Information Notice 2025-06, Lessons Learned from U.S. Nuclear Regulatory Commission Inspections of Commercial Grade Dedication at Nuclear Power Plants

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Lessons Learned from U.S. Nuclear Regulatory Commission Inspections of Commercial Grade Dedication at Nuclear Power Plants
ML25169A315
Person / Time
Issue date: 12/12/2025
From: Philip Mckenna
NRC/NRR/DRO
To:
References
IN-2025-06
Download: ML25169A315 (4)


ML25169A315 UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, DC 20555-0001 December 12, 2025

INFORMATION NOTICE 2025-06: LESSONS LEARNED FROM U.S. NUCLEAR

REGULATORY COMMISSION INSPECTIONS

OF COMMERCIAL GRADE DEDICATION AT

NUCLEAR POWER PLANTS

ADDRESSEES

All holders of operating licenses, construction permits, or combined licenses for nuclear power

reactors, except those that have permanently ceased operations and have certified that fuel has

been permanently removed from the reactor vessel.

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to alert

addressees to recent information related to lessons learned from NRC inspections of

commercial grade dedicated items at nuclear power plants. The NRC expects that addressees

will review the information for applicability to their facilities and consider actions, as appropriate, to identify and address similar issues. Suggestions contained in this IN are not NRC

requirements. Therefore, no specific action or written response is required.

DESCRIPTION OF CIRCUMSTANCES

Recently, the NRC staff initiated an update to the Reactor Oversight Process engineering

inspections in furtherance of the NRC safety mission. One of the new inspection programs

relates to Commercial Grade Dedication (CGD) as described in Attachment 21N.03, Commercial Grade Dedication, to NRC Inspection Procedure (IP) 71111, Reactor Safety

Initiating Events, Mitigating Systems, Barrier Integrity. In particular, the NRC issued IP

71111.21N.03 to review the implementation of the licensees process for dedicating commercial- grade items (CGIs), as defined in Title 10 of the Code of Federal Regulations (10 CFR) Part 21, Reporting of Defects and Noncompliance, and required to be conducted in accordance with

the applicable provisions of Appendix B to 10 CFR Part 50 (Appendix B) to provide reasonable

assurance that CGIs will perform their intended safety function.

During public meetings in late 2022 and early 2023 (for example, see Agencywide Documents

Access and Management System (ADAMS) Accession Nos. ML22258A010, ML22270A076 and

ML23023A243), the NRC staff described the objectives and intent of the IP 71111.21N.03 inspections, and indicated that lessons learned from those inspections would be made available

to stakeholders. NRC staff began implementing IP 71111.21N.03 in January 2023, with the

inspection to be conducted once at each operating power reactor site in the inspection cycle

ending December 31, 2026.

DISCUSSION

The NRC staff conducted inspections using IP 71111.21N.03 to review the

implementation of the licensees process for dedicating CGIs. The NRC staff also

conducted these inspections to review implementation of the licensees procurement

process for safety-related components as required in Appendix B or 10 CFR 50.69, Risk- informed categorization and treatment of structures, systems and components for nuclear

power reactors.

Initial NRC inspections using IP 71111.21N.03 identified numerous lessons learned

related to CGIs at the sampled nuclear power plants. The following is a summary of the

major lessons learned:

1. The NRC inspections found that some licensees did not identify and/or evaluate

critical characteristics of CGIs contrary to 10 CFR, Part 50, Appendix B, Criterion III,

Design Control, or Criterion IV, Procurement Document Control. Examples

included:

Failure to ensure design basis temperature requirements for safety injection tank

vent to containment valve diaphragms were included in documentation for

diaphragm replacement.

Prescribing incorrect electrical insulation testing in procurement documentation.

Failure to ensure the applicable design basis was correctly translated into

specifications, drawings, and instructions for reverse engineering activities on

safety-related electronic circuit boards.

Failure to ensure new filter-drier designs were suitable for safety chiller use.

Failure to ensure the control of unidentified embedded digital devices in the

design and testing of commercial grade components.

Failure to provide objective evidence of quality for lubricants prior to their

application in final component installation.

Failure to ensure that applicable regulatory requirements and the design basis

were correctly translated into specifications, drawings, and procedures used to

ensure 700-RTC relay circuits were installed correctly.

2. The NRC inspections found that some licensees did not furnish evidence or did not

conform to certain documents contrary to 10 CFR Part 50, Appendix B, Criterion

XVII, Quality Assurance Records, or Criteria VII, Control of Purchased Material, Equipment, and Services. Also, the NRC inspections found that some licensees

failed to include appropriate quantitative or qualitative acceptance criteria in a

procedure affecting quality contrary to 10 CFR Part 50, Appendix B, Criterion V,

Instructions, Procedures, and Drawings. Some specific examples were:

Failure to retain commercial grade surveys and source surveillances for the life of

commercially dedicated basic components. *

Failure to provide commercial grade dedication surveys for demonstrating that Flexitallic

gaskets procured from a commercial vendor were manufactured to meet the critical

characteristics necessary for the gaskets to perform their safety function in installed

applications.

Failure to include appropriate acceptance criteria in a service water strainer

maintenance procedure to establish that emergency core cooling system service water

strainer inspections were satisfactorily accomplished.

Failure to include the appropriate critical characteristics to be verified of commercially

purchased items in a quality receipt inspection procedure used in the dedication of items

for installation in safety-related applications. This led to the installation of commercial

grade items on safety-related equipment prior to completing the required dedication

activities.

3. The inspectors identified a non-cited violation (NCV) of 10 CFR Part 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, for the licensees failure to

ensure activities affecting quality were prescribed by documented instructions and

procedures appropriate to the circumstance. Specifically, the licensee failed to

ensure the instructions prescribed in procedures appropriately verified the critical

characteristics of commercially purchased items while dedicating the items for

installation in safety-related applications. This led to commercial items being installed

on safety-related equipment prior to completing required dedication activities.

The NRC staff suggests that licensees review this information for applicability to their facilities

and consider actions, as appropriate, to identify and address similar issues. Review and

consideration of the information in this IN will support CGD inspections at licensee facilities.

CONTACT

S

This IN requires no specific action or written response. Please direct any questions about this

matter to the technical contacts listed below or to the appropriate Office of Nuclear Reactor

Regulation (NRR) project manager.

/RA/

Philip J. McKenna, Acting Director

Division of Reactor Oversight

Office of Nuclear Reactor Regulation

Technical Contacts:

Douglas Bollock, NRR

Amar Patel, NRR

301-415-6609

610-337-5220

Douglas.Bollock@nrc.gov

Amar.Patel@nrc.gov

Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections. SUBJECT: NRC INFORMATION NOTICE 2025-06, LESSONS LEARNED FROM U.S.

NUCLEAR REGULATORY COMMISSION INSPECTIONS OF COMMERCIAL

GRADE DEDICATION AT NUCLEAR POWER PLANTS DATE: DECEMBER 12,

2025

ADAMS Accession No.: ML25169A315

EPID No.: L-2025-GEN-0002 OFFICIAL USE ONLY

OFFICE

QTE

NRR/DRO/IRIB

NRR/DRO/IRIB

NRR/DRO/IRIB

NRR/DRO/IOEB

NAME

APatel

DBollock

HJones

PClark

DATE

11/18/2025

6/23/2025

06/23/2025

6/23/2025

6/18/2025 OFFICE

OCIO

OE

NRR/DRO/IOEB

NRR/DRO/IOLB

NRR/DRO/IOEB

NAME

KBenney

JPeralta

AMivanyi

IBetts

RSigmon

DATE

7/2/2025

6/26/2025

12/11/2025

12/11/2025

12/12/2025 OFFICE

OGC

OIRA

NRR/DRO/

NAME

PMcKenna

DATE

7/24/2025

12/11/2025

12/12/2025