ML22258A099

EA-22-050: Public: the Hospital of Central Connecticut (Hocc) - NRC Inspection Report 03001250/2021001 and NRC Office of Investigations Report No. 1-2021-010

ML22258A099
Person / Time
Site:	03001250
Issue date:	09/15/2022
From:	Blake Welling Decommissioning, ISFSI, and Reactor Health Physics Branch
To:	Edwards J Hospital of Central Connecticut
References
EA-22-050, OI-2021-010 2021-001, IR 2021010
Download: ML22258A099 (4)

See also: IR 05000202/2010001

Text

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

475 Allendale Road, Suite 102

KING OF PRUSSIA, PA 19406-1415

September 15, 2022

EA-22-050

Jeanette Edwards, VP Operations

The Hospital of Central Connecticut

100 Grand Street

New Britain, CT 06050

SUBJECT: THE HOSPITAL OF CENTRAL CONNECTICUT (HOCC) - NRC

INSPECTION REPORT 03001250/2021001 AND NRC OFFICE OF

INVESTIGATIONS REPORT NO. 1-2021-010

Dear Ms. Edwards:

On March 5, 2021, Shawn Seeley and Robert Gallaghar, inspectors of the Nuclear Regulatory

Commission (NRC), conducted a routine announced inspection remotely, with an on-site

inspection for the safety and security portions from March 21-23, 2021, and continued in-office

review through August 19, 2022. This inspection was performed under your NRC License No.

06-02388-01.

During this inspection, the NRC staff examined activities conducted under your license related to

public health and safety. Additionally, the staff reviewed your compliance with the NRCs rules

and regulations as well as the conditions of your license. Within these areas, the inspection

consisted of selected examination of procedures and representative records, observations of

activities and interviews with personnel.

Based on the results of the inspection, apparent violations of NRC requirements were identified.

The violations were of a security-related nature; therefore, the details of the violations, as well as

the corrective actions that have since been taken to restore compliance with regulatory

requirements, are discussed in the non-public enclosure.

Additionally, the NRC Office of Investigations (OI), initiated an investigation (Case No. 1-2021-010)

to determine whether your staff deliberately committed security-related violations. Based upon

documentary and testimonial evidence developed during the OI investigation, the NRC did not

substantiate that the actions of your employees were deliberate.

The apparent violations are being considered for escalated enforcement in accordance with the

NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site at

https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html.

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

J. Edwards 2

The circumstances surrounding the apparent violations were discussed with you and additional

members of your staff telephonically during the final exit meeting on August 19, 2022. The

enclosed inspection report presents the findings of this inspection.

Since the NRC has not made a final determination in this matter, a Notice of Violation is not

being issued at this time. Please be advised that the number and characterization of the

apparent violations described in the enclosed inspection report may change as a result of

further review. You will be advised by separate correspondence of the results of our

deliberations on this matter. The circumstances surrounding the apparent violations, the

significance of the issues, and the need for lasting and effective corrective actions were

discussed with you during the August 19, 2022, telephone call. As a result, it may not be

necessary to conduct a pre-decisional enforcement conference in order to enable the NRC to

make an enforcement decision. In addition, since your facility has not been the subject of

escalated enforcement actions within the last two inspections, and based on our understanding

of your corrective action, a civil penalty may not be warranted in accordance with Section 2.3.4

of the Enforcement Policy.

Before the NRC makes its enforcement decision regarding the apparent violations, we are

providing you an opportunity to (1) respond to the apparent violations addressed in this inspection

report within 30 days of the date of this letter or (2) request a Pre-decisional Enforcement

Conference (PEC). If a PEC is held, it will be closed to public observation because it would

involve security-related information; however, the time and date of the PEC would be publicly

announced. A PEC should be held within 30 days of the date of this letter.

If you choose to provide a written response, it should be clearly marked as a Response to An

Apparent Violation in NRC Inspection Report 03001250/2021001; EA-22-050 and should include

for each apparent violation: (1) the reason for the apparent violation or, if contested, the basis for

disputing the apparent violation; (2) the corrective steps that have been taken and the results

achieved; (3) the corrective steps that will be taken; and (4) the date when full compliance will be

achieved. Your response may reference or include previously docketed correspondence if the

correspondence adequately addresses the required response. Additionally, your response should

be sent to the NRCs Document Control Center, with a copy mailed to Regional Administrator,

NRC Region I, 475 Allendale Road, Suite 102, King of Prussia, PA 19406, within 30 days of the

date of this letter. If an adequate response is not received within the time specified or an

extension of time has not been granted by the NRC, the NRC will proceed with its enforcement

decision or schedule a PEC.

If you choose to request a PEC, the conference will afford you the opportunity to provide your

perspective on these matters and any other information that you believe the NRC should take

into consideration before making an enforcement decision. The decision to hold a PEC does not

mean that the NRC has determined that a violation has occurred or that enforcement action will

be taken. This conference would be conducted to obtain information to assist the NRC in making

an enforcement decision. The topics discussed during the conference may include information to

determine whether a violation occurred, information to determine the significance of a violation,

information related to the identification of a violation, and information related to any corrective

actions taken or planned. In presenting your corrective action, you should be aware that the

promptness and comprehensiveness of your actions will be considered in assessing any civil

penalty for the apparent violations. The guidance in the enclosed excerpt from

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

J. Edwards 3

NRC Information Notice 96-28, Suggested Guidance Relating to Development and

Implementation of Corrective Action, may be helpful.

Please contact Ms. DeFrancisco at anne.defrancisco@nrc.gov within 10 days of the date

of this letter to notify the NRC which of the above options you choose. If you do not

contact the NRC within the time specified, and an extension of time has not been granted by

the NRC, the NRC will proceed with its enforcement decision.

Please note that final NRC investigation documents, such as the OI report described above,

may be made available to the public under the Freedom of Information Act (FOIA) subject to

redaction of information appropriate under the FOIA. Requests under the FOIA should be made

in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 9.23, Requests for

Records. Additional information is available on the NRC website at http://www.nrc.gov/reading-

rm/foia/foia-privacy.html.

However, the material enclosed herewith contains Security-Related Information in accordance

with 10 CFR 2.390(d)(1) and its disclosure to unauthorized individuals could present a security

vulnerability. Therefore, the material in the enclosure will not be made available electronically for

public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents

Access and Management System (ADAMS), accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html. If Security Related Information is necessary to

provide an acceptable response, please mark your entire response Security-Related Information

in accordance with 10 CFR 2.390(d)(1) and follow the instructions for withholding in 10 CFR

2.390(b)(1). In accordance with 10 CFR 2.390(b)(1)(ii), the NRC is waiving the affidavit

requirements for your response.]

If you have any questions concerning this matter, please contact Anne DeFrancisco of my

staff at anne.defrancisco@nrc.gov.

Sincerely,

Digitally signed by Blake

Blake D. D. Welling

Welling Date: 2022.09.15

16:06:58 -04'00'

Blake Welling, Director

Division of Radiological Safety and Security

Region I

Docket No. 030-01250

License No. 06-02388-01

Enclosures:

1. Inspection Report No. 03001250/2021001 (non-public)

2. NRC Information Notice 96-28

cc w/Encl:

Mohammed Aljallad, Ph.D., RSO

State of Connecticut

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

ML22258A099

Cvr Ltr & Encl: Non-Publicly Available Sensitive A.3.

ADAMS ACCESSION NUMBER: ML22258A097

OFFICE RI:DRSS RI:DRSS RI:DRSS RI:ORA

NAME SSeeley RGallaghar ADeFrancisco MMcLaughlin

DATE 9/9/22 9/1/22 8/31/22 8/31/22

OFFICE OE RI:DRSS

NAME LSreenivas BWelling

DATE 9/13 /22 9/15/22