Commerical
Grade
Dedication
By Bob Cole, AREVA Inc.
Bob Cole
Bob Cole is Manager of Integrated
Procurement Solutions for Installed
Base Services at
AREVA Inc., North
America. Bob is
responsible for the
business operation,
customer service
and financial
performance of
the Integrated
Procurement
Solutions business
line.
Bob earned a
Bachelor of Science
in Mechanical
Engineering from
Virginia Military Institute and has a
Masters in Business Administration from
Lynchburg College.
Responses to questions by Newal
Agnihotri, Editor of Nuclear Plant
Journal.
Dr. Charles Lakeman and Harry
Medsger of AREVA also contributed to
the responses.
1.
What is the role of international
lab accreditation cooperation (ILAC)
or similar other programs in AREVA’s
Commercial Grade Dedication (CGD)
Program?
AREVA has applied the accreditation
of certain suppliers of calibration and
general laboratory testing services
to support verification of critical
characteristics during the CGD process.
These applications of a supplier’s
accreditation have been limited to U.S.
Nuclear Regulatory Commission (NRC)-
endorsed domestic accreditation bodies.
Acceptable suppliers are accredited
to ISO/IEC 17025:2005, "General
requirements for the competence of testing
and
calibration
laboratories", and
are selected based
on their documented
capability to provide
the calibration or
testing services as
established by an
AREVA commercial
grade
dedication
(CGD) plan. In
these applications,
accreditation
is
used in lieu of
the
performance
of a commercial
grade survey to
support acceptance of certain specified
calibration and general laboratory
testing services. Recently, AREVA
added the ability to rely on laboratory
accreditation by accreditation bodies
that are signatories to the International
Laboratory
Accreditation
mutual
recognition arrangement in a limited
number of dedication plans.
2.
How are the characteristics
necessary to perform “safety functions”
measured?
There are a variety of ways critical
characteristics are verified during the
acceptance activities established in
dedication plans. Depending on the
acceptance method (or combination of
methods), the following approaches may
be applied:
1) Special tests and inspections.
2) Commercial grade survey (including
accreditation in lieu of commercial
grade survey as an acceptable
alternative).
3) Source verification.
4) Item/supplier performance record.
There arewell-established restrictions
on the use of all of these methods with the
exception of special tests and inspections.
The selected critical characteristics
are verified based on objective and
measurable facts, actions or observations;
and properly documented to establish a
reasonable assurance that the item, once
dedicated, will perform its intended
safety function.
3.
How are fraudulent items identified
by AREVA?
With respect to an item’s acceptance
for use in safety-related applications,
whether part of the CGD process or
applied as part of material control
performed generally under AREVA’s
Quality Assurance Program (which is
compliant with 10CFR50 Appendix B –
"Quality Assurance Criteria for Nuclear
Power Plants and Fuel Reprocessing
Plants"), inspections are typically directed
by procedures or instructions intended for
use at AREVA facilities and compliant
with the AREVA Procedure: PR-NA-
CORP-SS-CF-00003, “Counterfeit and
Fraudulent Items.” The purpose of this
procedure is to provide a general awareness
of counterfeiting and its global threat to
the health and safety of workers, the public
and the environment; and to establish
measures to prevent, detect and effectively
control items that have been procured by
the company and are considered to be
counterfeit or fraudulent items.
4.
How can IEEE 323 and IEEE 344
seismic and environmental qualification
requirements be met just by a dedication
program?
The processes of equipment
qualification (as specified by IEEE
323, "Standard for Qualifying Class 1E
Equipment for Nuclear Power Generating
Stations" in its various versions
and supported by IEEE 344, "IEEE
Nuclear Plant Journal, March-April 2016 NuclearPlantJournal.com
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