Nuclear Safety-Related Item Procurement

A nuclear facility procuring an item that supports a nuclear safety function has two options:

1. ASME NQA-1 Compliant Manufacturing – The item is manufactured under a full NQA-1 Quality Assurance program (Part I & Part II).
2. Commercial Grade Dedication (CGD) – The item is accepted through a formal NQA-1 Commercial Grade Dedication program in accordance with Part II, Subpart 2.14.

What is Commercial Grade Dedication?

Commercial Grade Dedication (CGD) is an acceptance process that provides reasonable assurance that a commercial item or service will successfully perform its intended nuclear safety function. It is considered equivalent to an item manufactured under a full NQA-1 QA program.

CGD is not simply an inspection activity — it is a structured engineering, procurement, and quality process that identifies critical characteristics, determines how they will be verified, and documents the evidence needed for acceptance.

Why Nuclear Distributors Need Strict Rules

Nuclear facilities use thousands of parts (valves, fasteners, instruments, electrical components, etc.). A failure in a normal factory may only stop production. In a nuclear facility, a failure can contribute to a radiation release or compromise public safety.

Parts are classified as:

• Safety-related – Support safety functions (reactor core protection, mitigation of radiological release)
• Non-safety-related – Used for normal operations

To supply safety-related parts, distributors must go through a documented qualification process.

Key Standards & Regulatory Frameworks

• 10 CFR Part 50, Appendix B – U.S. regulatory quality assurance criteria for nuclear power plants.
• ASME NQA-1 – The primary consensus standard for nuclear quality assurance programs (18 requirements).
• ISO 19443 – International standard for nuclear supply chain quality management (based on ISO 9001 with nuclear-specific requirements).
• NRC Regulatory Guide 1.164 & EPRI NP-5652 – Widely used industry guidance for CGD implementation.

Dufrane’s CGD Capabilities

The Dufrane team performs Commercial Grade Dedication in accordance with customer design engineering specifications and technical requirements, including:

Responsible Parties in the CGD Process

CGD is a cross-functional activity. Key roles include:

• Dedicating Entity – The organization responsible for performing and documenting the dedication process.
• Responsible Engineering Organization (REO) – Owns the technical basis and approves safety function, critical characteristics, and acceptance criteria.
• Quality Assurance / Quality Control – Verifies activities are performed under approved procedures and reviews objective evidence.
• Procurement – Ensures purchase documents contain correct technical, quality, and documentation requirements.
• Supplier Oversight / Source Verification – Witnesses activities and confirms supplier controls.

How to Find Qualified Nuclear Suppliers

Procurement teams should use a structured qualification process supported by:

• Industry Directories – ANS Buyers Guide, NPP Supplier Directory, NuclearMarket Database
• Certification Lists – ASME Certified Companies List (NQA-1)
• Shared Audit Programs – NUPIC and NIAC (reduce duplicate audits)
• Third-Party Certifications – ISO 19443 certificates (especially important in Europe)