Information Notice 2025-06, 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:
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
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
NRR/DRO/
NAME
PMcKenna
DATE
7/24/2025
12/11/2025
12/12/2025