National Board registration req'ts in N.C. 1

[packdad]

I work at a nuclear plant in North Carolina. I am ordering some ASME Section III Class 3 check valves for a system that sprays cold water into the containment building under emergency conditions. The question has come up: Do these valves have to be registered with the National Board? I am confident that this is not an ASME Code requirement, but it may be a N.C. state requirement.

Here are some pertinent sections from the Uniform Boiler and Pressure Vessel Act of N.C. How would you interpret these two excerpts?

Section 13.0701(b): All nuclear energy systems shall be stamped and registered with the National Board and stamped with a North Carolina serial number.

Section 13.0101(34): "Nuclear energy system" means any closed vessel in which water is heated, steam is generated, steam is superheated, or any combination thereof under pressure or vacuum for use externally to itself by the direct application of heat from nuclear energy and associated components, vessels, piping systems, pumps, valves, storage tanks and appurtenances.

In my opinion, a check valve in a cold water system does not meet the definition of a nuclear energy system. Our ANII (authorized nuclear inservice inspector) and I agree that registration should not be required in this case, but one of our procurement engineers disagrees.

This all came about because our specification for the valves requires board registration (it's just something we've always done with Code valves), but for some reason, the vendor would like to take exception to this. I'm just wondering if there is any grounds for exception in the unlikely event that the vendor decides to really push back on this. It really isn't that big of a deal in the grand scheme, but I am curious.

 

[vpl]

packdad,

This is just my opinion...but if your spec calls for board registration and you routinely do it, then you need to have a well thought out, well-documented reason not to do it, especially since the valve is part of a safety-related system (I am assuming containment spray from your description). I could make an arguement that the containment structure could have steam generated in it following an emergency and that it is a closed vessel and that the valve is associated with it. So you really need to think it through and have something more than the "vendor wants to take exception."

I would strongly suggest that you call the NC registration board (if your company routinely registers components, someone should have a contact) and ask them.

If your spec calls for it and the vendor bid on the spec but won't meet a provision of the spec, then it sounds like a breach of contract issue. And if the vendor really starts pushing back then you should be asking questions as to whether the vendor is really are meeting the Section 3, Class 3 requirements or if you're getting a counterfeit component.

Again, just my opinion.

Patricia Lougheed

Please see FAQ731-376 for tips on how to make the best use of the Eng-Tips Forums.

 

[packdad]

Thanks for the feedback.

Right now, we're standing by the requirements of our spec. I'd be VERY surprised if the vendor made a fuss about this. And I agree with you that we should not be of the mindset that we'll always try to accomodate a vendor anytime they want to take exception to a specification.

In this case, though, I wasn't very familiar with the purpose of board registration and the requirements to do so (since I deal with the purchase of Code components so infrequently). For me, then, it's as much of a learning experience as anything! This thread probably makes it seem like a bigger issue than it really is...