The NRC’s focus on nuclear power plant safety doesn’t stop at the plants. Since the 1970s (at that time under the Atomic Energy Commission), NRC inspectors have kept a watch on the companies that provide safety-related components and services to U.S. plants.
The agency believes plants and vendors have effective quality assurance programs in place to proactively prevent the use of counterfeit, fraudulent and suspect items. These programs include careful supplier selections, effective oversight of sub-suppliers, and the authority to challenge a part’s “pedigree” when necessary.
The NRC oversees these quality activities by inspecting nuclear power plants and their vendors. Vendor inspection can include site visits to production facilities. We create and share information and guidance for the nuclear industry to improve detection of counterfeit and fraudulently marketed products. We also incorporate this information into our inspection programs. The NRC has yet to see any instance of these items in safety-related systems in U.S. plants, but constant vigilance by the licensees and the NRC is essential to make sure it stays that way.
These days our Vendor Inspection Center of Expertise operates out of the Office of New Reactors to cover both operating reactors and those under construction. NRC staff experts inspect vendors, and observe when plants audit their suppliers, to determine if the plants are properly overseeing their supply chain. Importantly, the NRC also verifies that the plants and their vendors comply with our quality assurance criteria and our “Part 21” requirements for reporting defects and noncompliance, as well as applicable codes and standards.
The center’s staff also inspect companies applying for design certificates, early site permits or combined licenses. We check on whether the applicants have effective quality assurance processes and procedures for activities related to their applications.
Right now, we’re working on several vendor-related issues, including evaluating the industry’s process for safely upgrading commercial products that aren’t specifically made for nuclear applications to be used in some plant systems. Common items such as gaskets, nuts and bolts, and electrical relays could be acceptable for nuclear plant use, for example.
We’re updating and simplifying Part 21, the NRC regulation that covers counterfeit, fraudulent and suspect items. We’re also confirming effective controls are in place to prevent such items from making their way into the U.S. safety-system supply chain. We’re clarifying the processes for evaluating and reporting defects, and the acceptance criteria for off-the-shelf commercial products. The Center is developing regulatory guides so plants and vendors better understand these processes.
The NRC’s vendor workshop in Portland, Ore., gave us a forum to put this issue in the spotlight. Among a range of vendor topics, this year’s workshop included an industry perspective on counterfeit, fraudulent, and suspect items.
The NRC has also been actively involved with our international partners to address the risk of counterfeit and fraudulent items. We’ve collaborated with the International Atomic Energy Agency and the Nuclear Energy Agency to share best practices and recommend options to strengthen inspection programs and increase information sharing.