UNITED STATESNUCLEAR REGULATORY COMMISSION

WASHINGTON, D.C. 20555-0001

December 19, 2012

EA-12-178

Bonnie FletcherDirector, Global Trade ComplianceDresser, Inc.10343 Sam Houston Park Drive, Suite 210Houston, TX 77064

SUBJECT: NOTICE OF VIOLATION - LATE REPORTING OF EXPORTS OF NUCLEARREACTOR COMPONENTS DESCRIBED IN PARAGRAPHS (5) - (9) OFAPPENDIX A - VIOLATION OF 10 CFR 110.54(c)

Dear Ms. Fletcher:

This letter refers to your letter dated March 19, 2012, in which Dresser, Inc. submitted a latereport of the exports of nuclear reactor components as described in paragraphs (5) - (9) ofAppendix A to Part 110 covered by the U.S. Nuclear Regulatory Commission (NRC) generallicense during calendar year 2011. Specifically, contrary to the requirements in Title 10 of theCode of Federal Regulations (10 CFR) 110.54(c), 1 for the year 2011, you made multipleshipments of nuclear reactor components under the NRC general license established by10 CFR 110.26(a) to multiple destinations, but failed to report these shipments by February 1st

of the year following the year in which the shipments were made.

Based on the information you provided, the NRC has determined that a Severity Level IVviolation of NRC requirements occurred. This violation was evaluated in accordance with theNRC Enforcement Policy. The current Enforcement Policy is available on the NRC's Web siteat http://www.nrc.gov/about-nrc/regulatory/enforcementlenforce-pol.html. The violation is beingcited in the enclosed Notice of Violation (Notice) because the criteria for consideration as anoncited violation provided in Section 2.3.2 of the Enforcement Policy were not met, in thatDresser, Inc., did not identify the violation.

You are required to respond to this letter and should follow the instructions specified in theenclosed Notice when preparing your response. The NRC will use your response to the Noticeto determine whether further enforcement action is necessary to ensure compliance withregulatory requirements.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosures and your response will be made available electronically for public inspection in the

1 10 CFR 11O.54(c) states that persons making exports under the general license established by 110.26(a) shallsubmit by February 1st of each year one copy of a report of all components shipped during the previous calendaryear. This report must include: (1) a description of the components keyed to the categories listed in Appendix A ofthis part, (2) approximate shipment dates, and (3) a list of recipient countries and end-users keyed to the itemsshipped.

B. Fletcher - 2-

NRC Public Document Room or from the NRC's document system Agencywide DocumentsAccess and Management System accessible from the NRC Website athttp://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should notinclude any personal privacy, proprietary, or safeguards information so that it can be madeavailable to the public without redaction. If personal privacy, proprietary information orsafeguards information is necessary to provide an acceptable response, please provide abracketed copy of your response that identifies the information that should be protected and aredacted copy of your response that deletes such information. If you request withholding ofsuch information, you must specifically identify the portions of your response that you seek tohave withheld and provide in detail the bases for your claim of withholding (e.g., explain why thedisclosure of information will create an unwarranted invasion of personal privacy or provide theinformation required by 10 CFR 2.390(b) to support a request for withholding confidentialcommercial or financial information). The NRC also includes significant enforcement actions onits Web site at http://www.nrc.gov/reading-rm/doc-collections/enforcementlactions

Sincerely,

Nick Hilton, ChiefEnforcement Branch

Enclosure:Notice of Violation EA-12-178

cc: See next page

NOTICE OF VIOLATION

Dresser, Inc.Houston, Texas 77064

EA-12-178

Based on information received on March 19, 2012, from Dresser, Inc., a violation of U.S.Nuclear Regulatory Commission (NRC) requirements was identified. In accordance withEnforcement Policy, the violation is listed below:

10 CFR Part 110.54(c) states that persons making exports under the general licenseestablished by 110.26(a) shall submit by February 1st of each year one copy of a reportof all components shipped during the previous calendar year. This report must include:(1) a description of the components keyed to the categories listed in Appendix A of thispart, (2) approximate shipment dates, and (3) a list of recipient countries and end-userskeyed to the items shipped.

Contrary to the above, Dresser, Inc., failed to submit by February 1, 2012, one copy of areport of all applicable components shipped during the previous calendar year.Specifically, Dresser, Inc., made multiple shipments of nuclear reactor componentsunder the NRC general license established by 10 CFR 110.26(a) to multiple destinationsduring 2011, and failed to report those shipments until March 19, 2012.

This is a Severity Level IV violation.

Pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 2.201,Dresser, Inc. is hereby required to submit a written statement or explanation to the Director,Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001,within 30 days of the date of this Notice of Violation. This reply should be clearly marked as a"Reply to a Notice of Violation: EA-12-178" and should include for each violation: (1) the reasonfor the violation, or, if contested, the basis for disputing the violation or severity level; (2) thecorrective steps that have been taken and the results achieved; (3) any additional correctivesteps that will be taken; and (4) the date when full compliance will be or was achieved. Yourresponse may reference or include previous docketed correspondence, if the correspondenceadequately addresses the required response. If an adequate reply is not received within thetime specified in this Notice, the NRC may issue an Order or a Demand for Information requiringyou to explain why your license should not be modified, suspended, or revoked or why suchother action as may be proper should not be taken. Where good cause is shown, considerationwill be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, withthe basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear RegulatoryCommission, Washington, DC 20555-0001.

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In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and yourresponse will be made available electronically for public inspection in the NRC Public DocumentRoom or from the NRC's document system (ADAMS) accessible from the NRC Website athttp://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should notinclude any personal privacy, proprietary, or safeguards information so that it can be madeavailable to the public without redaction.

/Q~Dated this + day of December 2012.