What Is Commercial Grade Dedication and When is it Required for Nuclear Grade Welding Consumables?
Is your filler material intended to be used in a nuclear “safety-related” welding application? If the answer is “yes,” then read on to understand how you can know whether or not your nuclear-grade welding consumables are in compliance with Title 10 and the requirements of the Nuclear Regulatory Commission.
Before this question can be answered, we must ask another question: Is the filler material intended to be used in a nuclear “safety-related” welding application?
If the answer is yes, then we might be in a position where Commercial Grade Dedication (CGD) must be used, but we’re not there quite yet. First, let’s establish a little more context.
There are two subcategories that make up the safety-related realm: those that are within the pressure boundary and those that are not within the pressure boundary of a nuclear reactor. Welding applications that involve system components that are within the nuclear pressure boundary fall under the purview of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPV) Section III: Rules for Construction of Nuclear Facility Components.
For those safety-related welding applications that are not within the pressure boundary, other construction codes may apply (like American Welding Society AWS D1.8, Structural Welding Code – Seismic Supplement, for instance). But in those not within the pressure boundary safety-related situations, ASME Section III does not apply.
For those readers who may not be familiar with nuclear power reactor construction, the U.S. Nuclear Regulatory Commission (NRC) defines the pressure boundary as the pressure-containing components of nuclear reactors, including pressure vessels, piping, pumps, and valves that are either part of or connected to the reactor coolant system. This includes (but is not limited to) everything up to the outermost containment isolation valve in system piping, which penetrates primary reactor containment, as well as reactor coolant system safety and relief valves.
So the fact that the application is defined as safety-related and within/not within the pressure boundary should mean what exactly to you? Whenever a safety-related product is used in nuclear reactor construction, repair, etc., and the reactor is located in the United States, then the requirements of U.S. Government Title 10 CFR 50 Appendix B and Title 10 CFR Part 21 apply. And these regulations apply to ALL of the downstream components used in the construction activity, including welding filler materials.
The acronym CFR stands for “Code of Federal Regulations.” The CFR is divided into 50 distinctly different titles that represent the various areas subject to Federal regulation. Within these titles are the general and permanent rules as set forth by the various agencies of the U.S. Government. Title 10 is binding on all persons and organizations who receive a license from NRC permitting the use of nuclear materials or operation of nuclear facilities. One may associate the 10CFR as the “regulatory standards” for nuclear power plants, while by contrast the ASME Section III and AWS D1.8 would be considered the “construction codes.”
About the Author: Geisler Regis
There maybe a misconseption about ASME III, There is a application of Section III that is/could be within the Code boundary or may be external to the pressure containment area that always has to be considered – Supports as defined within Section NF of ASME III. Although the involvements are VERY complex it also straight forward. Ultimately the Owner will have designated the compliance factor and within the Section III or IX areas.
Thank you for the response, Mr. Wendler. I agree with your statement that “Supports” as covered in ASME Section III Subsection NF are indeed within the Code boundary. For the sake of brevity, I provided a non-comprehensive list of components to which Supports can certainly be added.