ML25218A255

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NRC Update at Pearts - Procurement Engineering and Related Topics Symposium- August 11-14, 2025
ML25218A255
Person / Time
Issue date: 08/14/2025
From: Aaron Armstrong
NRC/NRR/DRO/IQVB
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Download: ML25218A255 (21)


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NRC Update PEARTS - Procurement Engineering and Related Topics Symposium August 12-14, 2025 Clearwater, FL Aaron Armstrong Quality Assurance & Vendor Inspection Branch Office of Nuclear Reactor Regulation

Topics 2

NRC Vendor Inspection Results Update Upcoming Information Notice NEI 22-04, Revision 0 Nuclear Power Plant Restarts NRCs ILAC Process Refresher Questions

NRC Vendor Inspection Results Update 3

The following 2025 NRC Vendor Inspections that have been competed and reports have been issued:

  • Analysis & Measurement Services
  • Southwest Research Institute
  • GE Hitachi
  • Mistras
  • NuScale Aircraft Impact Assessment

NRC Vendor Inspection Results Update 4

Upcoming Inspections status:

Sargent & Lundy - Completed, Report Pending Westinghouse Electric (WEC) Company (Limerick D&IC) - In Process Element Materials Technology - Planned Operation Technology, Inc. - Planned

NRC Vendor Inspection Results Update 5

NRC Vendor Inspection Results Update 6

Flowserve (cont.)

Criterion IV, Procurement Document Control, and Criterion VII (1) Failed to invoke the applicable regulatory, technical, and quality requirements in the procurement documents for the water testing services to ensure the water meets the chemistry requirements used in the hydrostatic testing and cleaning of the safety-related components, and (2) failed to perform an assessment of the water testing supplier to verify the adequate implementation of their quality controls associated with the supply of water testing services.

NRC Inspection Findings Flowserve (cont.)

Criterion XVI, Corrective Action (1) Failed to assure that conditions adverse to quality are promptly identified and corrected (e.g., 7 CARs were past the 55-day due date with two having been opened for more than a year and (2) failed to open a CAR as identified in the 2023 and 2024 internal audits related to the CAR timeliness issue.

NRC Inspection Findings GE Hitachi Nuclear Energy Criterion XI, Test Control Specifically, after performing the hydrostatic pressure test on four cylinder and tube flange assemblies, the GEH inspector: (1) did not examine for leakage the two plug welds on each of the four cylinder tube and flange assemblies; and (2) did not verify the conductivity of the demineralized water after the hydrostatic pressure test was completed.

NRC Inspection Findings GE Hitachi Nuclear Energy Criterion XV, Nonconforming Materials, Parts, or Components Specifically, for the limited sample reviewed, (1) GEH could not locate a collet finger associated with NCR No. S-1054; and (2) GEH could not confirm that a retainer (NCR No. S-1007) and a spacer (NCR No. S-1031) were associated with these NCR Nos. because the serial numbers that provide traceability were not legible.

Upcoming Information Notice Information Notice (IN) titled Use of Approved Quality Assurance Alternatives During Exigent Conditions, expected to be issued in the Summer 2025.

The purpose of the IN is to inform the nuclear industry of the potential for inappropriate implementation of the QA alternatives approved for use during exigent conditions:

(1) Use of the QA alternatives to qualify new suppliers, and (2) licensees, applicants, and/or vendors incorrectly determining when an exigent condition exists.

The IN will provide more information on who can declare an exigent condition that will allow for the QA alternatives to be implemented.

NEI 22-04, Revision 0 On May 22, 2025, NEI submitted for NRCs review and endorsement Revision 0 of NEI 22-04, Utilization of ISO 9001 and Other Non-nuclear Suppliers for Safety-Related Applications.

The NRC staff is starting its review of the document.

No public meeting scheduled yet.

NEI 22-04 is publicly available and can be found at ADAMS Accession No. ML2516A142.

Nuclear Power Plant Restarts 12 On July 24, 2025, the NRC issued the bundle of licensing actions that reauthorizes power operations at Palisades Nuclear Plant.

Although issued, the exemptions and the license amendments are conditioned such that the plant cannot transition to an operational status before August 25, 2025, the date the licensee provided in its letter dated July 1, 2025.

The bundle consists of:

Exemption (ML25163A182)

License Transfer Application (ML25167A243)

Power Operations TS Amendment (ML25157A127)

Administrative Controls TS Amendment (ML25157A107)

Emergency Plan Amendment (ML25150A281)

MSLB Amendment (ML25156A045)

Nuclear Power Plant Restarts 13 Palisades' Restart Quality Assurance Program (RQAP).

https://www.nrc.gov/info-finder/reactors/pali.html.

Crane Clean Energy Center (TMI-1)

RQAPs submitted in December 2024 under 10 CFR 50.54(a)(3) in review.

https://www.nrc.gov/info-finder/reactors/tmi1.html NextEra considering restart of Duane Arnold No official communication to the NRC yet.

https://www.nrc.gov/info-finder/reactors/pali.html

NRCs ILAC Process Refresher Licensees, applicants, and vendors may use the ILAC accreditation as part of the commercial-grade dedication process.

Calibration and testing laboratories are accredited to ISO 17025-2017, General Requirements for the Competence of Testing and Calibration Laboratories.

Licensees, applicants, and vendors may take credit for the ILAC accreditation process in lieu of performing a commercial-grade survey.

Brief Recap Licensees, applicants, and vendors are required to meet the conditions from Revision 1 of NEI 14-05A and the NRCs SER.

Implementation Issues Identified During Vendor Inspections Identifying the conditions from Revision 1 of NEI 14-05A and the NRCs SER as the critical characteristics.

Missing some of the conditions from the procurement documents (e.g., on-site accreditation required within the last 48 months).

Not validating at receipt inspection that the purchase orders requirements were met.

Implementation Issues Identified During Vendor Inspections Referencing the 2005 edition of ISO 17025 in the procurement documents.

Not performing & documenting the receipt inspection.

Laboratory is added to the Approved Suppliers List as a safety-related vendor.

Important Things To Be Aware Of Limitations of Use:

The NRCs approval for using the ILAC accreditation process can only be implemented by a supplier who has a QA program that meets Appendix B to 10 CFR Part 50.

The ILAC accreditation process cannot be used as part of the commercial-grade dedication of NDE or NDT services.

Important Things To Be Aware Of ASME incorporated the ILAC accreditation process into Subsection NCA, General Requirements for Division 1 and 2.

NQA-1 also incorporated the ILAC accreditation process in the 2017, 2019, and 2022 edition in Subpart 2.19.

Revision 6 of Regulatory Guide 1.28 imposes a condition that Revision 1 of NEI 14-05A be used instead of Subpart 2.19.

Final Thoughts The use of the ILAC accreditation process in lieu of performing a commercial-grade survey as part of the commercial-grade dedication process is an ALTERNATIVE.

Licensees, applicants, and vendors are NOT REQUIRED to implement the ILAC accreditation process, but if they choose to, then they need to meet the requirements from Revision 1 of NEI 14-05A and the NRCs SER.

21 Aaron Armstrong Reactor Operations Engineer (301) 415-8396 Aaron.Armstrong@nrc.gov