**ASME CODE CLASSIFICATIONS FOR COMPONENTS

Introduction
The current scope of the IST requirements of 10CFR50.55a includes ASME
Code Class 1, 2, and 3 components. Therefore, ASME Section XI Code
classification of systems and components determine the examinations and tests
required for the purposes of inservice inspection, inservice testing and
repair/replacement activities.
Many of the problems regarding improper program scope originate from improper
classification of components. The process of classifying components is rather
straightforward for newer plants that were designed and constructed to ASME
Section III. Federal regulations required that components in plants whose
application for a construction permit was docketed after May 14, 1984 meet the
requirements of ASME Section III.
However, the older plants were designed and constructed to the United States of
America Standards (USAS) B31.1, Code of Power Piping, and B31.7, Code for
Nuclear Power Piping. ASME Section XI requirements for inservice inspection
and testing were imposed after the design and/or construction of these plants
were completed. Additionally, the early editions of Section XI did not include the
categorizations of Class 1, 2, and 3. These component classifications were
added in subsequent editions between 1971 and 1974. For these older plants,
safety-related components are classified based on the function of the
components; hence the wording from 10CFR50.55a(f):
"(1) For a boiling or pressurized water-cooled nuclear power facility whose
construction permit was issued prior to January 1, 1971, pumps and
valves must meet the test requirement of paragraphs (f)(4) and (5) of this
section to the extent practical. Pumps and valves that are part of the
reactor coolant pressure boundary must meet the requirements applicable
to components that are classified as ASME Code Class 1. Other safetyrelated pumps and valves must meet the requirements applicable to
components that are classified as ASME Code Class 2 or Class 3."
"(2) For a boiling or pressurized water-cooled nuclear power facility whose
construction permit was issued on or after January 1, 1971, but before
July 1, 1974, pumps and valves which are classified as ASME Code Class
1 and Class 2 must be designed and be provided with access to enable
the performance of inservice tests for operational readiness set forth in
editions of Section XI of the ASME Boiler and Pressure Vessel Code and
Addenda in effect 6 months prior to the date of issuance of the
construction permit."

"(3) For a boiling or pressurized water-cooled nuclear power facility whose

construction permit was issued on or after January 1, 1974:
(iii) Pumps and valves which are classified as ASME Code Class 1
must be designed and be provided with access to enable the
performance of inservice tests for assessing operational readiness
set forth in Section XI...
(iv) Pumps and valves which are classified as ASME Code Class 2
and Class 3 must be designed and be provided with access to
enable the performance of inservice testing of pump and valves for
assessing operational readiness set forth in Section XI..."
Because early vintage nuclear plants were designed and constructed before
Section III of the ASME Boiler and Pressure Vessel Code was incorporated into
10CFR50.55a, the ASME Section XI Code classifications for ISI may differ from
the original design classifications.
However, while the ASME Code
classifications determine the rules for repairs and replacements and the
component inspection requirements, all repairs and replacements are performed
to meet, at a minimum, the specifications of the original design code.
Historically. the safety-related classification process and criteria have not been
clearly defined. Various documents used in this process have alluded to such
phrases as "safety-related" or "important to safety" but no complete, consistent
guideline existed as to why some equipment is more important to nuclear safety
than other equipment or what documents are applicable. As a result, various
interpretations/inconsistencies have evolved in the use of the term "safetyrelated", often times confusing regulatory and other non-functional requirements
into its applicability.
Other phrases widely used in codes, standards, and other documents have also
been correctly and incorrectly interpreted to be synonymous to "safety-related".
"Basic component" defined in 10CFR21 is equivalent to "safety-related."
"Important to Safety," which was previously used as a synonym to "safetyrelated," is currently an unresolved NRC generic issue and officially undefined.
The facility Final Safety Analysis Report (FSAR) frequently uses the term "safety"
in a broader context than "safety-related". FSARs use phrases such as "safety
functions", "nuclear safety systems", "instruments required for safety" and others.
The relationship of the term "safety-related" to those other commonly referred to
terms such as "safety", "protection systems" etc. are not necessarily synonymous
with the term "safety-related".

There also exists further confusion regarding the term "safety-related". This
confusion results from the different uses and interpretations applied to this term.
The term safety-related is typically used in the following ways:
a. From a design engineering standpoint, the term "safety-related" is used to
identify items which are (1) part of the reactor coolant pressure boundary,
(2) required to shut down the reactor and maintain it in a safe shutdown
condition, or (3) required to prevent or mitigate the consequences of
accidents which could result in potential off-site exposures comparable to
10CFR100.11 guidelines.
b. Typically, three methods of procurement are utilized, commonly referred to
as: safety-related, commercial grade, and non-safety-related. A safetyrelated procurement refers to the purchase of an item under the provisions
of 10CFR21 from a vendor with a quality assurance program that meets
the requirements of 10CFR50 Appendix B.
A commercial grade
procurement refers to an item which will be dedicated for safety-related
use, but is not purchased to an approved 10CFR50 Appendix B Quality
Assurance program nor are 10CFR21 requirements imposed on the
vendor. Once a commercial grade item is dedicated it becomes a basic
component. A non-safety-related procurement refers to an item that does
not have a safety-related function.
c. Also, selected items may be classified as safety-related even though their
function is non-safety-related. This is done to institute greater controls over
procurement, maintenance, or replacement of such items.
As a result, it is important to understand the context in which the term "safetyrelated" is used and what is meant. For component classification for the
purposes of ISI and IST, the term "safety-related" pertains to the function a
system or component performs.
The "General Design Criteria for Nuclear Power Plant Construction Permits" was
published for comment in the Federal Register in July 1967. The final version of
these design criteria was not incorporated into the Code of Federal Regulations
(10CFR50, Appendix A) until February 1971; therefore, many plants were
designed prior to these requirements being finalized. These plants were typically
designed and constructed based on the licensee's "interpretation of the intent of
the Draft General Design Criteria published in July 1967". The design accepted
by the NRC, any rules or requirements imposed by the NRC, commitments made
by the licensee, and any exceptions to rules or requirements allowed when
granting the facility license was granted from the design basis and licensing basis
for that facility. The combination of the design basis, licensing basis and the
system and component functions determine the requirements for inservice

testing and inspection. These determinations may be quite difficult and subject
to opinion, which is precisely why they should be documented in a classification
basis document.
The basis document should define the test and examination boundaries and, in
general, the examinations and tests required by the Section XI Code and federal
regulations. Once established with a sound technical basis, these boundaries
change only when systems and components are modified or replaced. A basis
document provides the guidance needed for:

The rational used for a defensible basis for safety classification;

Assuring compliance with the law and the plant license basis such that all items
required by the regulatory definition or by licensing commitment to be safetyrelated are identified as such; and

Maintaining consistency with the current licensed plant design, with other plant
equipment, and with past and current industry and NRC practice.

Once the safety classification has been identified, the design and quality
assurance requirements consistent with NRC regulations, industry standards and
licensing basis can be identified. Some examples of classification basis
documentation are included in Appendix C of these course notes.
Classification Documents
The following documents are used as guidance for the functional classification of
systems, components, and component supports:

NUREG-0800, Standard Review Plan, Section 3.2.2, Revision 1 (SRP 3.2.2) This review plan is used by the NRC Office of Nuclear Reactor Regulation staff
to review applications for construction and operation of nuclear power plants.
SRP 3.2.2 explains the staff policies and approach to system quality group
classification. This document references Regulatory Guide 1.26, Revision 3, (RG
1.26) and "the corresponding ANS classification system of Safety Classes"
(which refers to ANSI/ANS-52.1 or -51.1) as specific implementation documents
for system classification.

10CFR50.55a, Codes and Standards - Sections 50.55a(c), (d), and (e) reference
10CFR50.2 and RG 1.26 for the classification of Quality Group A and Quality
Group B and C components, respectively. Footnote 9 of 10CFR50.55a references
RG 1.26 and SRP 3.2.2 for guidance for quality group classification of
components.

10CFR50.2, Reactor Coolant Pressure Boundary Definition - This section of the

1993 Edition of the Code of Federal Regulations provides criteria for the

classification of Quality Group A components. In previous issues of 10CFR,

these criteria were provided in section 50.2(v).

10CFR50.55a(c)(2) - This paragraph provides exclusions from the criteria of

Section 50.2, thus allowing components connected to the reactor coolant system
to be Quality Group B (Section XI Code Class 2) or non-Code Class.

Regulatory Guide 1.26, Revision 3, (RG 1.26), Quality Group Classifications

and Standards for Water-, Steam-, and Radioactive Waste Containing
Components of Nuclear Power Plants - This document provides criteria for the
classification of Quality Group B, C, and D (Typically non-Code Class)
components.

ANSI/ANS-51.1-1983, American National Standard, Nuclear Safety Criteria for

the Design of Stationary Pressurized Water Reactor Plants - This document may
be used as the basis for the examination and test boundaries or may be employed
for guidance in cases where the requirements of RG 1.26 are vague or incomplete.
It provides classification and design criteria for all safety-related components and
is much more detailed and comprehensive than RG 1.26. The classification and
boundary criteria of Section 3.3.2 are particularly useful in evaluating systems
and components which were not designed to meet the valving criteria of RG 1.26,
Footnote 4 or are not specifically covered by RG 1.26.

ANSI/ANS-52.1-1983, American National Standard, Nuclear Safety Criteria for

the Design of Stationary Boiling Water Reactor Plants - This document is
essentially identical to ANSI/ANS-51.1-1983, except that it specifically covers
classification and design criteria for boiling water reactors.

Per IWA-1400(a) of the Section XI, it is the owner's responsibility to determine

the appropriate Code Classes for each component and to identify the system
boundaries subject to inspection. IWA-1300 states that components identified for
inspection and testing shall be included in the inservice inspection plan, and that
the selection of components for the inservice inspection plan is subject to review
by the regulatory and enforcement authorities having jurisdiction at the plant site.
IWA-1320(a) states that the system group classification criteria of the regulatory
authorities having jurisdiction at the power plant site governs the application of
the rules of Section XI. IWA-1400(a), footnote 2, states that classification criteria
are specified in 10CFRS0. This reference is to Footnote 9 of 10CFR50.55a which
specifies that Regulatory Guide 1.26 and Section 3.2.2 of NUREG-0800 may be
used for this purpose. Section 3.2.2 of NUREG-0800 allows the use of either the
NRC Group Classification system of Regulatory' Guide 1.26 or the ANS Safety
Classification system (referring to the method described in ANSI/ANS-51.1 and 52.1) which can be cross-referenced to Regulatory Guide 1.26.
The Section XI Boundary Classification Process

The classification of systems and components is a two-phase process: first,

classification is performed based on system/component function. After this initial
"bounding" process, the included components are evaluated for the application of
ASME Section XI requirements and exemptions.
A review is performed to identify systems, or portions or systems, which may be
considered safety-related. The conclusions of this review, and their bases,
should be documented. This documentation should include discussion of
systems and components that are outside the scope of Section XI. However,
augmented examinations and tests should be performed for systems and
components outside the scope of Section XI commensurate with the safety
functions of these systems and their components.
For the systems that were identified to be safety-related and within the scope of
Section XI, the components of these systems are then evaluated, based on the
system safety function(s) identified, per the classification documents listed
previously. These components are then identified accordingly as ASME Class 1,
ASME Class 2, ASME Class 3, or non-Class.
When a particular group of components has been identified as performing an
ASME Class 1, 2, or 3 function, the components should be further reviewed to
assure that the boundary interfaces
(boundary valves and barriers) meet the
criteria of 10CFR50.2, 10CFR50.55a(c)(2), RG 1.26, SRP 3.2.2, or ANSI/ANS51.1 or -52.1. Technical positions should be written to detail any deviations from
the boundary classification criteria of these classification documents. These
technical positions should be included in an appendix of the classification basis
document.
When the safety function(s) and boundary interfaces are determined for a
system, the Section XI boundaries are marked on the applicable flow diagrams or
P&IDs, typically with "flags" containing characters designating Section XI Code
Class 1, 2, 3 or non-Class (NC).
Classification Notes
Section XI boundaries for Class I systems are typically established per
10CFR50.2 which requires that the reactor coolant (Class 1) pressure boundary
extend to include: (l) the outermost containment isolation valve in system piping
which penetrates the primary reactor containment, (2) the second of two valves
normally closed during normal reactor operation in system piping which does not
penetrate primary reactor containment, (3) the reactor coolant system safety and
relief valves and, for boiling water reactors, (4) the outermost containment
isolation valve in the main steam and feedwater piping. Exception may be taken
to these boundary, criteria for Class 1 components, per 10CFR50.55a(c)(2),
provided: (1) in the event of postulated failure of the component during normal
reactor operation, the reactor can be shut down and cooled down in an orderly

manner assuming makeup is provided by the reactor coolant makeup system or,
(2) the component is or can be isolated from the reactor coolant system by two
valves in series (both closed, both open, or one closed and the other open).
However, each open valve must be capable of automatic actuation and,
assuming the other valve is open, its closure time must be such that, in the event
of postulated failure of the component during normal reactor operation, each
valve remains operable and the reactor can be shutdown and cooled down in an
orderly manner, assuming makeup is provided by the reactor coolant makeup
system only.
Section XI boundaries for Class 2 and 3 systems are typically established per RG
1.26, footnote 4, which stipulates that the boundary include those portions of the
system required to accomplish the specified safety function and the connecting
piping up to and including the first valve that is either normally closed or capable
of automatic closure when the safety function is required.
In the event that a system performs more than one function, each of which is a
different class, the higher class would apply to all components. Note that for the
purposes of this classification process, in most cases, Quality Group A (RG 1.26)
and Safety Class 1 (ANSI/ANS-52.1) are considered equivalent to Section XI
Class 1; Quality Group B (RG 1.26) and Safety Class 2 (ANSI/ANS-52.1) are
considered equivalent to Section XI Class 2; and Quality Group C (RG 1.26) and
Safety Class 3 (ANSI/ANS-52.1) are considered equivalent to Section XI Class 3.
Any exceptions to this convention should be documented.
Optional construction of a system, or a component within a system boundary, to
a classification higher than the minimum class established in the component
design specification (either upgrading from Class 2 to Class 1 or from Class 3 to
Class 2) does not affect the overall system classification by which the rules for
examination and testing are determined.
Application of ASME Classifications
The second phase of the ASME boundary classification process is the
application of the examination requirements of ASME Section XI, detailed in
paragraphs IWB-1210, IWC-1210, IWD-1210, and IWF-1210; the application of
the exemptions of ASME Section XI, detailed in paragraphs IWB-1220, IWC1220, IWD-1220, and IWF-1230; and the testing requirements identified in ASME
Section XI, Subsections IWV and IWP, or the O&M Code, as applicable.
The basic rule for application of ASME Section XI examination requirements to
components included in the Section XI boundaries per Section 3.2 is given in
paragraph IWA-1320:
For ASME Class 1 components (Quality Group A), the requirements of
Subsection IWB apply; for ASME Class 2 components (Quality Group B)

the requirements of Subsection IWC apply; and for ASME Class 3 (Quality
Group C) components the rules of Subsection IWD apply.
For IST, the testing requirements for all Code Class components are determined
by component type and safety function, with the exception that closure testing of
certain valves may be required due to their location as Code Class pressure
boundary isolation valves.
**The above information was extracted from the training classes given by True
North (BCP) in recent years.
In addition, further guidance is provided in NUREG-1482 and the NRC Workshop
Summary, regarding the classification of components/systems for ISI and IST.
Care must be taken to ensure that components which are not tested under the
IST Program are tested "commensurate with the safety significance of the
components." This is to satisfy 10 CFR 50 Appendix B requirements.