ML20198P460

Submits Results of Evaluation of Financial Assurance Instruments Held within NMSS Headquarters in Instruments Safe.Evaluation Also Provides Verification That Current Financial Assurance Info Is in Licensing Tracking Sys

ML20198P460
Person / Time
Issue date:	01/14/1998
From:	Johnson T NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20198P413	List: ML20198P409 ML20198P460
References
REF-WM-3 NUDOCS 9801220128
Download: ML20198P460 (10)

Text

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,j NUCLEAR RECULATORY COMMISSION o

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January 14, 1998 MEMORANDUM TO: John W. N. Hickey, Chief Low Level Waste and becommissioning Projects Branch Divistori of Waste Management FROM:

Timothy C. Johnson, Section Chief Facilities Decommissioning Sectionw)

Low Level Waste and Decommission Projects Branch Division of Waste Management

SUBJECT:

FINANCIAL ASSURANCE INSTRUMENT SECURITY EVALUATION in accordance with Management Directive 8.12, Decommissioning Financial Assurance instrument Secunty Program," on December 30 and 31,1997, and January 2,1998, I conducted an ( valuation of the financial assurance instruments held within the NMSS Headquarters instrument safe. My evaluation was based on the evaluation form attached as. I also checkeo to venfy that current financial assurance information is in the Licensing Tracking System (LTS).

My findings are provided in Attachment 2. No instuments were missing. The instruments are being stored in a GSA approved safe in accordance with Management Directive 8.12. In general, the inventory log should be more rigorously filled out to ensure that proper dates, instruments, and signatures are identified Outdated instruments should be removed from the safe and returned to the licensee. When new instruments are submitted, this information needs to be included not only in the inventory log, but also the inventory control list Note that this was a recommendation in L. Bykoski's evaluation of December 1996, but has not been fully implemented. Entries in the inventory controllog should also be more complete. Note that this was also a recommendation in L. Bykoski's evaluation of December 1996, but has not been fully implemented. For almost all NMSS licenses requiring financial assurance, the LTS needs to be updated. Not all the LTS update recommendations made in L. Bykoski's Decemuer 1996 evaluation appear to have been incorporated. While recommendations were forwarded to the appropriate groups, there was no formal followup to ensure resolution of the open items. In the future, resolution of open items need to be formally tracked to ensure proper closure.

Attachments: As stated

Contact:

TCJohnson, DWM/NMSS (301) 415-7299 9001220128 900115 PDR WASTE WPt-3 PDR

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F'nancial Assurance instrument Evaluation Comments i

1.

Inventory Loj Sheets Most entnes under " Signature of Person Removing or Returning Instrument and Date" use initials and not signatures Signatures should be used for these entnes. Also, many entnes do not have dates Dates should be included for all entnes.

2.

Kerr-Mc'1,e. Cimarron Need to remove superseded parent guarantee documents and retum to licensee.

3.

pa.:,:ock & Wilcox Need to remove outdated instruments.

The Morgan letter of credit is undated - should 'his be 12-18-967 The Scotiabank letter of credit amendment dated 7 28-97 was not on the inventory log.

Inventory log sheet dates do not match some instrument dates Need to check the BWT standby trust value of $16,832,000 4.

Framatome Remove outdated instruments.

5.

Siemens Was a parent guarantee instrument submitted with the 12 20-96 CFO and auditor a letters?

If so, it should be checked to see if it is still valid and whether or not it has been superseded.

The standby trust amendment dated 4-16-97 was not listed correctly on the inventory log.

Need to remove outdated instruments.

The inventory log shows Parent Guarantee Amendment No.1. Need to verify what this is.

In the safe are standby trusts from Wachovia Bank and First Citizens Bank and a standby trust amendment from Bank of New York. Need to determine which of these standby trusts are valid and which trust the amendment applies to.

6.

NFS The escrow agr aments dated 2-17-97 and 9-24-97 are not shown on the inventory log.

Need to remuve outdated instrum-nts.

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2-7.

Dow Need to remove outdated instruments, 8.

' Jefferson Provina Ground Remove outdated instruments.

The Statement of intent is undated.' Need to have it dated.

9.

Fort St Vrajn The license was terminated in August 1997. The instruments need to be canceled and returned to the licensee.

10.-

Cintichem The standby trust document is not an original. Need to obtain an originalif possible.

11 Molycorp it appears that the parent guarantee documents dated 8 3194 have been superseded if so,' remove the outdated parent guarantee instrument.

12. Hartley & Hartlev. SCA It appears that insurance policy documents dated 3-3194 and 4-26-94 have been superseded. If so, these documents should be removed.

13.

Hartlev & Hartley. MDNR lt appears that the staternent of intent dated 9 5-95 has been superseded. Remove outdf.ed instruments.

14. Whittaker The letter of credit number is different from that stated on Schedule A of the standby trust.

Need to ensure that the standby trust properly references the correct letter of credit.

15. Seouoyah Fuels There are two escrow agreements in the safe. Has one been superseded? If so, please remove the superseded instrument.

16. General Electric Need to remove superseded self guarantee documents.

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.19.. Westinohouse

~ The Westinghouse financial assurance instruments m the safe were not listed on the-inventory log.

20. Rio Alcom. Lisbon -

Have the parent guarantees dated 3-2191,6 25-92, and 6-8 95 been superseded? If so, they should be removed from the safe.

21, Kennecott. LBar The letter of credit is issued to Sohio Westem and not Kennecott. Is this an acceptable name for the licensee?

. 22. Esthfinder. Lucky Mc Have the letters of credit issued by the Banque National de Paris been superseded?If so, they should be removed from the safe.

23 ARC L Bluo..ater There is only a copy of the standby trust. The original should be located, if possible.

24. Pathfinder. Shirley Basis Have the letters of credit issued by the Banque National de Paris been superseded? If so, e

they should be removed from the safe.

1 25,. Quivera It appears that the parent guarantees dated 3 2191,6-8-95, and 6-26-96 have been superseded. if so, they should be removed from the safe.

26. Rio Alcom. Smith Ranch Superseded and draft copies of the parent guarantee should be removed from the safe.

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27. Licensino Trackino System The Licensing Tracking System (LTS) needs to be updated for the following licenses:

ARCO, Bluewater (SUA-1470)- not in LTS Atlas, Moab (SUA 917)

Envirocare (SUA 1559)

Exxon, Highlands (SUA-1139)

Homestake. Milan (SUA-1471)

Schio Westem, LBar (SUA 1472)

Kennecott, Sweetwater (SUA-1350)

Pathfinder, Lucky Me (SUA-672)

Pathfinder, Shirley Basin (SUA 442)

Petrotomics (SUA 551)

Plateau Resources (SUA 1371)

Quivera, Ambrosia Lake (SUA-1473)

Rio Algom, Lisbon (SUA 1119) _

Rio Algom, Smith Ranch (SUA-1548)- not in LTS Umetco, White Mesa (SUA 1358)

L'NC, Church Rock (SUA 1475)

UWX (Stu A-2J01)

BWX (SNM 42, SNM-414)

BP Chemicals (SUB-908)

Cabot, Boyertown (SMB 920)

Cabot, Reading and Revere (SMC-1562)

Chemetron (SUB-1357)

Cintichem (SNM-639) - not in LTS Dow (21-00265-06, STB-527, R 108)

Fansteel (SMB-911)

General Atomics (SNM-696, R-67, R-38)

General Electric (vanous licenses)

Hartley & Hartley, MDNR - not in LTS Hartley & Hartley, SCA Kerr McGee, Cimarron (SNM 928) - not in LTS McDermott Technologies (SUB-1259, BPM-34-03043-03) - not in LTS Molycorp (SMB-1408) - not in LTS Nuclear Fuel Services (SNM-124)

RMI (SMB-602)

Sequoyah Fuels (SUB-1010)

Shieldalloy (SMB-743, SMB-1507)

Siemens (SNM-1227)

Department of Commerce, NIST (SNM-362)

The above LTS entries need to be updated to reflect the correct name of the licensee; the correct instrument type, issuer, and amount; and whether the instrument has beer; approved and the correct date of approval. Some of the uranium milllicense entries have the number of the letter of credit, bond, etc. These numbers should be removed from the LTS as the LTS is not a controlled database.

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4The following licenses have listings in the LTS, but there are no instruments in the saie:

L American Nuclear (SUA 667) l Bear Creek (SUA 1310)l

- Cogoma (SUA 1341)'

Crow Butte (SUA 1534) _

International Uranium (SUA-1558)-

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Pathfinder (SUA 1540)-

Power Resources (SUA-1511)1

- Umetco (SUA-648).

- U.S. Energy (SUA 1524)

-Westem Nuclear (SUA 56)

Baltimore Gas & Electric (SNM-2505)

Massachusetts Institute of Technology (SNM 986)

Pennsylvania State Univ. (SNM 95)'

Purdue Univ, (SNM 142)

- The LTS entries for the above licenses need to be checked to venfy that financial assurance is required; that instruments have been provided and we know where the instruments are (if the-instruments are not in Regional safes, the instruments need to be forwaNed to DWM or the.

Regions for placement in t_he instrument safe); ano the LTS entries need to be updated as.

necessary.

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1 Uraniurr Recovery Branch Financial Assurance Evaluation Followuo items ltem l Finding Action Needed Disposition Status 1.

Rio Algom, Lison: The parent Remove superseded items an j OPEN guarantees dated 3-21-91,6 return originals to licensee.

92, and 6-8-95 appear to have been superseded.

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2.

Kennecott, LBar. The letter of Verify that Sohio Westem is the OPEN credit is issued to Schio Western correct name of the licensee.

and not Kennecott.

3.

Pathfinder, Lucky Mc: The letters -

Remove superseded items and OPEN of credit issued by the Banque retum originals to licensee.

National de Paris appear to have been superseded.

t 4.

ARCO, Bluewater. The original Locate the original, if possible.

OPEN standby trust agreement is not in the safe.

5.

Pathfinder, Shirley Basin: The Remove superseded items and OPEN letters of credit issued by the retum originals to licensee.

Banque National de Paris appear to have been superseded.

6.

Quivera: The parent guarantees Remove superseded items and OPEN dated 3-21-91,6-8-95, and 6 retum originals to licensee.

96 appear to have been superseded.

2 OPEN 7.

Rio Algom Smith Ranch: There Remove superseded items and api; ear to be superseced copies retum originals to licensee.

of the parent guarantee.

OPEN 8.

The LTS has outdated information The LTS entries need to be for the following licensees:

updated to reflect the correct name of the licensee; the correct ARCO, Bluewater (SUA-1470) -

instrument type, issuer, and not in LTS amount; and whether the Atlas, Moab (SUA-917) instrument has been approved I

Envirocare (SUA-1559) and the correct date of approval.

Exxon, Highlands (SUA-1139)

Some of the uranium milllicense Homestake, Milan (SUA-1471) entries have the number of the Schio Western, LBar (SUA-1472) letter of credit, bond, etc These Kennecott, Sweetwater (SUA-numbers should be removed from the LTS as the LTS is not a 1350)

Pathfinder, Lucky Mc (SUA-672) controlled database.

Pathfinder, Shirley Basin (SUA-442)

Petrotomics (SUA-551)

Plateau Resources (SUA-1371)

Quivera, Ambrosia Lake (SUA-1473)

Rio A!gom, Lisbon (SUA-1119)

Rio Algom, Smith Ranch (SUA-l 1548)- not in LTS Umetco, White Mesa (SUA-1358)

UNC, Church Rock (SUA-1475) e a

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The followog h:enses have T e LTS entnes need to be OPEN*

j listings ir* the LTS, but there are checked to venfy that financial

'no instruments in the safe:.

assurance is required; that instruments have been prov&<1 l

Amencan Nuclear (SUA-667) and we know where the I

Bear Creek (SUA-1319) instruments are (if the instrurcents i

Cogema (SUA-1341) are not in Regional safes, the t

i Crow Butte (SUA-1534) mstruments need to be forwarded i

International Uranium (SUA-1558) to DWM or the Regions for l

Pathfinder (SUA-1540) placemen* in the instrument safe);

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Power Resources (SUA-1511) and the L.'3 entries need to be Umetco (SUA-648) updated as necessary.

U.S. Energy (SUA-1524)

Westem Nuclear (SUA-56)

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