ML20058P002
| ML20058P002 | |
| Person / Time | |
|---|---|
| Site: | 07000033 |
| Issue date: | 07/12/1993 |
| From: | Kinneman J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Elliott M TEXAS INSTRUMENTS, INC. |
| References | |
| 117056, NUDOCS 9310210285 | |
| Download: ML20058P002 (47) | |
Text
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JUL 121993 License No. SNM-23 Docket No. 070-00033 Control No. I17056 Texas Instruments, Inc.
ATTN: Michael J. EUiott, Environmental Manager Metal Systems Division 34 Forest Street Attleboro, Massachusetts 02703
Dear Mr. Elliott:
Subject:
Financial Assurance for Decommissioning This refers to your submittal regarding financial assurance for decommissioning dated August 14, 1992.
We have reviewed this submittal and have no further questions at this time. If you have any questions, please contact Anthony Dimitriadis of my staff at (215) 337-6953.
Your coopemtion with us is appreciated.
Sincerely, O
%C S!ag ' *;v; UL D. W x n.1 John D. Kinneman, Chief Research, Development and Decommissioning Section Division of Radiation Safety and Safeguards bec:
Region I Docket Room (w/ concurrences)
OFFICI AL IECORD COPY - G:\\WPS\\RPT\\TXINSTR.FA - 06/03/93 i
MD 10 9310210285 930712 PDR ADOCK 07000033 C
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Texas Instruments, Inc. DRSS:RJ 'smh Dimitriallic K
eman 4.
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NOTE TO DMB:
TIIE A'ITACIIED DOCUMENTS ARE TO BE PROCESSED AS ONE MATERIALS LICENSING PACKAGE.
LICENSE NUMBER:
S //A'7 - ? $
DOCKET NUMBER:
C 7[ - ('l'Z 8 3 CONTROL NUMBER:
/ / 78 62 TIIIS SIIEET MAY BE DISCARDED AFTER PROCESSING.
TIIANK YOU!
19009.;
A A70-oeo 33 w
w TEXAS INSTRUMENTS N
August 14, 1992 U.S. Nuclear Regulatory Commission Region I Attention: John Kinneman 475 Allendale Road King of Prussia, PA 19406-1415
Dear Mr. Kinneman:
Please find enclosed a fully executed originalStandby Trust Agreement between Texas Instruments Incorporated and Continental Bank National Association.
Sincerely, MATERIALS & CONTROLSGROUP lla-lY /
p-.- (
FrancisJ. Veale, Jr.
Environmental, Safety, & Health Manager FJVAa Enclosure TEXAS INSTRUMENTS INCORPORATED
- 34 FOHE ST STREET e ATTLETSORD MA 02703 5,08 699 3000
- TE LE X P10801
- CABLE TEXINS
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w STANDBY TRUST AGREEMENT 4
TRUST AGREEMENT, the Agreement entered into as of / 7 day of August, 1992, by and between TEXAS INSTRUMENTS INCORPORATED, a Delaware corporation, herein referred to as the " Grantor," and Continental Bank National Association, Attention: Corporate Trust Department, 231 South LaSalle Street, Chicago, Illinois 60697, the " Trustee."
WHEREAS, the U.S. Nuclear Regulatory Commission (NRC), an agency of i
the U.S. Government, pursuant to the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974, has promulgated regulations in Title 10, Chapter I of the Code of Federal Regulations, Part 70.
These regulations, applicable to the Grantor, require that a holder of, or an applicant for, a Part 70 license provide assurance that funds will be available when needed for required decommissioning activities.
WHEREAS, the Grantor has elected to use a letter of credit to provide all of such financial assurance for the facilities identified herein; and WHEREAS, should payment be made under a letter of credit, this standby trust shall be used for the receipt of such payment; and WHEREAS, the Grantor, acting through its duly authorized officers, has selected the Trustee to be the trustee under this Agreement, and the Trustee is willing to act as trustee, NOW, THEREFORE, the Grantor and the Trustee agree as follows:
Section 1.
Definitions. As used in this Agreement:
(a)
The term " Grantor" means the NRC licensee who enters into this Agreement and any successors or assigns of the Grantor.
(b)
The term " Trustee" means the Trustee who enters into this Agreement and any successor Trustee.
Section 2.
Costs of Decommissioning. This Agreement pertains to the costs f decommissioning the materials and activities identified in License Number SNM
.3 issued pursuant to 10 CFR Part 70 as shown in Schedule A.
Section 3.
Establishment of Fund. The Grantor and the Trustee hereby establish a standby trust fund (the Fund) for the benefit of the NRC. The Grantor and the Trustee intend that no third party have access to the Fund except as provided herein.
Section 4.
Payments Constituting the Fund. Payments made to the Trustee for the Fund shall consist of cash, securities, or other liquid assets acceptable to the Trustee. The Fund is established initially as consisting of the property, which is acceptable to the Trustee, described in Schedule B attached hereto.
Such property and any other property subsequently transferred to the Trustee are referred to as the " Fund," together with all earnings and profits thereon, less any payments or distributions made by the Trustee pursuant to this Agreement.
The Fund shall be held by the Trustee, IN TRUST, as hereinafter provided.
The STANDBYTRUSTAGREEMENTTI/NRC PAGE 1
r w
Trustee shall not be responsible nor shall it undertake any responsibility for the amount of, or adequacy of the Fund, nor any duty to collect from the Grantor any Jayments necessary to discharge any liabilities of the Grantor established by tle NRC.
Section 5.
Payment for Recuired Decommissioning Activities. In the event of the Grantor's default or inability to direct decommissioning activities, the Trustee shall make payments from the Fund as the NRC shall direct, in writing, to provide for the payment of the costs of required activities covered by this Agreement.
The Trustee shall reimburse the Grantor or other persons as specified by the NRC from the Fund for expenditures for required activities in such amounts as the NRC shall direct in writing.
In addition, the Trustee shall refund to the Grantor such amounts as the NRC specifies in writing. Upon refund, such funds shall no longer constitute part of the Fund as defined herein.
Sec
, 6.
Trust Management.
The Trustee shall invest and reinvest the princ.,.al and income of the Fund and keep the Fund invested as a single fund, without distinction between principal and income, in accordance with general investment policies and guidelines which the Grantor may communicate in writing to the Trustee from time to time, subject, however, to the provisions of this section. In investing, reinvesting, exchanging, selling, and managing the Fund, the Trustee shall discharge its duties with respect to the Fund solely in the interest of the beneficiary and with the care, skill, prudence, and diligence under the circumstances then prevailing which persons of prudence, acting in a like capacity and familiar with such matters, would use in the conduct of an enterprise of a like character and with like aims; except that:
(a)
Securities or other obligations of the Grantor, or any other owner or operator of the facilities, or any of their affiliates as defined in the Investment Company Act of 1940, as amended (15 U.S.C. 80a-2(a)), shall not be acquired or held, unless they are securities or other obligations of the Federal or a State government; (b)
The Trustee is authorized to invest the Fund in time or demand deposits of the Trustee, to the extent insured by an agency of the Federal Government, and in obligations of the Federal Government such as GNMA, FNMA, and FHLM bonds and certificates or State and Municipal bonds rated BBB or higher by Standard and Poors or Baa or higher by Moody's Investment Services; and (c)
For a reasonable time, not to exceed 60 days, the Trustee is authorized to hold uninvested cash, awaiting investment or distribution, without liability for the payment of interest thereon.
Section 7.
Comminalina and Investment. The Trustee is expressly authorized in its discretion:
(a)
To transfer from time to time any or all of the assets of the Fund to any common, commingled, or collective trust fund created by the Trustee in which the Fund is eligible to participate, subject to all of the provisions thereof, to be commingled with the assets of other trusts participating therein; and STANDBY TRUST AGREEMENT TI/NRC PAGE 2
n O
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v (b)
To purchase shares in any invest ent company registered under the Investment Company Act of 1940 (15 b.S.C. 80a-1 et seq.), including one that may be created, managed, underwritten, or to which investment advice is rendered, or the shares of which are sold by the Trustee. The Trustee may vote such shares in its discretu n.
Section 8.
Express Fowers of Trustee. Withcut in any way limiting the powers and discretion conferred upon the Trustee.)y the other provisions of this Agreement or by law, the Trustee is expressly authorized ano empowered:
(a)
To sell, exchange, convey, transfer, or otcerwise dispos.: of any property held by it, by public or private sale, a necesssry to allow duly authorized withdrawals at the joint request of the 6rantor and the NRC or to reinvest in securities at the direction of the Grantor; (b)
To make, execute, acknowledge, and deliver any and all documents of transfer and conveyance and any and all other instruments that may be necessary or appropriate to carry out the powers herein granted; (c)
To register any securities held in the Fund in its own name, or in the name of a nominee, and to hold any security in bearer form or in book entry, or to cembine certificates representing such securities with certificates of the same issue held by the Trustee in other fiduciary capacities, to reinvest interest payment and funds from matured and redeemed instruments, to file proper forms ccncerning securities held in the fund in a timely fashion with appropriate government agencies, or to depod. or arrange for the deposit of such securities in a qualified centm depository even though, when so deposited, such securities may be merged and held in bulk in the name of the nominee or such depository with other securities deposited therein by another person, or to deposit or arrange for the deposit of any securities issued by the U.S. Government, or any agency or instrumentality thereof, with a Federal Reserve bank, but the books and records of the Trustee shall at all times show that all such securities are part of the Fund; (d)
To deposit any cash in the Fund in interest-bearing accounts mairaained or savings certificates issued by the Trustee, in its separate corporate capacity, or in any other banking institution affiliated with the Trust 2e, to the extend insured by an agency of the Federal government; and (e)
To compromise or otherwise adjust all claims in favor of or against the Fund.
Section 9.
Taxes and Expenses. All taxes of any kind that may be assessed or levied against or in respect of the fund and all brokerage commissions incurred by the Fund shall be paid from the Fund.
All other expenses incurred by the i
l Trustee in connection with the administration of this Trust, including fees for legal services rendered to the Trustee, the compensation of the Trustee to the extent not paid directly by the Grantor, and all other proper charges and disbursements of the Trustee shall be paid from the Fund.
STANDBYTRUSTAGREEMENTTI/NRC PAGE 3 j
GU Section 10.
Annual Valuation. After payment has been made into this standby trust fund, the Trustee shall annually, at least 30 days before the anniversary date of receipt of payment into the standby trust fund, furnish to the Grantor and to the NRC a statement confirming the value of the Trust. Any securities in the Fund anall be valued at market value as of no more than 60 days before the anniversary date of the establishment of the Fund. The failure of the Grantor to object in writing to the Trustee within 90 days after the statement has been furnished to the Grantor and the NRC shall constitute a conclusively binding assent by the irantor, barring the Grantor from asserting any claim or liability r
against the Trustee with respect to the matters disclosed in the statement.
Section 11. Advice of Counsel. The Trustee may from time to time consult with counsel with respect to any question arising as to the construction of this
,'greement or any action to be taken hereunder.
The Trustee shall be fully protected, to the extent permitted by law, in acting on the advice of counsel.
_S_gction 12. Trustee Compensation. The Trustee shall be entitled to reasonable compensation for its services as agreed upon in writing with the Grantor.
(See Schedule C.)
Section 13. Successor Trustee. Upon 90 days notice to the NRC, the Trustee may resign; upon 90 days notice to NRC and the Trustee, the Grantor may replace the Trustee; but such resignation or replacement shall not be effective until the Grantor nas appointed a successor Trustee and this successor accepts the appointment.
The successor Trustee shall have the same powers and duties as those conferred upon the Trustee hereunder.
Upon the successor Trustee's acceptance of the appcintment, the Trustee shall assign, transfer, and pay over to the successor Trustee the funds and properties then constituting the Fund.
If for any reason the Grantor cannot or does not act in the event of the resignation of the Trustee, the Trustee may apply to a court of competent jurisdiction for the appointment of a successor Trustee or for instructions. The successor Trustee shall specify the date on which it assumes administration of the Trust in a writing sent to the Grantor, the NRC, and the present Trustee by certified mail 10 days before such change becomes effective.
Any expenses incurred by the Trustee as a result of any of the acts contemplated by this section shall be paid as provided in Section 9.
Section 14. Instructions to the Trustee. All orders, requests, and instructions by the Grantor to the Trustee shall be in writing, signed by such persons as are signatories to this Agreement or such other designees as the Grantor may designate in writing.
The Trustee shall be fully protected in acting without inquiry in accordance with the Grantor's orders, requests, and instructions. If the NRC issues orders, requests, or instructions to the Trustee, these shall be in writing, signed by the NRC or its designees, and the Trustee shall act and shall be fully protected in acting in accordance with such orders, requests, and instructions.
The Trustee shall have the right to assume, in the absence of written notice to the contrary, that no event constituting a change or a termination of the authority of any person to act on behalf of the Grantor or the NRC hereunder has occurred. The Trustee shall have no duty to act in the absence of such orders, requests, and instruction from the Grantor and/or the NRC, except as provided for herein.
STANDBY TRUST AGREEMENT TI/NRC PAGE 4
Section 15.
Amendment of Acreement.
This Agreement may be amended by an instrument in writing executed by the Grantor, the Trustee and the NRC, or by the Trustee and the NRC, if the Grantor ceases to exist.
Section 16. Irrevocability and Termination. Subject to the right of the parties to amend this Agreement as provided in Section 15, this Trust shall be irrevocable and shall continue until terminated at the written agreement of the Grantor, the Trustee, and the NRC, or by the Trustee and the NRC, if the Grantor ceases to exist. Upon termination of the Trust, all remaining Trust property, less final Trust administration expenses, shall be delivered to the Grantor or its successor.
Section 17. Immunity and Indemnification. The Trustee shall not incur personal liability of any nature in connection with any act or omission, made in good faith, in the administration of this Trust, or in carrying out any directions by the Grantor or the NRC issued in accordance with this Agreement.
The Trustee shall be indemnified and save harmless by the Grantor or from the Trust fund, or both, from and against any personal liability to which the Trustee may be subjected by reason of any act or conduct in its official capacity, including all expenses reasonably incurred in its defense in the event the Grantor fails to provide such defense.
Section 18.
This Agreement shall be administered, construed, and enforced according to the laws of the State of Texas.
Section 19. Interpretation and Severability. As used in this Agreement, words in the singular include the plural, and words in the plural include the singular.
The descriptive headings for each section of this Agreement shall not affect the interpretation or the legal efficacy of this Agreement.
If any part of this agreement is invalid, it shall not affect the remaining provisions which will remain valid and enforceable.
IN WITNESS WHEREOF the parties have caused this Agreement to be executed by the respective officers duly authorized as of the date first written above.
TEXASINpTRUMENTSINCORPORATED, MATESIAL
& CONTROLS'T;R0pP
/
By:/ D Cf a d Y f(/e1 R Werner 5thuele
Title:
Senior vice President 13 August 1992 Date:
CONTINENTAL BANK NATIONAL ASSOCIATION, as Trustee x;
By: C_J X L M "
i YdC Pm i dm
Title:
Date:
?/1'E STANDBY TRUST AGREEMENT TI/NRC PAGE 5
STATE OF MASSACHUSETTS )
)
COUNTY OF BRISTOL
)
This instrument was acknowledged before me on the 13thday of August, 1992, by Werner Schuele Senior Vice President of TEXAS INSTRUMENTS INCORPORATED, a Delaware corporation, on behalf of said corporation.
MATERIALS & CONTROLS GROUP A
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Notary Public Signature
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This instrument was acknowledged before me on the//8 ay of August, d
1992, by m t w =6 i m
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Continental Bank National Association, a National Banking Association, on behalf of said Association.
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V. WASHINGTON Notary Pyc Signature
- Seal
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STANDBY TRUST AGREEMENT TI/NRC PAGE 6
O Q
c TRUST AGREEMENT SCHEDULE SCHEDULE A Decommissionino Cost Estimate This Agreement demonstutes financial assurance for the following cost estimates for the following licensed activities 4 U.S. NUCLEAR REGULATORY COMMISSION LICENSE NUMBER Docket Number 70-33 SNM License Number SNM-23 NAME AND Texas Instruments Incorporated ADDRESS OF Materials & Controls Group LICENSEE Attn: Werner Schuele 34 Forest Street Attleboro, Massachusetts 02703 ADDRESS OF Texas Instruments Incorporated LICENSED Materials & Controls Group ACTIVITY 34 Forest Street Attleboro, Massachusetts 02703 COST ESTIMATE FOR REGULATORY ASSURANCES DEMONSTRATED BY THIS AGREEMENT
$380.980.00 The cost estimate listed above was reviewed with and approved by the NRC at a meeting between representatives of Licensee and NRC Region I, King of Prussia, Pennsylvania on July 14, 1992.
STANDBYTRUSTAGREEMENTTI/NRC PAGE 7
1
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TRUST AGREEMENT SCHEDULE r
SCHEDULE B Initial Fund Property AMOUNT:
$380.980.00 (Three Hundred Eighty Thousand Nine Hundred Eighty and 00/100 U.S. Dollars) r AS EVIDENCED BY:
Irrevocable Standby Letter of Credit l
Irrevocable Documentary Credit Number: C7205732 Issued August-4, 1992 by:
Continental Bank National Association Attention: Corporate Trust Department 231 South LaSalle Street Chicago, Illinois 60697
?
I BENEFICIARY:
U.S. Nuclear Regulatory Commission Region I, Attn: John Kinneman 475 Allendale Road
[
King of Prussia, PA 19406-1415
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Telephone: (215) 337-5252
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STANDBYTRUSTAGREEMENTTI/NRC PAGE 8
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TRUST AGREEMENT SCHEDULE SCHEDULE C Trustee Compensation CONTINENTAL BANK, NATIONAL ASSOCIATION Fee Schedule Effective January 1,1992 Acceptance Fees An acceptance fee, based on the initial value of deposits when the account is opened, is iarged as follows:
First $
50,000..................................$1,400. minimum Next $
300,000..................................$ 1.35 per $1,000 Next $
350,000..................................$
.60 per $1,000 Next
$1,000,000..................................$
.23 per $1,000 Next
$1,700,000.................................
- 11 per $1,000 Annual Administration Fees An annual administrative fee, based on the value of assets in the account at the beginning of the fee period plus any deposits made through the fee billing period, is charged as follows:
First $
50,000......................
750. minimum **
Next $
300,000..................................$ 1.35 per $1,000 Next $
350,000..................................$
.60 per $1,000 Next
$1,000,000..................................$
.23 per $1,000 Next
$1,700,000..................................$
.11 per $1,000 When our service is limited strictly to holding life or casualty insurance policies, the minimum annual fee is reduced to $250. At the time of a casualty, the regular schedule will apply to the insurance proceeds.
Operatina Service Fees When our responsibilities for an escrow account include maintaining participants' or claimants' records, issuing payments and preparing tax forms, the following schedule applies:
Initial record set-up
$1.30 per participant
($300 minimum)
Issue one interest payment and
- $4.00 per participant prepare tax forms
($200 minimum)
Each principal distribution
,$1.25 per participant i
Each additional distribution
,$1.25 per participant
- Annual Fees Per Arnie Lenters, unless and until a draw is made on the letter of credit funds, the minimum $750 annual administrative fee will be chargea on this Standby Trust.
j STANDBYTRUSTAGREEMENTTI/NRC PAGE 9
O O
SCHEDULE C Trustee Compensation CONTINENTAL BANK, NATIONAL ASSOCIATION Fee Schedule Investments When we are required to invest funds, as directed by parties to the escrow, the following charges apply:
Buyi ng and Selli ng......................$90 per transacti on Movement of assets (securities, deeds, insurance polici es).....................$60 per deposit or delivery When we are required to invest funds using a cash sweep account, the following charges apply:
Cash Sweep..............................$45 per deposit Annual Cap..............................$500 When we are required to maintain custody of stripped coupons, the following charges apply:
Total Face Amount Annual charge per $1,000 OMM - 10MM......................................$
.15 10MM - 25MM......................................$
.20 25MM -100MM......................................$
.25 Over 100MM......................................$
.35 Termination There are no separate termination charges. Fees for the final billing period are prorated to the date of termination, subject to a six-month minimum.
Expenses and Other Charges The fees quoted in this schedule apply to services ordinarily rendered in administering an escrow account and are subject to reasonable adjustment if we are required to handle unusual duties, responsibilities, or procedures.
An increase in the cost of doing business can also lead to a pricing change.
The cost of all stationery and supplies, telephone, postage, printing, or other out-of-pocket expenses will be added to our regular service charges.
In addition, j
a base out-of-pocket expense of three (3) percent of total fees will be assessed for those expenses that cannot be directly allocated. Interest of 11/2 percent per month will be charged on all invoices unpaid for more than 30 days.
In determining the general schedule of fees, various incidental benefits we may realize i om the operation of escrow accounts are taken into consideration.
These include the temporary availability to the bank of funds resulting from the retention of dividends or interest pending disbursement, the execution of securities transactions for accounts and funds from other sources.
Collected funds must be deposited prior to disbursement of interest. Float on these funds is considered in calculation of the fees.
4 STANDBYTRUSTAGREEMENTTI/NRC PAGE 10
T g
w ACKNOWLEDGEMENT
[The following is an example of the acknowledgement that must accompany the trust agreement for a standby trust fund or trust fund.]
STATE OF
/ " '~'ta To Wit:
CITY OF
> de e oc, Onthis/J&ayof8gffr[-
, before me, a notary public in and for the city and State aforesaid, personally appeared Fr+sraxulin?-and she/he did depose and say that she/he is the [ title], of f Moe PrenMan+'1, national banking association, Trustee, which executed the above instrument, that she/he knows the seal of said association; that the seal affixed to such instrument is such corporate seal; that it was so affixed by order of the association; and that she/hesignedher/hisnametheretobylikeorder.
-[ %
V. WASHINGTON
[Signatupf notary public]
My Commission Expires: f-Jd -f/-
[Date]
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V. WASHINGTON NOTr&Y PUBtK. ST All of ittmo!5
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b ObiqCIA1. Hi:XXmo COPE Fa,20 117056 STANDBYTRUSTAGREEMENTTI/NRC PAGE 11 I
O Continental Bank" CABLE ADDRESS Comi Bank Teen C2 f233
- SWIFT ADDRESS CNTLUS44 e TELEFAX NUMBER T+6748?B 4
PAGE: 1 DATE: AUGUST 4, 1992 IRREVOCABLE DOCUMENTARY CREDIT NUMBER: C7205732 BENEFICIARY APPLICANT U.S. NUCLEAR REGULATORY COMMISSION TEXAS INSTRUMENTS INCORPORATED REGION 1, ATTN JOHN KINNEMAN P.O.
BOX 650311,MS 3994 475 ALLENDALE ROAD ATTN: JOHN D.
MCCOLLEY KING OF PRUSSIA, PA 19406-1415 DALLAS TX 75265 i
AMOUNT j
USD 380,980.00 THREE HUNDRED EIGHTY THOUSAND NINE HUNDRED EIGHTY AND 00/100'S US DOLLARS EXPIRY AUGUST 4, 1993 AT OUR COUNTERS WE HEREBY ESTABLISH OUR IRREVOCABLE STANDBY LETTER OF CREDIT NUMBER C7205732 IN YOUR FAVOR, AT THE REQUEST AND FOR THE ACCOUNT OF TEXAS INSTRUMENTS INCORPORATED, P.O. BOX 650311, MAIL STATION 3994, DALLAS, TEXAS 75265 (HEREINAFTER "TI") REFERENCING DOCKET NO. 70-33 AND SNM LICENSE NO. 23 UP TO THE AGGREGATE AMOUNT OF THREE HUNDRED EIGHTY THOUSAND NINE HUNDRED EIGHTY U.S. DOLLARS (U.S.$380,980.00) AVAILABLE UPON PRf.:SENTATION OF (1) YOUR SIGHT DRAFT, BEARING REFERENCE TO THIS LETTER OF CREDIT NUMBER C7205732, AND (2) YOUR SIGNED STATEMENT READING AS FOLLOWS:
"I CERTIFY THAT THE AMOUNT OF THE DPAPT IS PAYABLE PURSUANT TO REGULATIONS ISSUED UNDER AUTHORITY OF THE U.S. NUCLEAR REGULATORY COMMISSION.*
EACH DRAFT MUST BEAR THE CLAUSE " DRAWN UNDER LETTER OF CREDIT NUMBER C7205732, DATED AUGUST 4, 1992, AND THE TOTAL OF THIS DRAFT AND ALL OTHER DRAFTS PREVIOUSLY DRAWN UNDER THIS LETTER OF CREDIT DOES NOT EXCEED US$380,980.00."
WHENEVER THIS LETTER OF CREDIT IS DRAWN ON UNDER AND IN COMPLIANCE WITH THE TERMS OF THIS LETTER OF CREDIT, WE SHALL DULY HONOR SUCH DRAFT UPON ITS PRESENTATION TO US WITHIN 30 DAYS, AND WE SHALL DEPOSIT THE AMOUNT OF THE DRAFT DIRECTLY INTO THE STANDBY TRUST FUND OF TI IN ACCORDANCE WITH YOUR INSTRUCTIONS.
THIS LETTER OF CREDIT IS ISSUED IN ACCORDANCE WITH REGULATIONS ISSUED UNDER THE AUTHORITY OF THE U.S. NUCLEAR REGULATORY COMMISSION (NRC),
AN AGENCY OF THE U.S. GOVERNMENT, PURSUANT TO THE ATOMIC ENERGY ACT OF 1954, AS AMENDED, AND THE ENERGY REORGANIZATION ACT OF 19 7 4. TEL:
NRC HAS FROMULGATED REGULATIONS IN TITLE 10, CHAPTER 1 OF THE CODE OF FEDERAL REGULATIONS, PART {30, 40, 70, OR 72,} WHICH REQUIRE THAT A HOLDER OF, OR AN APPLICANT FOR, A LICENSE ISSUED UNDER 10 CFR PARTS
{30, 40, 70, OR 72} PROVIDE ASSURANCE THAT FUNDS WILL BE AVAILABLE WHEN NEEDED FOR DECOMMISSIONING.
THIS LETTER OF CREDIT IS EFFECTIVE AS OF AUGUST 4, 1992 AND SHALL EXPIRE ON AUGUST 4, 1993, BUT SUCH EXPIRATION DATE SHALL BE ORIGINAL L
4 F'LE ASE ADDRE SS ALL CCHRESPONDENCE TO Contmentaf Bane N A e Leters of Cre%1580 e 231 South LaSahe Street, CNcago, thntus 60697
(] Continental Bank' 1
CABLE ADDRESS Cond BwA Teen 02 5233 e SMFT ADDRESS CN1LUS44
- TELEFAX NUtABER 9874,828 PAGE: 2-THIS IS AN INTEGRAL PART OF LETTER OF CREDIT NUMBER: C7205732 AUTOMATICALLY EXTENDED FOR A PERIOD OF ONE YEAR ON THE ORIGINAL EXPIRATION'DATE AND ON EACH SUCCESSIVE EXPIRAITON DATE, UNLESS, AT LEAST 90 DAYS BEFORE THE CURREN"' EXPIRATION DATE, WE NOTIFY BOTH YOU AND TI, BY CERTIFIED MAIL, AS S!!OWN ON THE SIGNED RETURN RECEIPTS. IF TI IS UNABLE TO SECURE ALTERNATIVE FINANCIAL ASSURANCE TO REPLACE THIS LETTER OF CREDIT WITHIN 30 DAYS OF NOTIFICATION OF CANCELLATION THE NRC MAY DRAW UPON THE FULL VALUE OF THIS LETTER OF CREDIT PRIOR TO CANCELLATION. THE BANK SHALL GIVE IMMEDIATE NOTICE TO THE APPLICANT AND THE NRC OF ANY NOTICE RECEIVED OR ACT* SON FILED ALLEGING (1) THE INSOLVENCY OR BANKRUPTCY OF THE FINANCIAL INSTITUTION OR (2)
ANY VIOLATIONS OF REGULATORY REQUIREMENTS THAT COULD RESULT IN SUSPENSION OR REVOCATION OF THE BANK'S CHARTER OR LICENSE TO DO BUSINESS. THE FINANCIAL INSTITUTION ALSO SHALL GIVE IMMEDIATE NOTICE IF THE BANK, FOR ANY REASON, BECOMES UNABLE TO FULFILL ITS OBLIGATION UNDER THE LETTER OF CREDIT.
THIS CREDIT IS SUBJECT TO THE
- UNIFORM CUSTOMS AND PRACTICE FOR DOCUMENTARY CREDITS" (1983 REVISION), INTERNATIONAL CHAMBER OF COMMERCE PUBLICATION NO. 400.
IF YOU REQUIRE ANY ASSISTANCE OR HAVE ANY QUESTIONS REGARDING THIS TRANSACTION, PLEASE CALL 312-923-59I5.
i
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CONTINENTAL BANK, NATIONAL ASSOCIATION
/M.'
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FOR CASHIER MY FOR CASHIER i
THIS DOCUMENT CONSISTS OF 2 PAGE(S).
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PLEASE ADDRESS ALL CORRESPONDENM 10.
Cornme,ta' Dank N.A
- Lenes of Cman-Src
- 231 South LaSaue Sveet, Chogo Eknos fME97
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a TEXAS INSTRUMENTS po# y
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q l-July 30,.1992 Certified Mail I
ReturnReceipt Requested
~
?Oj[ah(o RECEIVED BY LFDCB 27 e c*, #
A Mr. Jerome Roth A L-y 4
NuclearRegulatory Commission
/ /
D** -
/pd Region I i
~ ~ * - ~ ~ ~ ~
475 Allendale Road Kingof Prussia,PA 19406-1415
__ s_ C
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~~
Re:
Docket No. 70-33 SNM License No. 23 Texas InstrumentsIncorporated j
Attleboro, MA 02703 1
- 1. NRC Review of Appmval of Remediation Plan
- 2. Development of the Remediation Plan Schedule
- 3. Pre-excavation Survey 4.: Financial Assurances li
Dear Mr. Roth:
1 Thankyou for the very informative and productive meeting which was held at the -
i Region I offices of the NRC on July 14, 1992. At that meeting, TI presented the results of the June Pilot Study Investigation and delivered the Remediation Plan for the Former LLRW Burial Site.
l 1.0 NRC Review and Approvalof the RemediationPlanfor TI Attleboro's Former LLRW BurialSite As an outcome A le July 14 meeting, NRCindicated it would commence review l
and approval of the ri sa diation plan pending receipt of two additionalsubmittals:
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the final 'Het Ith & Safety Plan," and d
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the "Pr ect ichedule" indicating major milestoMs.
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C Both of these document ar.; attached to this correspndense.
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initiate excavation dEring ths' week of August 31
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Please note that TI w A: t and would greatly appreciate il 6e NRC would grdnt per.znission to begin work on or before Friday, August 28, 1992.
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2.0 Development of the RemediaJrSchedule i
Pursuantto an agreement ruct<d at the meeting of April 14,1992 between the NRC and TI, TI committed to sul wi2ing a schedule for development of a remediation' j
plan regarding it's Former L1 TJ Darial Site. TI has gone beyond it's commitment; since upon receipt of the wrents attached to this correspondence, it will have submitted a fully developed e r uiation plan and project schedule.
l DFftcICIAL RECORD COJP-E 10 11705G
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TEXA$ INSTRUMENTSINCORPORATED
- 34 FOREST STREET
- ATT O. MA 07703 -
- b tVJO699 3800 + TELEM 710801
- CABLE TExtNS
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Mr. Jerome Roth July 30,1992 Page 2 3.0 Pre-excavation Survey During the period from July 17 through July 28, 1992, TI performed numerous field activities to complete the pre-excavation survey as described in the Remediation Plan. The original 1984 ORAU (10m x 10m) grid pattern was re-established by a kcal surveyor. Subsequently, fifty (50) soil borings were advanced to a depth of one (1) meter and in nine (9) of those locations to a depth of two (2) meters.
Split spoon samples were collected at half (0.5) meter intervals for analysis by gross alpha screening.
Five (5) samples were packaged and shippd for confirmatory analysis at Lockheed Analytical Laboratories (LAL)in Las Vegas, hevada. Three (3) mini-wells were driven to a depth of two (2) meters with a five (5) foot screened intervals below the water-table.
At a later date, the mini-wells along with other monitor wells in the vicinity, will be sampled for radioactivity.
TI's health physics consultants, CPS, were onsite during all fieldwork. IIcalth &
Safety protocol were followed to be consistent with the level of risk during each operation performed.
The results of the pre-excavation survey will be used to more accurately estimate soil volumes and areas to be excavated.
It is expected that this information will le availableby August 14, 1992.
4.0 Financial Assurances M&C's Environmental, Safety, and IIcalth Department Manager, Francis J. Veale, along with the assistance of M&C's Controller, have initiated a Letter of Credit and Standby Trust Agreement for $380,980 through an appropriate fiancial institute. It is anticipated that this exercise will be complete within approximately fourteen (14) days.
Upon receipt, TI will forward a copy of the letter of credit for NRC files.
Thank you for your continued efforts in support of TI's license termination activities. Please feel free to contact me if I can clarify anything or provide further assist mee. I can be reached at (508) 699-1809.
Sincerely, g
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Mic ael J. Elliott/
EnvironmentalManager j
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Mr. Walter Pasciak, NRC Region 1 Mr. John Kinneman,NRC Region I Mr. FrancisJ. Veale, Jr., Esquire,TI Attleboro Mr. Richard Churchill,TI Attleboro Enclosures
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w Former LLRW Burial Site Remediation Texas Instruments Incorporated Materials & Controls Group Attleboro, Massachusetts Special Nuclear Material License No. 23 PROJECT SCHEDULE July 30, 1992 Description Start End of Task Date Date 1.
Pre-excavation Survey:
1.1 Drilling & Sampling Sat 7/25 1.2 Analysis by Gross Alpha Mon 8/03 Screening 1.3 Confirmatory Analysis by Tue 7/28 Fri 8/07 Lockheed Analytical Labs (LAL) 1.4 Revised Project Estimates Mon 8/10 Fri 8/14
-Contaminated Soil Volume
-Area of Excavation 2.
Regulatory Oversight 2.1 Complete Submittal of Reme-Fri 7/31 diation Plan & Schedule 2.2 NRC Review and Approval Mon 8/03 Fri 8/28 2.3 ORAU Sampling and In-Mon 9/14 Fri 9/18 spection of Open Excavation 2.4 ORAU Post-verification Survey
-Fieldwork Hon 11/30 Fri 12/04
-Data Compilation Mon 12/07 Fri 12/18
& Report
g AU Project Schedule July 30, 1992 Page 2 Description Start End of Task Date Date 3.
Excavation & Segregation 3.1 Perform Excavation &
Mon 8/31 Fri 9/11 Segregation 3.2 Leave Excavation Exposed Mon 8/31 Mon 9/21 for ORAU Inspection 3.3 Backfill Excavation Mon 9/21 3.4 Stockpile Segregated Soils Awaiting Final Disposition Clean Mon 8/31 Mon 9/21 Contaminated Mon 8/31 Wed 9/30 4.
Transportation & Disposal 4.1 Order 90T Rail Gondola Fri 8/14 Covers 4.2 Grder 90T Rail Gondolas Mon 9/14 4.3 Receive 90T Rail Mon 9/28 Gondolas & Covers 4.4 Package & Ship 90T Rail Mon 9/28 Wed 9/30 Gondolas for Disposal 4.5 Acceptance of Material Wed 10/14 at Licensed LLRW Land-fill i
5.
Post Excavation Survey l
5.1 Field Survey & Sampling Tue 9/22 Wed 9/30 5.2 Analysis by Gross Alpha Tue 9/22 Thu 10/01 Screening 5.3 Confirmatory Analysis Fri 9/25 Thu 10/01 by LAL 5.4 Prepare Draft Report Thu 10/01 Thu 10/22 5.5 Issue Final Report Hon 10/26
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1 RADIOLOGICAL HEALTI-AND SAFETY PLAN Developed for Texas Instruments incorporated Materials and Control Group By Creative Pollution Solutions, Inc.
Version 2.0 July 20,1992 l
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RADIOLOGICAL HEALTH AND SAFETY PLAN TABLE OF CONTENTS 1.
Scope ll.
Site History and Description Ill.
Responsible Organizations and Key Personnel IV.
Work Stop Authority V.
Site Radiological Characteristics VI.
Personnel Training Requirements Vll.
Site Control Vill.
Personal Protective Equipment IX.
Monitoring and Sampling X.
Decontamination XI.
Medical Surveillance Xil.
Informational Programs Xill.
Record Keeping l
Appendix A -- Site Map and Zone Description i
Appendix B -- Site Access Log l
Appendix C -- Dosimetry Assignment Log l
Appendix D -- Action Limits l
l Appendix E -- Training Log I
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- l. Scope This health and safety plan is established for the radiological health and safety aspects of the remediation work to be performed on the former burial site (between buildings 11 and 12) at the Texas Instruments incorporated facility in Attleboro, Massachusetts, in part, this plan will be based, when applicable, to the USNRC license SNM-23 Health anu Safety Plan and incorporating relevant sections by inclusion or reference to the generic health and safety plan developed by Franklin Environmental Services.
This health and safety plan details the site specific requirements for radiation protection purposes only.
General health and safety considerations, including chemical and physical hazards, are addressed in the general health and safety plan developed by Franklin Environmental Services.
II. Site History and Description HISTORY In 1952, the General Plate Division of Metals & Controls, Incorporated (M&C) became involved in the nuclear materials field to fabricate enriched uranium into thin foils for use in reactor experiments. In 1956, M&C received a contract form the Federal Government to manufacture the fuel core of the submarine " Triton".
Additional contracts for Triton refuelings were completed by January 1959.
In 1959, M&C merged with Texas instruments incorporated, Materials and Control Group (TI) and continued processing nuclear materials. TI's involvement in the nuclear business, including the fabrication of High Flux Isotope Reactors (HFIR), extended to 1981.
1 VER. 2.0
w The A.E.C. approved the burial of low level contaminated construction materials and refuse in the disposal area east of building 10 (see site map appendix B). It is TI's belief that only low level scrap waste was disposed of on site. Ti has indicated that there is no evidence, documentation, or records of any source material ores being disposed of on-site.
In 1982 decontamination and decomrnissioning activities in the area within building 10 were conducted. Having met the established standards for decommissioning work on the interior of the buildings, the NRC then dictated that Tl wou!d have to meet acceptable health and safety levels for residual radiation with regard to the grounds outside the buildings. In particular, the former on-site disposal area between buildings 11 and 12 was the primary area of concern.
i Subsequently, Tl performed a radiological survey and Oak Ridge Associated Universities (ORAU) performed a verification study (pubiished 12 February 1985), and CPS performed a pilot excavation / sampling study (June 1992). These studies helped to identify the areas for excavtion between buildings 11 and 12. (see Appendix A)
DESCRIPTION The Texas Instruments incorporated, Materials and Control Group, Attleboro, MA, site is located in Attleboro, approximately 48 kilometers south of Boston on Route 123.
The area of concern for this pilot study has been identified as the burial site which is located to the southwest of Building 12.
l 2 VER. 2.0
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III. Responsible Organizations and Key Personnel Specific individuals specified within the organizations shall be identified by the site access log detailed in appendix B.
A. Organizations
- 1. Texas Instruments, incorporated Texas Instruments, incorporated by virtue of ownership is responsible for all aspects of the project scope.
Departments involved include:
Environmental Health and Safety, Security, Medical, and Facilities.
- 2. Franklin Environmental Services Franklin Environmental Services is responsible for the physical excavation, preperation and packaging of materials for disposition.
Personnel involved include operations and health and safety.
- 3. Creative Pollution Solutions, Inc.
Creative Pollution Solutions, Inc.
will provide the Site Specific Radiological Health and Safety Plan, radiation protection and controls during site activity, and recommendations to Texas Instruments, incorporated regarding radiation protection 3 VER. 2.0
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B. Key Personnel
- 1. Texas Instruments, Inc.
Environmental Health and Safety Health and Safety Site Security Facilities Shipping and Receiving Medical
- 2. Franklin Environmental Services Operations Manager Safety and Compliance Officer Machine Operator Laborers
- 3. Creative Pollution Solutions, Inc.
Field Supervisor / Health Physicist Certified Health Physicist Health Physics Technicians Health Physics Analytical Support IV. Work Stop Authority Any individual or organization has the right to shut down the operations on the site.
In the event of a disagreement, the most conservative approach shall be taken. A meeting shall be convened by identified representatives of each organization to assess the decision at hand.
4 VER. 2.0
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V. Site Radiological Characteristics Radiological hazards associated with this site are the result of previous NRC licesened activities which involved the manufacturing and processing of uranium. Hence, site radiological hazards are those associated with this material.
Concentrations of radioactive materials and site assessment is detailed within the Oak Ridge Associated Universities report (Report # RSAP / SMPB-8). According to the Oak Ridge report the radionuclides of interest include: U-238, U-235, Th-232, and Ra-226.
Concentrations of Radionuclides in Surface Soil (Grid intersections)
The concentration of U-238 in soil ranges from < 0.38 - 44.9 pCi/g. U-235 concentrations ranged from < 0.11 to 8.15 pCi/g. Th-232 concentra: ions ranged from 0.13 - 3.56 pCi/g. Ra-226 concentrations ranged from 0.11 -
1.86 pCi/g.
Concentrations of Radionuclides Surface Soil (Elevated Contact Radiation 1.evels)
The concentration of U-238 in sub-surface soil ranged from < 46.6 - 887 pCi/g; U-235 ranged from < 1.78 - 590 pCi/g; Th-232 ranged from 1.04 - 10.2 pCi/g; and Ra-226 concentrations were found not to be significantly greater than background.
1 Concentrations of Radionuclides Sub-Surface Soil Radionuclide concentrations in the sub-surface soit did not depart significantly from surface soil concentrations.
5 VER. 2.0
O External Exposure Rates (Grid Intersections)
External Exposure Rates ranged from 10 - 14 pR/h.
External Exposure Rates (Elevated Readings)
At numerous locations within the site elevated expsoure rates ranged from 16 - 200 R/h.
Verification Surveys Verification external exposure rate and soil sampling surveys conducted by Creative Pollution Solutions, Inc. were consistent with the ORAU report mentioned above. This verification survey combined with the more extensive ORAU report were used to determine soil sample locations and excavation areas (Radiological Characterization report, CPS, July 1992).
VI. Personnel Training Requirements All site personnel will have received training consistent with that required under the general health and safety plan developed by Franklin Environmental Services. Site specific training regarding radiation protection and control will be conducted by CPS. Site specific training will include, but not be limited to, physical properties and health effects of radiation and decontamination of personnel and equipment.
6 VER. 2.0
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Vll. Site Control 1
The site will be broken down into three primary zones: the Exclusion Zone, the Contamination Reduction Zone and the Support Zone. These zones are all to be considered part of the larger Restricted Area. Only authorized personnel will be allowed within the Restricted Area. See Appendix B for
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locations of zones within the site map.
Exclusion Zone -- Exclusion zone is the area within the Restricted Area where sampling work will be performed. The exclusion zone will require level C protective clothing unless a decision to downgrade is made.
Contamination Reduction Zone -- Within the contamination reduction zone a control point will be established to control access to the Exclusion Zone. A personnel decontamination area and an equipment area will a!so be established.
Support Zone --- The support zone will include a command center, equipment and supplies.
Security check points will be established in order to control access to the Restricted Area. In addition, parking lots by buildings 11 and 12 will not be used by unauthorized personnel during site operations.
Tl personnel will assure that only authorized personnnel are allowed past security check points without an escort. All visitors allowed past security check points must be with a Tl escort and must remain in pre-established visitor areas within the support zone.
7 VER. 2.0
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l Vill. Personnel Protective Equipment Personnelin the Exclusion Area will maintain, as a minimum, level D protective equipment. The minimum protective equipment required includes:
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I hard hat, steel toed safety shoes, and dosimetry. Additional protective equipment may be required as conditions warrant. Decisions to upgrade or downgrade protective equipment at any time during the site operation will be made jointly by Texas Instruments Incorporated, Materials and Control Group personnel and Creative Pollution Solutions, Inc. personnel.
IX. Monitoring and Sampling This section describes the radiological sampling and monitoring to be done l
during site operations in order to protect site personnel and the community.
Action Levels have been established for certain aspects of sampling and monitoring (Appendix D).
l Area Air Sampling Area air sampling will be performed, as needed, during site operations at perimeter locations and work areas. Perimeter locations will be based on prevailing conditions.
Personnel Breathing Zone Air Samples Personnel BZA's will be provided to a representative number of workers based on job task.
8 VER. 2.0 1
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Dose Rate Monitoring Direct Reading Direct reading dose rate monitoring will be performed during all site operations. This monitoring will be performed to assess direct worker exposure levels.
Personnel Dosimetry I
Personnel dosimetry shall be worn by all personnel entering the exclusion zone. Personnel dosimetry shall include thermoluminescent I
dosimeters (Landeur) and/or self reading pocket dosimeters.
Bioassay Measurements In-vitro bioassay monitoring consisting of baseline and post-work urinalysis will be performed on all personnel working in the exclusion zone. Urinalysis samples will be analyzed for total uranium via flourometric techniques by an identified outside laboratory.
i Personnel Contamination Monitoring Frisking of personnel and equipment shall be performed prior to exit from the contamination reduction zone. Frisking will be done to assure personnel and equipment are not contaminated.
9 VER. 2.0
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w X. Decontamination Personne! Decontamination Personnel decontamination will be performed in accordance with standard decontamination practices as outlined in the
" Occupational Safety and Health Manual for Hazardous Waste Site Activities".
In addition to standard waste site procedures frisking out of all personnel will take place prior to exiting the exclusion zone.
Equipment Decontamination All equipment shall be surveyed to determine disposition.
Disposition shall include decontamination for free release (see Appendix D) or disposed of as appropriate.
XI. Medical Surveillance Medical surveillance shall be performed for all personnel working in the exclusion zone. Medical surveillance shall be in accordance with the general health and safety plan developed by Franklin Environmental Services in addition, for this site, a bioassay analysis j
for the assessment of intakes of radionuclides shall be performed pre and post site work.
l 10 VER. 2.0 l
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Xil. Informational Programs informational programs are the responsibility of Texas Instruments incorporated, Materials and Control Group. These programs will inform Tl employees and the community of the site work as necessary.
Xill. Record Keeping Site records will be kept including but not limited to : Site log, site sampling and monitoring, personnel dosimetry records, and bioassay results.
XIV. Emergency Response Contingency Plan Emergency procedures will be consistent with those outlined in the general health and safety plan developed by Franklin Environmental Services and Texas instruments incorporated, Materials and Control Group Disaster Emergency Management Plan.
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i 11 VER. 2.0
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Appandix A Site Map and Zone Description
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I Site Access Log Name Date Company Position / Purpose 15 VER. 2.0
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Appendix C I
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Dosimetry Assignment Log h
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1 Self Reading Pocket Dosimeter issuance Log Reading Name Date in Out Net 18 VER. 2.0
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Appendix D Action Limits 19 VER. 2.0 1
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O Air Sample (General Area)
General Area Air Sampling is performed to assess airborne concentrations of radionuclides. Action Limits are established in accordance with NRC published concentration limits.
i Concentration Action
< 25%
No Action 25% < X < 75 %
Investigate and notify radiation protection supervision 75% < X < 100%
Stop work.
Notify radiation j
protection supervision.
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1 20 VER. 2.0 l
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' Personnel Exposure j
i External Dose t
Thermoluminescent Dosimetry (TLDs) shall be the dose of record for those issued.
Self reading pocket dosimeters are fer exposure control purposes, dose of record for those not issued TLDs, and to serve as a backup to TLDs.
Action limits are established for dose control purposes using the self reading pocket dosimeters.
SRD Reading Action
< 20 mR No Action
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20 mR < X < 100 mR Notify Radiation Protection Supervision for Investigation
> 100 mR Remove worker from area and notify and
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notify Radiation Protection Supervision.
Breathina Zone Air Samoles (BZA) f BZAs are worn by a representative group of workers based on job function. BZAs are used to assess potentialintakes of radionuclides. Action Limits are as follows:
< 150 dpm No action
> 150 dpm Investigation level. Verify by bioassay 21 VER. 2.0 l
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w Bipassav (Urine analysis)
Urine samples are obtained to assess intakes and verify the effectiveness of the respiratory protection. Bioassay results are reported in the units of pCi/l. The results are compared to baseline values and to investigation / Action levels.
Bioassay results Action
< 45 pCi/l No action
> 45 pCi/l Investigation Contamination Levels in accordance with USNRC guidelines for " Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuciear Material", Dated November 1976, the following is established:
Area Alpha Beta fixed removable fixed removable Clean areas 2000 200 20,000 2000 Equipment 2000 200 20,000 2000 22 VER. 2.0
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w Exposure Rates Action Limits for external exposure rates are specified as follows:
Exposure Rate Action Background < X < 1 mR/h No Action 1 mR/h < X < 10mR/h Stop work and Radiation Protection Supervision Notified for investigation 10 mR/h < X < 100 mR/h Stop Work. Personnel retire to area of exposure rate less than 1 mR/h.
Radiation protection supervision notified for investigation.
> 100 mR/h Stop work, evacuate to control point and exit to command center.
Radiation Protection supervision notified.
1 23 VER. 2.0
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W Appendix E l
i Training Log l
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w Training Log Description of Training:
Date:
Attendees:
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25 VER. 2.0
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