The US Nuclear Regulatory Commission (NRC) recently published its annual vendor newsletter, The Vendor Times, documenting findings of NRC vendor inspection staff and lessons learned related to the vendor inspection program. The newsletter follows the NRC’s November 20 vendor inspection program self-assessment for fiscal year 2023. Through these two issuances, the NRC noted an increase in enforcement findings and indicated that it will focus on 10 CFR Part 21 and supplier oversight compliance during future inspections.
FY2023 Vendor Inspection Metrics
In fiscal year 2023, the NRC vendor inspection staff conducted 22 inspections for operating reactors, including 18 vendor inspections, one licensing audit, and three observations of Nuclear Procurement Issues Corporation audits. These compliance monitoring actions led the NRC to issue 12 notices of nonconformance (NOCs) and four notices of violation (NOVs) for eight vendors, an overall increase in the total number of findings over fiscal year 2022. None of the NOCs or NOVs were contested.
The NRC identified that this increase in NOCs and NOVs is mainly in the areas of corrective actions, 10 CFR Part 21, and supplier oversight. Therefore, the NRC stated it will focus on these areas during future inspections and stress the importance of adequately implementing correction action and 10 CFR Part 21 programs to vendors. With respect to supplier oversight, the NRC will focus on the areas of commercial-grade dedication and supplier audits.
NRC vendor inspection staff also supported 47 allegation actions during fiscal year 2023, one of which resulted in a reactive inspection.
Lessons Learned
The NRC continues to support the implementation of Inspection Procedure (IP) No. 71111.21N.03, Commercial Grade Dedication, last revised in March 2023. To that end, NRC staff supported technical process and inspection implementation training for regional inspectors, including tabletop scenario discussions, and engaged in discussions with stakeholders to provide clarity on the IP.
The NRC will carry out inspections through 2026, and each nuclear plant site will have an inspection. As of October 2023, the NRC has completed 20 inspections, identifying seven noncited violations. The NRC identified the following common themes associated with the noncited violations:
- Lack of implementation for control of parts and material that are signed out of the warehouse, transferred to the shop to the jobsite, and then returned to the warehouse if not used;
- Shelf life of parts in the warehouse and the lack of controls to properly identify and update the item as needed;
- A misunderstanding regarding compliance with 10 CFR Part 21 and reporting requirements;
- When using commercial-grade surveys, a survey report is the dedication documentation and QA record and must be retained as a permanent record for the dedicated component; and
- Properly translating all design requirements into critical characteristics.
Update Regarding COVID-19 Public Health Emergency
With the termination of the COVID-19 Public Health Emergency on May 11, 2023, the NRC no longer allows for 100% remote audits, commercial-grade surveys, or source verifications. Accordingly, vendor inspection staff are reinstating on-site inspections at vendor facilities.
2024 Workshop
The NRC staff are currently planning the NRC’s 9th Workshop on Vendor Oversight, tentatively scheduled for June 13, 2024, in Baltimore. The anticipated attendees include industry representatives, licensees, vendors, and members of the public. More information is available at the NRC’s website, including how to submit proposed topics of discussion during the workshop, which will be accepted through January 12, 2024.