IR 05000219/2023002

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EA-23-076 Oyster Creek Nuclear Generating Station - Notice of Violation and Proposed Imposition of Civil Penalty - $43,750 - NRC Inspection Report No. 05000219/2023002
ML23306A127
Person / Time
Site: Oyster Creek
Issue date: 11/09/2023
From: Ray Lorson
NRC Region 1
To: Trice K
Holtec Decommissioning International
References
EA-23-076 IR 2023002
Download: ML23306A127 (1)


Text

November 9, 2023

SUBJECT:

OYSTER CREEK NUCLEAR GENERATING STATION - NOTICE OF VIOLATION AND PROPOSED IMPOSITI ON OF CIVIL PENALTY - $43,750 -

NRC INSPECTION REPORT NO. 05000219/2023002

Dear Kelly Trice:

This letter refers to the inspection conducted by the U.S. Nuclear Regulatory Commission (NRC) at the Oyster Creek Nuclear Generating Station (Oyster Creek) between January 1 -

June 30, 2023. The purpose of the inspection was to examine activities conducted under your license as they relate to safety and compliance with the NRCs rules and regulations and the conditions of your license.

Based on the results of the inspection, the NRC staff identified one apparent violation (AV) of NRC requirements. The NRC staff discussed this AV with members of your staff during the inspection exit meeting on July 11, 2023. The AV was described in the inspection report sent to you with a letter dated August 22, 2023 (ML23214A247). 1 The AV involved the failure by Holtec Decommissioning International, LLC (HDI) staff at Oyster Creek to prepare radioactive materials for shipment so that under conditions normally incident to transportation the radiation level did not exceed 200 millirem/hour (mrem/h) at any point on the external surface of the package, as required by Section 173.441 of Title 49 of the Code of Federal Regulations (49 CFR). Pursuant to 10 CFR 71.5, licensees who transport licensed materials on public highways must comply with the requirements of the U.S. Department of Transportation (DOT) regulations in 49 CFR Parts 171 through 180.

In the August 22, 2023, letter transmitting the inspection report, we informed you that the AV was being considered for escalated enforcement action, including a civil penalty. In the letter, we provided you the opportunity to address the AV identified in the report by either attending a pre-decisional enforcement c onference, engaging the NRC in Alternative Dispute Resolution (ADR) mediation, or by providing a written response before we made our final enforcement decision. In a letter dated September 6, 2023 (ML23249A121), HDI provided a response to the AV and described the root cause as a deficiency in the radioactive material shipping procedure,

1 Designation in parentheses refers to an Agency-wide Documents Access and Management System (ADAMS) accession number. Documents referenced in this letter are publicly-available using the accession number in ADAMS.

Kelly Trice 2

which, contrary to industry guidelines, did not require a final verification survey of the transportation package in all instances. HDI also noted contributing causes involving inadequacies with oversight, risk determination, coordination, communication, and procedure adherence. In addition, HDI described the actions taken and planned to prevent recurrence of the issues that led to the AV.

Based on the information developed during the inspection and the information that you provided in your written response to the inspection report dated September 6, 2023, the NRC has determined that a violation of NRC requirements occurred and is proceeding with enforcement action. The violation is cited in the Notice of Violation and Proposed Imposition of Civil Penalty (Notice) provided as Enclosure 1. The circumstances surrounding the violation are described in detail in the subject inspection report. As stated above, the violation involved the failure by HDI staff at Oyster Creek to prepare radioactive materials for shipment so that under conditions normally incident to transportation the radiation level did not exceed 200 mrem/h at any point on the external surface of the package. Specifically, on May 3, 2023, HDI staff at Oyster Creek shipped reactor segmentation tooling to the Indian Point Energy Center (Indian Point) in an Open Transport vehicle. The segmentation tool was packaged in an Industrial Package Type IP-1 package (i.e., a reinforced polyethylene bag). The radiation survey to verify that the contact dose rates on the loaded package were within regulatory limits was performed by HDI staff at Oyster Creek on the packaged tool prior to the package being strapped down in its final shipping configuration. This survey identified a maximum contact dose rate of 120 mrem/h. The initial receipt survey performed by HDI staff at Indian Point identified a maximum contact dose rate of 450 mrem/h on top of the package, which exceeds the 200 mrem/h limit specified in 49 CFR 173.441. HDI staff at Indian Point initiated actions to properly control the item and notified Oyster Creek staff and, subsequently, the NRC of this event.

The NRC considered that the failure to perform an adequate survey by HDI staff at Oyster Creek resulted in a shipment that exceeded NRC and DOT regulatory limits, which potentially could have caused individuals associated with or in close proximity to the shipment to have received unintended and excess radiation expos ure. Therefore, the NRC has assessed this violation at Severity Level (SL) III, in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.

In accordance with the civil penalty assessment process in Section 2.3.4 of the Enforcement Policy, a base civil penalty in the amount of $43,750 is typically considered for an SL III violation by an independent spent fuel storage installation (ISFSI) facility (see Tables 8A.c and 8B of the Enforcement Policy). For the purposes of determining the appropriate civil penalty category in Table 8A, the NRC staff considered that at the time of the violation, Oyster Creek had removed all fuel from the reactor vessel, completed the transfer of all irradiated fuel to the on-site ISFSI and had received related NRC license amendments documenting changes to major programs supporting the transition from power operations to decommissioning. Therefore, the NRC concluded that it was appropriate to consider Oyster Creek under the ISFSI civil penalty category in this case.

Kelly Trice 3

Because your facility has been the subject of escalated enforcement actions within the last two years,2 the NRC considered whether credit is warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section 2.3.4 of the Enforcement Policy. The NRC determined that identification credit is not warranted because the violation was revealed through an event. The NRC has concluded that credit is warranted for HDIs corrective actions taken to address this specific violation. Namely, as described in HDIs letter dated September 6, 2023, HDI revised its shipping procedures to emphasize the potential for soft-sided package geometry to be changed during the process of securing the package for transport and to require a verification shipping survey after the package has been secured. The HDI letter described additional planned actions, to include: (1) training radiation protection technicians and supervisors on the potential for soft-sided packaging geometry to change during the shipping process; (2) establishing a pre-job briefing process for all shipping activities; (3)

developing a risk assessment procedure for shipments from decommissioning sites; (4)

establishing a loading plan process for shipments to coordinate the activities of all involved parties; and (5) elevating the shipping procedure classification from information use to reference use.

Therefore, to emphasize the importance of compliance with limits on radiation levels and of prompt identification of violations, and in recognition of your previous escalated enforcement action, I have been authorized, after consultation with the Director, Office of Enforcement, to issue the Notice of Violation and Proposed Imposition of Civil Penalty (Notice) provided as Enclosure 1, in the base amount of $43,750 for the SL III violation. In addition, issuance of this Notice constitutes escalated enforcement action that may subject you to increased inspection effort. This civil penalty follows multiple escalated enforcement actions within a two year period and suggests that HDI may consider additional actions to prevent future escalated enforcement actions.

The NRC staff considered HDIs request in its September 6, 2023, letter that the NRC not propose a civil penalty. Specifically, HDI noted that this shipping violation occurred on May 3, 2023, and the incident associated with the previous escalated enforcement action occurred on May 7-8, 2021 (which is almost outside the two-year window). HDI also noted that Oyster Creek has had no previous shipping violations despite conducting about 200 radioactive shipments per year since entering decommissioning. Finally, HDI offered that Indian Point (another HDI facility)

identified the violation and that robust corrective actions would prevent reoccurrence of this issue.

Regarding HDIs previous escalated enforcement action at Oyster Creek, Section 2.3.4 of the Enforcement Policy states that for an NRC-identified violation, the starting point of the two-year assessment period is when the NRC puts the licensee on notice of the need to take corrective action, which is typically at the inspection exit meeting. Because the inspection exit meeting for the May 2021 incident took place on July 15, 2021, that is the appropriate starting point for the two-year review period. Furthermore, as noted in the Enforcement Policy, the process considers whether the licensee has had any previous escalated enforcement action regardless of the activity area. Therefore, all past escalated actions are considered, not just those involving transportation or radiological surveys.

Regarding identification of the issue by HDI staff at Indian Point, the NRC staff noted that the staff at Indian Point did not initially identify that the situation involved a violation of NRC requirements. That failure resulted in the issuance of a violation to Indian Point (ML23215A139)

2 An escalated enforcement action was issued on December 21, 2021 (EA-21-093) involving security-related violations.

Kelly Trice 4

for failure to immediately report the occurrence to the NRC as required by 10 CFR 20.1906(d)(2). Moreover, the NRC staff considered the following applicable factors in Section 2.3.4.b of the Enforcement Policy for determining whether identification credit was warranted:

a) Whether the problem requiring corrective acti on was identified by the NRC, identified by the licensee, or revealed through an event. Because this violation was identified by a third-party after the shipment had occurred on public highways, the NRC staffs view is that the problem is best classified as involving an event. The Enforcement Policy defines an event, in part, as a radiological impact on personnel or the environment in excess of regulatory limits. This issue involved a shipment that exceeded NRC and DOT dose rate limits.

b) Whether prior opportunities existed to identify the problem requiring corrective action, and if so, the age and number of those opportunities. Prior opportunities existed for HDI staff at Oyster Creek to identify the probl em through proper performance of the shipping survey.

d) For a problem revealed through an event, the ease of discovery and the degree of licensee initiative in identifying the root cause of the problem and any associated violations. The licensee would have readily identified the violation if a proper survey had been performed after the package was loaded for transport.

Based on the above considerations, the NRC staff c oncluded that credit for identification is not warranted. As discussed above, the NRC staff determined that credit for corrective action was warranted based on HDIs actions both taken and planned in response to this issue.

You may choose to pay the proposed civil penalty by submitting your payment, with the invoice enclosed to this letter (Enclosure 2), to the following address:

Office of the Chief Financial Officer U.S. Nuclear Regulatory Commission P.O. Box 979051 St. Louis, MO 63197

In addition, you may pay the proposed civil penalty in accordance with NUREG/BR-0254, Payment Methods, provided as Enclosure 3. When using NUREG/BR-0254 to pay the civil penalty, the invoice number should be used as the enforcement action identifier when submitting your payment through one of the app roved methods listed in the brochure. The NRC may consider a request for additional time to pay the proposed civil penalty, including the option to enter into an installment agreement, if payment of the civil penalty as a lump sum in the required timeframe would pose a financial hardship. To request additional time to pay, you must submit a written request, with appropriate justification explaining your financial hardship, to NRCCollections.Resource@nrc.gov. All requests should be submitted in sufficient time to allow the NRC the ability to review your request for ad ditional time to pay before the 30-day payment period expires.

If you disagree with this enforcement sanction, you may deny the violation, as described in the Notice, or you may request ADR with the NRC in an attempt to resolve this issue. ADR is a general term encompassing various techniques for resolving conflicts using a neutral third party.

The technique that the NRC has decided to employ is mediation. Mediation is a voluntary, informal process in which a trained neutral third party (the mediator) works with all parties to Kelly Trice 5

help them reach resolution. If the parties agree to use ADR, they select a mutually agreeable neutral mediator who has no stake in the outcome and no power to make decisions. Mediation gives parties an opportunity to discuss issues, clear up misunderstandings, be creative, find areas of agreement, and reach a final resolution of the issues. Additional information concerning the NRC's ADR program can be found at http://www.nrc.gov/about-nrc/regulatory/enforcement/adr.html.

The Institute on Conflict Resolution (ICR) at Cornell University has agreed to facilitate the NRC's program as a neutral third party. If you are interested in pursuing this issue through the ADR program, please contact: (1) the ICR at (877) 733-9415; and (2) Anthony Dimitriadis at (610) 337-6953 or Anthony.Dimitriadis@nrc.gov within 10 days of the date of this letter. You may also contact both ICR and Anthony Dimitriadis for additional information. Your submitted signed agreement to mediate using the NRC ADR program will stay the 30-day time period for payment of the civil penalty and the written response (if you choose to provide one), as identified in the enclosed Notice, until the ADR process is completed.

The NRC has concluded that information regarding : (1) the reason for the violation, or if contested, the basis for disputing the violation; (2) the corrective steps that have been taken and the results achieved; and (3) the corrective steps that will be taken; and (4) the date when full compliance was achieved is already adequately addressed on the docket in Inspection Report No. 05000219/2023002 and in your letter dated September 6, 2023. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room and from the NRCs Agencywide Documents Access and Management S ystem (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, any response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. The NRC also includes significant enforcement actions on its website at https://www.nrc.gov/about-nrc/regulatory/enforcement/current.html.

Kelly Trice 6

If you have any questions concerning this matter, pl ease contact Anthony Dimitriadis of my staff at 610-337-6953 or Anthony.Dimitriadis@nrc.gov.

Sincerely, Raymond K. Lorson Regional Administrator Enclosures:

1. Notice of Violation 2. Civil Penalty Invoice 3. NUREG/BR-0254, Payment Methods

Docket No. 50-219 License No. DPR-16

cc w/encl: Distribution via ListServ

ML23306A127 X Non-Sensitive X Publicly Available X SUNSI Review/ MMM Sensitive Non-Publicly Available

OFFICE RI/ORA RI/DRSS RI/ORA RI/ORA OE NMSS

M McLaughlin A Dimitriadis B Klukan NLO J Nick J Peralta R Sun

DATE 9/20/23 9/21/23 9/25/23 9/25/23 10/6/23 10/6/23

OFFICE OGC RI/DRSS RA

NAME M Simon NLO P Krohn R Lorson DATE 10/25/23 10/30/23 11/09/23

ENCLOSURE 1

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY

Holtec Decommissioning International, LLC Docket No.: 50-219 Oyster Creek Nuclear Generating Station License No.: DPR-16 EA-23-076

During an NRC inspection conducted between January 1, 2023, and June 30, 2023, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the NRC proposes to impose a civil penalty pursuant to Sect ion 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violation and associated civil penalty is set forth below:

Title 10 CFR 71.5 requires, in part, that each licensee who transports licensed materials on public highways shall comply with the requirements of the U.S. Department of Transportation regulations in 49 CFR Parts 171 through 180. Title 49 CFR 173.441 requires that each package of radioactive material offered for transportation, including those transported by Exclusive Use shipment in an open transport vehicle, be designed and prepared for shipment so that, under conditions normally incident to transportation, the radiation level does not exceed 200 mrem/h at any point on the external surface of the package.

Contrary to the above, on May 3, 2023, Holtec Decommissioning International, LLC failed to prepare a package of radioactive material for transportation such that, under conditions normally incident to transportation, the radiation level did not exceed 200 mrem/h at any point on the external surface of the package. Specifically, the licensee shipped a package containing radioactive material using Exclusive Use controls in an open transport vehicle.

When the shipment arrived at the Indian Point Energy Center, radiation levels of 450 mrem/h were measured on top of the external surface of the alignment fixture package during the receipt survey, exceeding the regulatory requirement of 200 mrem/h.

This is a Severity Level III Violation (NRC Enforcement Policy Section 6.8).

Civil Penalty - $43,750 (EA-23-076)

The NRC has concluded that information regarding t he reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in Inspection Report No. 05000219/2023002 and in the letter from the Licensee dated September 6, 2023.

However, if the description therein does not accurately reflect your position or your corrective actions, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 within 30 days of the date of the letter transmitting this Notice of Violation. In that case, or if you choose to respond, clearly mark your response as a Reply to a Notice of Violation, and send it to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North, 11555 Rockville Pike, Rockville, MD 20852-2738, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region I, 475 Allendale Rd., Suite 102, King of Prussia, PA 19406-1415, and the Document Control Desk, Washington, DC 20555-0001.

Notice of Violation 2

The Licensee may pay the civil penalty proposed above through one of the following two methods:

1. Submit the payment with the enclosed invoice for Civil Penalty EA-23-076, issued to Holtec Decommissioning International, LLC, to the following address:

Office of the Chief Financial Officer U.S. Nuclear Regulatory Commission P.O. Box 979051 St. Louis, MO 63197

OR

2. Submit the payment in accordance with NUREG/BR-0254.

The Licensee may protest the imposition of the civil penalty in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice. Should the Licensee fail to answer within 30 days of the date of this Notice, the NRC will issue an order imposing the civil penalty. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an Answer to a Notice of Violation and may: (1) deny the violation listed in this Notice, in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or (4) show other reasons why the penalty should not be imposed. In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.

In requesting mitigation of the proposed penalty, the response should address the factors addressed in Section 2.3.4 of the Enforcement Policy. Any written answer addressing these factors pursuant to 10 CFR 2.205 should be set forth separately from the statement or explanation provided pursuant to 10 CFR 2.201 but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205 regarding the procedure for imposing a civil penalty.

Upon failure to pay any civil penalty which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205 to be due, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234 of the Act, 42 U.S.C. 2282(c).

The responses noted above (i.e., Reply to Notice of Violation, Statement as to payment of civil penalty, and Answer to a Notice of Violation), should be addressed to: Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North, 11555 Rockville Pike, Rockville, MD 20852-2738, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region I, 475 Allendale Rd., Suite 102, King of Prussia, PA 19406-1415, and the NRC Document Control Desk, Washington, DC 20555-0001.

If you choose to respond, your response will be made available electronically for public inspection in the NRC Public Document Room or in the NRCs Agencywide Documents Access and Management System (ADAMS), access ible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not Notice of Violation 3

include any personal privacy, proprietary, classified or safeguards information so that it can be made available to the public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request that such material is to be withheld from public disclosure, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days of receipt.

Dated this 9th day of November, 2023.

ENCLOSURE 2

Civil Penalty Invoice HOLTEC DECOMMISSIONING INTERNATIONAL, LLC KRISHNA P. SINGH TECH CAMPUS; 1 HOLTEC BLVD CAMDEN, NJ 08104

Page 1 of 3 Address/Customer Information Bill Information Bill Summary HOLTEC DECOMMISSIONING INTERNATIONAL, LLC Bill Number: EA-23-076 Initial Charges $43,750.00 KRISHNA P. SINGH TECH CAMPUS; 1 HOLTEC BLVD Amount Due: $43,750.00 Discount 0.00 CAMDEN, NJ 08104 Surcharge 0.00 Interest Charges 0.00 Penalty Charges 0.00 Customer Codes Contact Us Admin Charges 0.00 Account Code: L000002111/1 Phone Number: 301-415-7554 Bill Amount $43,750.00 Fax Number: 301-415-4135 Collected 0.00 Email Address: Fees.Resource@nrc.gov Applied Credit 0.00 Adjustments 0.00 Amount Due $43,750.00 Remit to Address Office of the Chief Financial Officer Credit Summary U.S. Nuclear Regulatory Commission Applied Credit $0.00 P.O. Box 979051 Unapplied Credit 0.00 St. Louis, MO 63197 Credit Total $0.00

Comments:

For questions, contact (301) 415-7554 or by email at Fees.Resource@nrc.gov. For NRC debt collection procedures, including interest and penalty provisions, see 31 U.S.C. 3717, 4 CFR 101-105, AND 10 CFR 15.

For questions, contact (301) 415-7554 or by email at Fees.Resource@nrc.gov. For NRC debt collection procedures, including interest and penalty provisions, see 31 U.S.C. 3717, 4 CFR 101-105, AND 10 CFR 15. Invoice if for Civil Penalty EA., issued to Holtec Decommissioning International, LLC.

Page 2 of 3 Customer Information Remittance Information L000002111/1 Office of the Chief Financial Officer HOLTEC DECOMMISSIONING INTERNATIONAL, LLC U.S. Nuclear Regulatory Commission KRISHNA P. SINGH TECH CAMPUS; 1 HOLTEC BLVD P.O. Box 979051 CAMDEN, NJ 08104 St. Louis, MO 63197

Change of Address: This Payment References the following Bill:

EA-23-076

Outstanding Amount Due: $43,750.00

Amount Enclosed:

Phone:

Page 3 of 3 ENCLOSURE 3 NUREG/BR-0254, Payment Methods

QUESTIONS?

If you have questions, please visit https://www.nrc.gov and search for License Fees.

Questions may also be directed to the NRC Accounts Receivable Help Desk by e-mail at nrc@fiscal.treasury.gov, by phone at (301) 415-7554, or by writing to the address below:

U.S. NUCLEAR REGULATORY COMMISSION OCFO/DOC/ARB Mail Stop T9-E10 Washington, DC 20555-0001

U.S. NUCLEAR REGULATORY COMMISSION OCFO/DOC/ARB Mail Stop T-9-E10 Washington, DC 20555-0001 PH (301) 415-7554

NUREG/BR-0254, Rev. 9 June 2019 APPROVED BY OMB: NO. 3150-0190 See the sample EFT message to Treasury below. Each numbered field is The optimum format for fields 7, 8, 9, and 10 using an 8-digit ALC is as described below. follows:

Estimated burden per response to comply with this voluntary collection request: 10 minutes. This brochure provides information about TREAS NYC/CTR/BNF=/AC-31000001 OBI=

available payment methods. Forward comments about to burden estimate to the Records Management Branch (T6-F33), U.S. Nuclear The optimum format, shown above, will allow 219 character positions of Regulatory Commission, Washington, DC 20555-0001, and to the information following the OBI= indicator.

Paperwork Reduction Project (3150-0190), Office of Management and Budget, Washington, DC 20503. If a means used to impose an If the licensees bank is not a member of the Federal Reserve System, the information collection does not display a currently valid OMB control nonmember bank must transfer the necessary information and funds to number, the NRC may not conduct or sponsor, and a person is not a member bank, which then must transfer the information and funds to required to respond to, the information collection. the local Federal Reserve Bank.

NRC accepts the methods described below. For a transfer of funds from local Federal Reserve Banks to be recorded on the same day, the transfer must be received at the New York Federal Reserve Bank by 4 p.m., EST. Otherwise, the deposit will be recorded on the next workday.

RECEIVER-DFI# - Treasurys ABA number for deposit messages is PAYMENT BY AUTOMATED 021030004. PAYMENT BY CHECK CLEARINGHOUSE TYPE-SUBTYPE-CD-The sending bank will provide the type and subtype Checks should be made payable to the U.S. Nuclear Regulatory To pay by Automated Clearinghouse/Electronic Data Interchange (ACH/ code. Commission with the invoice number, Enforcement Action number, EDI), provide a copy of NRC Form 628 to your financial institution. or other information that identifies the payment, written on the check.

You may obtain a copy of NRC Form 628 from the NRC Web site at SENDER-DFI# - The sending bank will provide this number. Mail the check to the following address:

http://www.nrc.gov by searching for NRC Form 628. You can also obtain a form by calling the NRC Accounts Receivable Help Desk at SENDER-REF# - The sending bank will insert this 16-character reference U.S. Nuclear Regulatory Commission (301) 415-7554. number at its discretion. U.S. Bank AMOUNT - The transfer amount must be punctuated with commas and P.O. Box 979051 decimal point; use of the $ is optional. The depositor will provide this St. Louis, MO 63197-9000 PAYMENT BY CREDIT CARD item.

FedEx or overnight mailings must be delivered to the following address:

The NRC is currently accepts credit c ard payments of up to SENDER-DFI-NAME - The Federal Reserve Bank will automatically insert U.S. Nuclear Regulatory Commission

$24,9 9 9.9 9. For payment by credit c ard, go to Pay.gov, search for this information. U.S. Bank Government Lockbox

,U.S. Nuclear Regulator y Commission F ees and enter the required RECEIVER-DFI-NAME - Treasurys name for deposit messages is TREAS SL-MO-C2GL information. NYC. The sending bank will enter this name. 1005 Convention Plaza St. Louis, MO 63101 You may also mail or fa x NRC PRODUCT CODE - A product code of CTR for customer transfer should Form 629 following the direc tions on be the first item in the reciever text field. Other values may be entered, if the form. To obt ain a copy of NRC appropriate, using the ABAs options. A slash must be entered after the TAXPAYER IDENTIFICATION Form 629 go to ht tp: // w w w.nrc.gov product code. NUMBER and search for NRC Form 629 or c all the NRC Accounts Receivable Help AGENCY LOCATION CODE (ALC) - THIS ITEM IS OF CRITICAL You must file your Taxpayer Identification Number (TIN) with the NRC.

Desk at (301) 415-755 4. IMPORTANCE. IT MUST APPEAR ON THE FUNDS TRANSFER DEPOSIT Use NRC Form 531 to provide your TIN. You may obtain NRC MESSAGE IN THE PRECISE MANNER AS STATED TO ALLOW FOR THE Form 531 from the NRC Web site at http://www.nrc.gov by searching AUTOMATED PROCESSING AND CLASSIFICATION OF THE FUNDS for NRC Form 531 or by calling the NRC Accounts Receivable Help PAYMENT BY FEDWIRE DEPOSIT TRANSFER MESSAGE TO THE AGENCY LOCATION CODE OF THE Desk at (301) 415-7554.

SYSTEM APPROPRIATE AGENCY. The ALC identification sequence can, if necessary, begin on one line and end on the next line; however, the field tag BNF=

must be on one line and cannot contain any spaces. The NRCs 8-digit ALC The NRC can receive funds through the U.S. Department of the is: BNF=/AC-31000001 Treasury (Treasury) Fedwire Deposit System. The basic wire message THIRD-PARTY INFORMATION - The Originator to Beneficiary Information format below complies with the Federal Reserve Boards standard (OBI) field tag OBI= signifies the beginning of the free-form third-party text.

structured third-party format for all electronic funds transfer (EFT) All other identifying information intended to enable the NRC to identify the messages. depositfor example, NRC annual fee invoice number, description of fee, 10 CFR 171 annual fee, and licensee nameshould be placed in this field.