inspection 

a Documentation included Part 50 App B

b Inspection at 

manufacturer's facility

Part 50 App B

c Receipt examination OM-App I

d Procurement 

requirements on site 

before installation 

e Specification 

requirements retained at 

plant site 

13 Installation 

a Standards (industry, 

quality) 

b Qualification of 

procedures and 

personnel 

c Welding and joining 

d Alignment and 

tolerances

e Configuration

Part 50 App B 

Part 50 App B

Critical or 

Noncritical 

Evaluation Evaluation Basis 

Critical Documentation is necessary to provide assurance that a component will meet the specified requirements. For low-risk components, the documentation requirements could be reduced. 

Noncritical Inspection at the manufacturer's facility is not necessary to assure reasonable confidence of component functionality since an installation test could be used. Inspection at a manufacturer's facility may be a financial issue in that installation of a faulty component could 

be costly. 

Critical Receipt examination is necessary to assure the part is as ordered and not damaged in shipping. 

Rigor could be reduced for low risk components.

Noncritical

Part 50 App B Noncritical

GDC I 

Part 50 App B 

Part 50 App B

NCA-3000 

NB/NC/ND-4000 

RG 1.34, 1.43 

Part 50 App B 

NB/NC/ND-4000

NB/NC/ND-3000, 4000, 

App XT

RG 1.12

Noncritical 

Critical

Critical 

Critical 

Critical

Having every piece of paper on-site before the component can be installed is not necessary for reasonable confidence of component functionality. Assurance of component quality and manufacturing attributes could be supplied in other ways. For example, a catalog number may indicate component capability to meet design conditions. 

Specification requirements could be maintained anywhere.

Industry standards alone do not provide reasonable confidence of component functionality. A specification or vendor recommendations may be more important than a standard. 

Adequately qualified and trained personnel and qualified procedures are necessary to provide reasonable confidence of component functionality. Plants should have more flexibility on the use of a qualified procedure and personnel for low risk components. 

Qualified procedures and personnel are necessary to provide reasonable confidence of functionality for welding and joining operations. Strict adherence to the ASME Code may not be necessary for low risk components. 

Adequate alignment and tolerances are necessary to assure that equipment will operate. Alignment and tolerance documentation and requirements could be relaxed for low.risk components. 

Maintaining the correct size valve operator, proper size motors, etc. is necessary to provide reasonable confidence of component functionality. Reduced rigor in configuration control could be allowed for low risk components.

,>.

Part 50 App B
Table 2. (continued). 

Regulatory (Nuclear) Regulatory Critical or 

Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis 

14 Monitoring 

a Maintain SSC IST B & C Critical Maintaining component performance requirements is important for reasonable confidence of 

performance component functionality. 

requirements 50.55a(b)(3)(ii) 

GL 96-05 

Part 50 App B 

b Determine SSC IST B & C Critical It is important to know what factors affect component performance and the rate at which 

performance OM-App II performance degrades to provide reasonable confidence of component functionality. 

degradations 

50.55a(b)(3)(ii) 

GL 96-05 

Part 50 App B 

c Identify & correct IST C Critical Implementing corrective actions can significantly affect the reasonable confidence of 

conditions adverse to component functionality. 

operability 50.55a(b)(3)(ii) 

OL 96-05 

Part 50 App B 

d Determine/correct root IST C, OM-App II Critical Implementing a corrective action based on a root cause analysis can significantly affect the or apparent cause to reasonable confidence of component functionality. 

prevent reoccurrence 50.55a(b)(3)(ii) 

GL 96-05 

Part 50 App B 

e Document root or 50.55a(b)(3)(ii) Noncritical As long as root causes are identified and corrective actions are implemented, documenting 

apparent cause & report GL 96-05 these items and reporting them to management will provide a small increase in the reasonable 

to management confidence of component functionality. 

Part 50 App B 

f Feedback into corrective 50.55a(bO(3)(ii) Critical The feedback of corrective actions and lessons learned is critical to maintaining component action GL 96-05 functionality. Therefore, it is necessary for maintaining reasonable confidence of component 

functionality.
Regulatory Critical or 

Requirements and Noncritical 

Guidelines Evaluation Evaluation Basis

Table 2. (continued). 

Regulatory (Nuclear) 

Special Treatment 

Processes and Attributes 

15 Repair, Replacement, 

or Modification 

a Stock Rotation

Part 50 App B

IWA 4000

Part 50 App B 

c Stamping requirements IWA 4000

d Verification and 

inspection 

documentation

e Material substitution 

f Failure/flaw evaluations 

and corrective actions

Part 50 App B 

IWA 4000

IPart 50 App B

IWA 4000

Part 50 App B 

Part 50 App B

Critical 

Noncritical 

Critical 

Critical 

Critical

g Examination and testing IWA 4000 Critical

h Welding, brazing, metal 

removal, and installation 

i Heat exchanger tubing 

requirements, plugging, 

repair, sleeving, 

replacement 

j Maintain qualified 

configuration

IST B & C 

Part 50 App B 

IWA 4000 

Part 50 App B 

IWA 4000 

Part 50 App B 

Part 50 App B

Critical 

Critical 

Critical

IWA 4000 Critical Stock rotation is necessary to assure that shelf life and storage recommendations are followed. For example, lubricants must be controlled to assure functionality of motor-operated valves. A stock program could be less rigorous for low risk components. 

When mechanical clamping devices are necessary, requirements should be followed to provide reasonable confidence of component functionality. Requirements may be relaxed for low risk components. 

Stamping component requirements functionality. alone Use are of not non necessary "N" stamped to provide reasonable confidence of items could be allowed for low risk items. 

Verification and inspection documentation is necessary to provide reasonable confidence of functionality. The level of documentation could be relaxed for low risk components, 

The correct material is necessary to provide reasonable confidence of component functionality since the wrong material may prevent functionality. Requirements could be reduced for low 

risk components. 

Failure and flaw evaluations are necessary corrective actions to provide reasonable confidence of component functionality. Failure and flaw evaluation programs could be less rigorous for low risk significant components 

Post maintenance (repair or replacement) examination and testing is necessary to provide reasonable confidence of component functionality. Less rigor may be required for low-risk components. 

Proper welding, brazing, metal removal techniques are necessary to maintain pressure boundary integrity and provide reasonable confidence of component functionality. Less rigor may be required for low risk components. 

Proper heat exchanger repair, plugging, etc., are necessary to provide reasonable confidence of component functionality. Less rigor may be required for low-risk components. 

Maintaining equipment qualification, properly sized valve operators, etc., are necessary to provide reasonable confidence of component functionality. A less rigorous configuration control program could be allowed for low risk cornponents.

b Mechanical clamping 

devices requirements

L.
Table 2. (continued). 

Regulatory (Nuclear) Regulatory Critical or 

Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis 

k Use qualified 50.49 (k)(l) Critical Use of the correct component is necessary to provide reasonable confidence of functionality. components RG 1.89 For low-risk components, a particular code that may not be critical, for example, a B3 1.1 

piping component may be satisfactory to provide reasonable confidence of functionality. Part 50 App B 

L Modifications Part 50 App B Critical Adequate modification is necessary to provide reasonable confidence of component 

functionality. However, for low risk components the modification program could be less 

rigorous. 

m Inspection agency IWA 4000 Noncritical An inspection agency does not provide reasonable confidence of component functionality. 

16 Maintenance 

a Maintain specified IST B & C Critical Maintaining a component's performance characteristics is important for reasonable confidence 

characteristics of component functionality. 

50.55a(b)(3)(ii). 

GL 96-05 

RG 1.33, 1.12, 1.52 

Part 50 App B 

b Replacement equipment 50.55a(b)(3)(ii). Critical Qualified equipment may be necessary for applications such as seismic, environmental 

must be fully qualified GL 96-05 qualification, and pressure boundary components. 

Part 50 App B 

17 Trending 

a Develop Trending OM-App I Critical The development of the Trending program is important for monitoring the performance of 

program plant components over time. The program establishes the requirements and identifies the 

50.55a(b)(3)(ii). departments that are responsible for completion of the requirements. However, not all of the 

GL 96-05 special treatment requirements for program development are necessary for RISC-3 

components. For example, the program requirements/responsibilities may be less-formally Part 50 App B documented in several existing documents instead of being organized into a separate, stand

alone document. 

b Gather SSC performance IST B & C Critical Gathering the appropriate component performance data is the basis for an effective trending 

data OM-App II program. 

50.55a(b)(3)(ii). 

GL 96-05 

Part 50 App B
Table 2. (continued).

MLa nll inpDut trom 

testing in operation, 

inspection, examination 

maintenance, monitoring 

and trending 

c Implement actions to 

address input 

d Document performance 

and completion of 

actions

IN I B~ & C, UM-App II

50.55a(b)(3)(ii). 

GL 96-05

Part 50 App B 

50.55a(b)(3)(ii). 

GL 96-05 

Part 50 App B 

IST B & C, OM-App I

50.55a(b)(3)(ii). 

GL 96-05

Critical

Critical 

Noncritical

Gathering the various program inputs is necessary for determining the corrective actions 

necessary for providing reasonable confidence of component functionality. 

Taking proper corrective actions for nonconforming conditions is important for providing reasonable confidence of component functionality. 

As long as the appropriate corrective actions are taken, the documentation of these actions does not affect reasonable confidence of component functionality.

Part~~~ An 50 I _________________________________ Part 50A -

Regulatory (Nuclear) Regulatory Critical or 

Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis c Analyze SSC OM-App II Critical Analysis of component performance data is necessary for an effective trending program. performance trends 

50.55a(b)(3)(ii). 

GL 96-05 

Part 50 App B 

d Develop trend report 50.55a(b)(3)(ii). Critical Development of a formal report of the trend results does not provide reasonable confidence of GL 96-05 component functionality. 

Part 50 App B e Feedback and 50.55a(b)(3)(ii). Critical Implementing corrective actions based on trend results can significantly affect reasonable implementation of GL 96-05 confidence of component functionality. trending results 

18 Corrective Actions 

a Develop corrective 50.55a(b)(3)(ii). Critical The development of the Corrective Action program is important for issues affecting action program GL 96-05 component functionality. The program establishes the requirements and identifies those 

Part 50 App B departments that are responsible for completion of the requirements. However, not all of the special treatment requirements for program development are necessary for RISC-3 

components. For example, the program requirements/responsibilities may be less-formally documented and possibly fewer parameters would require trending as compared to high-risk safety-related components.
Table 2. (continued). 

Regulatory (Nuclear) Regulatory Critical or 

Special Treatment Requirements and Noncritical 

Processes and Attributes Guidelines Evaluation Evaluation Basis 

e Control backlog of 50.55a(b)(3)(ii). Noncritical As long as the appropriate corrective actions are taken, the documentation associated with 

actions GL 96-05 tracking these actions does not affect reasonable confidence of component functionality. 

Part 50 App B 

f Incorporate results into OM-App II Critical Implementing the corrective actions and lessons learned from past problems is critical for 

plant programs maintaining component functionality. 

50.55a(b)(3)(ii). 

GL 96-05 

Part 50 App B
NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER 

(2-89) (Assigned by NRC, Add Vol, Supp., Rev., 

NRCM 1102, and Addendum Numbers, If any.) 3201,32 BIBLIOG HIC DATA SHEET 

(See instsucd on Me revere) NUREG/CR-6752 

2. TITLE AND SUBTITLE INEELUEXT-01-01127 

A Comparative Analysis of Special Treatment Requirements for Systems, Structures, and 

Components (SSCs) of Nuclear Power Plants With Commercial Requirements of 3. DATE REPORT PUBLISHED 

Non-Nuclear Power Plants MONTH YEAR 

Jandary 2002. 

4. FIN OR GRANT NUMBER 

J2828 

5. AUTHOR(S) 6. TYPE OF REPORT 

J.H. Phillips, J.L. Edson, M.R. Holbrook, M.E. Nitzel, A.G. Ware Technical 

7. PERIOD COVERED (Inclusive Dates) 

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor, 

provide name and mad7ing address.) 

Idaho National Engineering and Environmental Laboratory 

Idaho Falls, ID 83415-3129 

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type Same as above'; if contractor provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission, 

and mailing address) 

Division of Engineering 

Office of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001

10. SUPPLEMENTARY NOTES 

D.C. Fischer, NRC Project Manager 

11. ABSTRACT (200 words or/ess) 

This report describes a comparative analysis between the special treatment requirements applied to SSCs in nuclear power 

plants and commercial requirements applied to SSCs in non-nuclear power plants. This comparative analysis focused on the 

practices applied to SSCs in non-safety related applications [balance-of-plant (BOP)] at nuclear plants with additional 

information on non-nuclear power facilities. Site visit information, other nuclear power plant information, and regulatory 

documents were used to perform a critical process evaluation. The typical nuclear SSC life cycle was divided into four critical 

stages and the processes affecting each of these stages were identified. The critical attributes of each of these processes were 

then identified so that the differences between nuclear and BOP approaches could be studied. Evaluations characterized any 

significant differences between the nuclear processes, attributes, and special treatment rules (i.e., applicable codes and 

standards) and the corresponding nuclear BOP and/or commercial processes, attributes, and applicable codes and standards 

as they relate to providing reasonable confidence of component functionality. Component specific commercial codes and 

standards were reviewed for thirty-three different components that are typically required to comply with special treatment rules. 

The conclusions obtained during this project were divided into the categories of State and Federal Requirements, Commercial 

Practice, Differences in Special Treatment Rules and Commercial Practice, and Use of Commercial Codes, Standards, and 

Practices for RISC-3 SSCs. For example, one conclusion states that commercial standards by themselves are not adequate to 

provide reasonable confidence of functionality. However, measures such as utilizing a combination of detailed engineering 

specifications, plant processes and procedures, and multi-level QA programs that augment commercial requirements (but 

provide for less rigor then required for the full 10 CFR 50 Appendix B QA program) might be one potential way to establish 

reasonable confidence of functionality. 

12. KEY WORDS/DESCRIPTORS (List words orphrases that wiN assist researchers in locating the reporL) 13. AVAILABILITY STATEMENT 

Special treatment rules, risk-informed Part 50, SSC, RISC-3, commercial components unlimited 

balance of plant, commercial practice 14. SECURITY CLASSIFICATION 

(This Page) 

unclassified 

(This Report) 

unclassified 

15. NUMBER OF PAGES 

16. PRICE

NRC FORM 335 (2-89)
Federal Recycling Program
NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER (2-M) - (Assigned by NRC, Add Vol, Supp., Rev., NRC, 1102, and Addendum Numbers, If any.) 3201,3202 BIBILIUGRAIPHIC DATA SHEET 

(See instmctas on fte reverse) NUREG/CR-6752 

2. TITLE AND SUBTITLE INEEL/EXT-01-01127 

A Comparative Analysis of Special Treatment Requirements for Systems, Structures, and 

Components (SSCs) of Nuclear Power Plants With Commercial Requirements of 3. DATE REPORT PUBLISHED Non-Nuclear Power Plants MONTH YEAR 

January 2002. 

4. FIN OR GRANT NUMBER 

J2828 

5. AUTHOR(S) 6. TYPE OF REPORT 

J.H. Phillips, J.L. Edson, M.R. Holbrook, M.E. Nitzel, A.G. Ware Technical 

7. PERIOD COVERED (inclusive Dates) 

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC provide Division, Office or Region, U.S. Nudcear Regulatory Cornission, and mailing address; ifcontractor, 

provide name and maining adres&) 

Idaho National Engineering and Environmental Laboratory 

Idaho Falls, ID 83415-3129

9. S>PUN•UIM OINI•U<G.a ORAIZA.TION - NAME: AND ADDRESS (ffNRa, type "amaie as above,, if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Coimmissiion, and mailing address.) 

Division of Engineering 

Office of Nuclear Reactor Regulation 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 iA, ,O~rL~n I C i, n e,

D.C. Fischer. NRC Proiect Manaaer

1-1 . Pz I I"A,. I (200 words or Al•e)

This report describes a comparative analysis between the special treatment requirements applied to SSCs in nuclear power plants and commercial requirements applied to SSCs in non-nuclear power plants. This comparative analysis focused on the 

practices applied to SSCs in non-safety related applications [balance-of-plant (BOP)] at nuclear plants with additional information on non-nuclear power facilities. Site visit information, other nuclear power plant information, and regulatory documents were used to perform a critical process evaluation. The typical nuclear SSC life cycle was divided into four critical 

stages and the processes affecting each of these stages were identified. The critical attributes of each of these processes were then identified so that the differences between nuclear and BOP approaches could be studied. Evaluations characterized any significant differences between the nuclear processes, attributes, and special treatment rules (i.e., applicable codes and standards) and the corresponding nuclear BOP and/or commercial processes, attributes, and applicable codes and standards 

as they relate to providing reasonable confidence of component functionality. Component specific commercial codes and standards were reviewed for thirty-three different components that are typically required to comply with special treatment rules. The conclusions obtained during this project were divided into the categories of State and Federal Requirements, Commercial 

Practice, Differences in Special Treatment Rules and Commercial Practice, and Use of Commercial Codes, Standards, and Practices for RISC-3 SSCs. For example, one conclusion states that commercial standards by themselves are not adequate to 

provide reasonable confidence of functionality. However, measures such as utilizing a combination of detailed engineering specifications, plant processes and procedures, and multi-level QA programs that augment commercial requirements (but provide for less rigor then required for the full 10 CFR 50 Appendix B QA program) might be one potential way to establish 

reasonable confidence of functionality.

12. KEY WORDSIDESCRIPTORS (Ust words orphrases that will assist researchers in iocatng fth report) 13. AVAILABILITY STATEMENT 

Special treatment rules, risk-informed Part 50, SSC, RISC-3, commercial components unlimited 

balance of plant, commercial practice 14. SECURITY CLASSIFICATION 

(This Page) 

unclassified 

(This Report) 

unclassified 

15. NUMBER OF PAGES 

16. PRICE

NRC FORM 335 (2-89)

ou'-IIMQ11 VU /1 • I•IU 1V o ,I
NUREG/CR-6752 A COMPARATIVE ANALYSIS OF SPECIAL TREATMENT REQUIREMENTS FOR 

SYSTEMS, STRUCTURES, AND COMPONENTS (SSCs) OF NUCLEAR POWER PLANTS 

WITH COMMERCIAL REQUIREMENTS OF NON-NUCLEAR POWER PLANTS

JANUARY 2002

UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

WASHINGTON, DC 20555-0001 

OFFICIAL BUSINESS 

PENALTY FOR PRIVATE USE, $300