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# 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 (NUREG/CR-6752)

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## Publication Information

**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

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## 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.

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