ML19119A259
| ML19119A259 | |
| Person / Time | |
|---|---|
| Site: | Holtec |
| Issue date: | 04/26/2019 |
| From: | Singh K Holtec |
| To: | Michael Layton Division of Spent Fuel Management |
| Marcano D | |
| References | |
| IR 2018201 | |
| Download: ML19119A259 (2) | |
Text
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ Telephone (856) 797-0900 Fax (856) 797-0909 April 26, 2019 Mr. Michael C. Layton, Director Via Email:
Division of Spent Fuel Management Michael.Layton@nrc.gov Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738
Subject:
Holtec International - Notice of Violation; U.S. Nuclear Regulatory Commission Inspection Report No. 07201014/2018-201 Division of Spent Fuel Management
Reference:
Holtec Project #5014
Dear Director Layton:
We thank you for your letter of April 24, 2019 on the above-referenced subject matter. We accept NRCs characterization of the violations and of our investigations and evaluations that followed the discovery of the shim stand-off issue, including the root cause evaluation and corrective action efforts. We appreciate the credit granted to us for the proactive corrective action implementations made by us and represent to you that all remedial actions arising from the shim stand-off episode documented in our QI#2471 have been fully integrated into the infrastructure of our QA program. A formal response as requested in your letter will follow within 30 days.
We would welcome NRCs validation of our QA upgrades to ensure unconditional compliance through future scheduled or unscheduled inspections. We are certain that the NRCs inspection team will confirm that we are not only in comprehensive compliance with our representations made to the NRC regarding the corrective actions arising from this issue but have made many other enhancements as a part of our continuous improvement program to insure that our QA program remains state-of-art. In particular, our recent emphasis has been in erecting more effective barriers against human performance errors (of the sort that led to the shim stand-off
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Mr. Michael C. Layton, Director Page Two April 26, 2019 issue) throughout the life cycle of the product - from design conceptualization - to site commissioning.
We are heartened to note that NRC agreed with our technical position that the presently deployed MPCs equipped with the shim stand-offs meet all applicable regulatory criteria.
Again, we thank you for your balanced evaluation and fact-based conclusions to close out this subject matter.
Sincerely, Dr. Kris Singh, President & CEO Holtec International cc:
Dr. Stefan Anton Kim Manzione Mark Soler EXCOM Document No. 5014872