Commercial
Grade
Dedication
By Marc Tannenbaum, Electric Power
Research Institute.
Marc Tannenbaum
Marc Tannenbaum is the Principal
Technical Leader at the Electric
Power Research Institute (EPRI).
He is responsible for research in the
areas of procurement
engineering and supply
chain management.
His current research
focuses on improving
the quality of procured
items, commercial
grade item dedication,
the technical
aspects of materials
management and
proactive management
of obsolescence and
inventory to support
equipment reliability.
Tannenbaum joined EPRI in 2007. Prior
to joining EPRI, he consulted with EPRI
and delivered several of EPRI’s nuclear
procurement training courses.
Tannenbaum received a Bachelor of
Science degree in Industrial Engineering
and Business Administration from the
University of Illinois.
An interview by Newal Agnihotri,
Editor of Nuclear Plant Journal, at
the American Nuclear Society Utility
Working Conference in Amelia Island,
Florida on August 12 ,2014.
1.
How
is
information
related
to Commercial Grade Dedication
communicated to the utilities so that they
may benefit from it?
The best introduction to the nuclear
procurement process in general, and to
commercial grade dedication (CGD)
specifically, is the EPRI Nuclear Utility
Procurement course, which has been
upgraded to address the updated CGD
guidance. In addition, EPRI is developing
an advanced course on dedication that
will address each step in the dedication
process,
including
implementation
guidance, examples of past problems,
and lessons learned. Key issues related
to common areas of interest brought to
EPRI’s attention by
our members and our
member’s
suppliers
will also be included.
EPRI plans to roll
out the guidance in
workshops that review
the dedication process,
discuss known problem
areas, and work through
example
scenarios.
The first is scheduled
for November 5 & 6
at EPRI’s facilities
in
Charlotte,
NC.
Our intent is to offer
several more in different locations. The
workshops will be open to suppliers and
utilities.
2.
What is the role of international lab
accreditation cooperation (ILAC) and
Mutual Recognition and Arrangement in
Commercial Grade Dedication?
Calibration services provided by
accredited laboratories are commercial
grade services. At present, the NRC
allows
the
accreditation
process
performed by U.S.-based accreditation
bodies to be used in lieu of a commercial
grade survey for calibration (not testing)
service providers. However, it’s important
to point out that a commercial grade
dedication is still required.
The approach relies upon the
supplier’s accreditation in lieu of
performing a commercial grade survey of
the supplier.
A commercial grade dedication
technical evaluation and an acceptance
plan must still be prepared to dedicate
calibration services. The following
activities are included in a dedication
technical evaluation for services:
1. Identify and document safety
function of the service.
2. Identify and document credible
failure modes for the service.
3. Identify and document critical
characteristics of the service.
4. Identify
and
document
the
acceptance methods that will be used
to verify the critical characteristics.
5. Implement the acceptance methods.
There are four dedication methods
that can be used to verify the critical
characteristics mentioned in 4 and 5
above:
• Method 1 – Special Tests and
Inspections.
• Method 2 – Commercial Grade
Survey of the Supplie.
• Method 3 – Source Verification.
• Method 4 – Acceptable Item/
Supplier Performance Record.
Activities 1, 2 and 3 (above) are the
same as they would be for a standard
dedication. However, if the dedication is
based upon Method 2, the accreditation
process can be credited to accomplish
activities 4 and 5 in lieu of performing a
commercial grade survey of the supplier.
The dedicating entity would document
use of a supplier accredited to ISO/IEC
17025:2005 (General Requirements
for the Competence of Testing and
Calibration Laboratories) by a U.S.-
based accreditation body in the technical
evaluation. Documentation would include
the following:
a. Identificationof the testmethodology,
including measurement parameters,
ranges and uncertainty.
b. Verification that the laboratory
is accredited by a U.S.-based
accrediting body and that the
calibration services to be provided to
the dedicating entity are included in
the scope of accreditation.
c. Identification of any additional
technical and quality requirements,
including certification that the
calibration services were provided in
accordance with the accredited ISO/
IEC-17025:2005,
General requirements
for the competence of testing and
calibration laboratories. American
National
Standards
Institute/
International Organization for
S t andard i za t i on / In t erna t i ona l
Electrotechnical
Commission,
34
NuclearPlantJournal.com Nuclear Plant Journal, September-October 2014
