ML19087A099

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Letter to K. Singh Holtec International Pre-decisional Enforcement Conference Summary (W/Enclosure)
ML19087A099
Person / Time
Site: Holtec
Issue date: 03/29/2019
From: Michael Layton
Division of Spent Fuel Management
To: Singh K
Holtec
Terry T
Shared Package
ML19087A097 List:
References
EA-18-151
Download: ML19087A099 (5)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 29, 2019 EA-18-151 Dr. K. P. Singh President and CEO Holtec International Krishna P. Singh Technology Campus 1 Holtec Boulevard Camden, NJ 08104

SUBJECT:

HOLTEC INTERNATIONAL PREDECISIONAL ENFORCEMENT CONFERENCE

SUMMARY

Dear Dr. Singh:

On January 9, 2019, the U.S. Nuclear Regulatory Commission (NRC) staff held a Predecisional Enforcement Conference (PEC) with you and members of your staff at the NRC Headquarter Office in Rockville, Maryland. The PEC was requested by Holtec International (Holtec) following the issuance of the NRCs Choice Letter EA-18-151. The apparent violations are related to Holtecs failure to: (1) establish adequate design control measures as a part of the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the functions of the structures, systems, and components which are important to safety, in accordance with 10 CFR 72.146(a), Design control, and (2) failure to perform a 10 CFR 72.48 evaluation when required. The Choice Letter EA-18-151 was dated November 29, 2018, and is available from the NRCs website, www.nrc.gov, under the Agencywide Documents Access and Management System Accession No. ML18306A853.

A brief summary of the PEC proceedings is enclosed.

No response to this letter is required. Please contact Mr. Christian Araguas of my staff at (301) 415-7210 or by e-mail at Christian.Araguas@nrc.gov.

Sincerely,

/RA/

Michael C. Layton, Director Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 72-1014

Enclosure:

PEC Summary

ML19087A097 LTR: ML19087A099 OFFICE NMSS/DSFM NMSS/DSFM NMSS/DSFM NMSS/MSST NMSS/DSFM NMSS/DSFM NAME TTerry WWheatley ELove MBurgess DMarcano MLayton DATE 03/28/2019 03/29/2019 03/28/2019 03/28/2019 03/29/2019 03/29/2019 PREDECISIONAL ENFORCEMENT CONFERENCE

SUMMARY

Licensee: Holtec International Facility: Krishna P. Singh Technology Campus, located in Camden, New Jersey License No.: N/A Docket No.: 72-1014 EA-18-151 On November 29, 2018, the NRC issued Holtec a Choice Letter EA-18-151 (Agencywide Documents Access and Management System (ADAMS) No. ML18306A853) describing two apparent violations under consideration for escalated enforcement action in accordance with the NRC Enforcement Policy. The apparent violations involve: (1) failure to establish adequate design control measures as a part of the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the functions of the structures, systems, and components which are important to safety, in accordance with 10 CFR 72.146(a),

Design control, and (2) failure to perform a 10 CFR 72.48 evaluation when required.

The letter transmitting the inspection report provided Holtec with the opportunity to address the apparent violations identified in the report by either: (1) attending a Pre-decisional Enforcement Conference (PEC), or (2) participating in an Alternative Dispute Resolution session prior to our final enforcement decision. In a letter dated December 3, 2018, (ADAMS Accession No. ML18341A126) Holtec requested a PEC.

On January 9, 2019, a PEC was convened at the NRC Headquarters. The purpose was to provide an opportunity for Holtec to provide any information that they would like NRC to consider in the final enforcement determination, including determining whether an enforcement action is necessary. The PEC focused on areas such as (1) a common understanding of the facts and root causes, and (2) a common understanding of Holtecs corrective actions taken or planned. No decisions were reached or discussed during the conference.

The attendance list, the NRC's presentation, and the Holtecs presentation are attached to this summary. The attendance list is Enclosure 1. NRCs presentation is Enclosure 2, and Holtecs presentation is Enclosure 3. The PEC transcript is available in ADAMS (Accession No. ML19088A271).

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this summary and its enclosures will be made available to the Public.

Enclosures:

1. Attendance List
2. NRCs Presentation
3. Holtecs Presentation

Holtec Predecisional Enforcement Conference Public Meeting Attendance List Name Affiliation Michael Layton U.S. Nuclear Regulatory Commission (NRC)

Christopher Regan NRC Paul Peduzzi NRC Patricia Silva NRC Michele Burgess NRC Earl Love NRC Marlone Davis NRC Jorge Solis NRC Antonio Rigato NRC Wendy Reed NRC Meraj Rahimi NRC Jeremy Tapp NRC Jon Woodfield NRC Chris Bajwa NRC John McKirgan NRC David Jones NRC Yoira Diaz-Sanabria NRC Darrell Dunn NRC Carla Roque-Cruz NRC David McIntyre NRC Lorraine Baer NRC Tomeka Terry NRC Krishna Singh Holtec International (Holtec)

Kimberley Manzione Holtec Mark Soler Holtec Robert Tindal Holtec Stefan Anton Holtec Fredrick Bidrawn Holtec Debabrata Mitramajumdar Holtec Abrar Mohammad Holtec Charles Bullard II Holtec Venkat Prabhala Holtec Pamela Cowan Holtec Robert Mahorter Holtec Pankaj Chaudhary Holtec Joy Chaudhary Holtec Stephen Agace Holtec Christopher OMullane Holtec

Name Affiliation Howard Lambersky Holtec Steven Magown Holtec Andrew Fecht Holtec Kevin Landis Holtec Adam Wisniewski Holtec Rick Trotta Holtec Omar Quyyum Holtec Umang Parikh Holtec Adam Levin AHL Consulting Randall Granaas SCE Richard Chang SCE Allen Williams SCE Mark Morgan SCE Al Bates SCE Richard Chang SCE Sylvia Groves SCE Julie Holt SCE Robert Quinn Westinghouse Electric Company Sylena Smith Westinghouse Electric Company Sandra Christianson Energy Northwest Gabriel Chavez Exelon George Gellrich Exelon Eric Stein Exelon Don Shaw TN Americas LLC Charlie Gear Entergy Suzanne Leblang Entergy Susan Raimo Entergy Mandy Halter Entergy Kenneth Swanger Entergy John Skonieczny Entergy Glenn Schwartz PSEG Nuclear, LLC Coley Chappell PSEG Nuclear, LLC Tony Leshinskie Vermont Yankee Gina Haub STP Nuclear Operating Company Steve Maheras Pacific Northwest National Laboratory Brian Gutherman Gutherman Technical Services, LLC Ling Huan Chiao TECRO Andrea Jennetta Taucher International Donald Graf MPR Associates Inc Shari Day Structural Integrity Associates, Inc

Name Affiliation Jerry Humpheys New Jersey Department of Environmental Protection Justin Cochran California Energy Commission Steve Carlson University of California Reihani Seyed University of Illinois Philippe Soenen Pacific Gas & Electric Company Clay Turnbull New England Coalition on Nuclear Pollution Raymond Shadis New England Coalition Charles Langley Public Watch Dog Mary Brangan Ecological Options Network Gary Headrick San Clemente Green Mary Brangan Ecological Options Network Marvin Lewis Members of Public Elizabeth Andrews Members of Public Ron Rodarte Members of Public Nina Babiarz Members of Public Michael Keegan Members of Public Lindsay Bazett Members of Public Sarah Brady Members of Public Patricia Borchmann Members of Public Rich Van Every Members of Public Chris Gorman Members of Public Roger Johnson Members of Public Nana Vadiar Members of Public Bill Weigel Members of Public Chris Gorman Members of Public Gerges Scott Members of Public Raymond Lutz Members of Public Mike Faher VTDigger Linda Chou Energy Solutions Zita Martin Tennessee Valley Authority Mark Ritcher NEI Ted Quinn SONGS CEP Member Marty Scott Xcel Nuclear Will Phillips Southern Nuclear Dry Storage Steve Mannon AECOM Robert Fraser AECOM Paul Gunter Beyond Nuclear Donna Gilmore San Onofre Safety