NRC ORDER – Order

On December 14, 2017, the NRC issued a Confirmatory Order to Global Nuclear Fuel – Americas, L.L.C (GNF-A) to formalize commitments reached as part of an alternative dispute resolution (ADR) mediation session involving violations at the facility in Wilmington, NC. The NRC identified the following five Apparent Violations (AVs), all of which were considered for escalated enforcement in accordance with the NRC's Enforcement Policy: (1) Failure to make or cause to be made surveys of scrap metal piping prior to its release and transportation as required by 10 CFR 20.1501(a); (2) failure to comply with applicable Department of Transportation (DOT) regulations appropriate to the mode of transport of contaminated materials as required per 10 CFR 71.5(a); (3) failure to notify the NRC as required by 10 CFR 20.1906(d)(1) when removable radioactive surface contamination exceeds the limits of 10 CFR 71.87(i); (4) failure to perform the monitoring of a package as required by 10 CFR 20.1906(c); and (5) the failure to maintain records of surveys as required by 10 CFR 20.2103(a). As part of the settlement agreement, GNF-A agreed to take a number of actions in addition to those already completed. These additional actions include, but are not limited to: (1) install a vehicle portal monitor with a sensitivity to detect vehicle surface radiation levels specified in 10 CFR20.1301(a)(2); (2) conduct a nuclear safety culture assessment of the GNF-A organization by a third party independent of GNF-A who is experienced with NRC nuclear safety culture and safety conscious work environment policies; (3) conduct a benchmark assessment of the GNF-A Radiation Protection Program (RPP) with at least two external RPP organizations in the Fuel Cycle industry; and (4) expand its Difference of Professional Opinion process to include all technical safety matters related to GNF-A licensed activities. In recognition of these actions, the NRC agreed to refrain from proposing a civil penalty and issuing