In nuclear quality programs, the identification of a nonconformance is not the end of a problem, it is the beginning of a controlled process. The Non-Conformance Report (NCR) is the mechanism by which that process is initiated, tracked, and closed. NQA-1 Requirement 15 and 10 CFR 50 Appendix B Criterion XV require nuclear organisations to maintain a documented nonconformance control program. The quality of that program, how consistently it identifies issues, how rigorously it evaluates them, and how reliably it closes them, is a primary indicator of overall program health.
The NCR lifecycle
An NCR does not exist in isolation. It moves through a defined sequence of states, and the program's ability to manage that movement, without items ageing out, without dispositions going unreviewed, without close-out steps being skipped, is what regulators assess.
Any personnel can initiate an NCR when a nonconformance is observed. The item, service, or process is identified, tagged (where physical), and the NCR is formally raised in the quality management system.
The NCR is fully documented: what was observed, what requirement was not met, which specification or drawing was the baseline, where and when the nonconformance was found.
A qualified engineer evaluates the nonconformance and assigns a disposition: Use As Is (with safety justification), Repair, Rework, or Reject/Scrap. Use As Is dispositions require documented engineering basis.
The disposition is implemented: the item is repaired, reworked, accepted with justification, or removed from service. Resolution is documented and verified by the appropriate authority.
The NCR is formally closed with evidence of resolution attached. Records are retained in accordance with the QA records program (NQA-1 Req. 17 / Appendix B Criterion XVII).
Closed NCRs feed into the Corrective Action Program for trend analysis. Recurring nonconformances in the same area may indicate a systemic issue requiring a formal corrective action.
NQA-1 Requirement 15 vs. 16: Requirement 15 governs nonconforming items, identifying, segregating, and dispositioning them. Requirement 16 governs corrective action, the systemic response to conditions adverse to quality. An NCR that reveals a pattern of similar issues should trigger a Corrective Action, moving the issue into the CAP for root cause analysis and long-term resolution.
NCR dispositions explained
The disposition assigned to an NCR determines how the nonconformance is resolved. Each disposition carries different requirements for documentation and approval authority.
Use As Is: The item does not meet the original specification but is accepted in its current condition. This disposition requires a documented engineering evaluation that justifies why the item still meets its safety function and applicable codes. Use As Is dispositions are scrutinised closely during audits, the justification must be technically sound and traceable.
Repair: The item is restored to an acceptable condition, but through a method that differs from the original fabrication requirement. A repair procedure must be developed and approved before work begins, and the repaired item must be re-inspected.
Rework: The item is brought into full conformance with the original requirement using standard processes. The simplest disposition operationally, but it requires verification that the reworked item now meets the full specification.
Reject / Scrap: The item cannot be dispositioned for use. It is removed from the program, marked or segregated to prevent inadvertent use, and disposed of in accordance with program requirements.
Why regulators look at NCR programs carefully
NCR program health is a leading indicator of overall quality program effectiveness. An organisation that consistently identifies nonconformances, resolves them within their stated timelines, and mines the data for systemic trends is demonstrating that the quality culture is working as intended. Conversely, NCR programs with high volumes of aged-out items, pattern failures in the same area, or superficial dispositions signal a program under strain.
NRC inspection data shows that Criterion XV findings are among the most common, and they typically manifest in one of three ways: nonconformances that were observed but not formally raised (indicating a cultural problem with identification), items dispositioned but not resolved within the stated timeline, or Use As Is dispositions that lack adequate technical justification.
For suppliers, the stakes are equally high. A nuclear buyer's supplier qualification process will assess the supplier's NCR program, both in initial qualification surveys and ongoing surveillance. Suppliers with poor NCR management are a liability for buyers who are held accountable by the regulator for the quality of purchased items.
Forged Operations manages the full NCR lifecycle, from initiation through disposition, resolution, and close-out. AI reads across quality records to flag NCRs approaching their resolution window, identify patterns across suppliers, and surface issues before they become findings.
References
- American Society of Mechanical Engineers. ASME NQA-1-2022: Quality Assurance Requirements for Nuclear Facility Applications, Requirement 15 — Control of Nonconforming Items. New York: ASME, 2022.
- U.S. Nuclear Regulatory Commission. "Criterion XV — Nonconforming Materials, Parts, or Components." Code of Federal Regulations, 10 CFR 50 Appendix B. Washington, D.C.: NRC.
- U.S. Nuclear Regulatory Commission. "Inspection Procedure 88045 — Nonconforming Materials, Parts, or Components." NRC Inspection Manual. Washington, D.C.: NRC.
- CSA Group. CSA N286:12 (R2018): Management System Requirements for Nuclear Facilities, Clause 7.3 — Nonconformance Control. Toronto, Ontario: CSA Group.