ML20199A717

Forwards Financial Assurance Instrument Security Evaluation Recently Performed by TC Johnson.Evaluation Indicates Number of Items Applicable to Matls Decommissioning Section Projects,Need to Be Corrected

ML20199A717
Person / Time
Issue date:	01/16/1998
From:	Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Bell L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
REF-WM-3 NUDOCS 9801280064
Download: ML20199A717 (3)

Text

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./ January 16, 1998 MEMORANDUM TO: Larry Bell, Section Chief Materials Decommissioning Section Low LevelWaste and Decommissioning Projects Branch Division of Waste Management, NMSS FROM: John W. N. Hickey, Chief [0riginal signed by]

Low-Level Waste and Decommissioning Projects Branch Division of Wasie Management, NMSS

SUBJECT:

FINANCIAL ASSURANCE INSTRUMENT SECURITY EVALUATION l am attaching a copy of the financial assurance instrument security evaluation recently performed by T. C. Johnson (see Attachment 1). The evaluation indicates a number of items applicable to Matedals Decommissioning Ssetion projects that need to be corrected.

Attachment 2 is a table that outlines these items and the needed corrective actions. Please t

provide us with your corrective actions by February 13,1998. L. Bykoski and T. C. Johnson will provide any assistance you need.

Attachments: As stated CONTACT: L. Bykoski, DWM/NMSS l) b 3

(301)415-6754

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T. C. Johnson, DWM/NMSS q pf (

(301) 415 7299 p l(p.i TICKET: N/A W #'

DISTRIByILQB:

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January 16, 1998 MEMORANDUM To: Larry Bell, Section Chief i

Materials Decommissioning Section Low Level Waste and Decommissionir.g Projects Branch Division of Waste Management, NMSS FROM: John W. N. Hickey, Chief, Low Level Waste and (Decommissioning 1/

Projects Branch Division of Waste Management, NMSS

SUBJECT:

FINANCIAL ASSURANCE INSTRUMENT SECURITY EVALUATION I am attaching a copy of the financial assurance instrument security evaluation recently performed by T C. Johnson (see Attachment 1). The evaluation indicates a number of items applicable to Materials Decommissioning Section projects that need to be corrected.

Attachment 2 is a table that outlinem these items and the needed corrective actions. Please

.. provide us with your corrective actions by February 13,1998. L. Bykoski and T. C. Johnson will provide any assistance you need.

Attachments: As stated CONTACT: L. Bykoski, DWM/NMSS (301) 415 6754 T. C, Johnson, DWM/NMSS (301)415 7299

1 i

. i January 16, 1998 MEMORANDUM TO: Larry Bell, Section Chief ,

Materials Decommissioning Section Low. Level Waste and Decommissioning 4 Projects Branch Division of Waste Management, NMSS FROM: John W. N. Hickey, Chief [0riginalsignedby)

Low level Waste and Decommissioning Projects Branch Division of Waste Management, NMSS

SUBJECT:

FINANCIAL ASSURANCE INSTRUMENT SECURITY EVALUATION l am attaching a copy of the financial assu ance instrument security evaluation recently performed by T. C. Johnson (see Attachment 1). The evaluation indicates a number of items applicable to Materials Decommissioning Section projects that need to be corrected.

Attachment 2 is a table that outlines these items and the needed corrective actions. Please '

provide us with your corrective actions by February 13,1998. L. Bykoski and T. C. Johnson will I provide any assistance you need.

Attachments: As stated CONTACT: L. Bykoski, DWM/NMSS (301)415-6754 T, C. Johnson, DWM/NMSS (301)415 7299

-TICKET: N/A

. DISTRIBUTION: Central File LLDP r/f NMSS r/f RJohnson PUBLIC LBykoski RTurtil To receive a copy of this document in small box en "OFC:" line enter: "C" = Copy without attachmentlenclosure: "E" = Copy with attachment / enclosure; *N" = No copy Path & File Name: S:'DWM\LLDP\TCJ\FAAUDLB.

OFC LLDP [ LLQPa m NAME TCJoMbbg h: key DATE 1/llp/98 /

14 //98 OFFICIA'L RECORD COPY

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'% ,/ January 14, 1998 MEMOiANDUM TO. John W N. Hickey, Chief Low Level Waste and Decommissioning Projects Branch Division of Waste Management FROM: Timothy C. Johnson, Section Chief Facilities Decommissioning Sectionw Low Level Waste and Decommissioni Projects Branch

(

Division of Waste Management

SUBJECT:

Fl'lANCIAL ASSURANCE INSTRUMENT SECURITY EVAL UATION in accordance with Management Directive 8.12, Decommissioning Financial Assurance Instrument Security Program," on December 30 and 11,1997, and January 2,1998,1 Jonducted an eveauatlan of the financial assurance ir struments held within the NMSS Headouarters instrument safe. My evaluation was based on the evaluation form attached as Attachment 1. I also checked to verify 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 frem 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 controllist. 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 December 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 Attachment 1 dM.

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Financial Assurance Instrument Evaluation Comments

1. Inventory 1oa Sheets Most entnes under " Signature of Person Removing or Returning instrument and Date" use initials and not signatures, Signatures should be used for these entries Also, many entnes do not have dates. Dates should be included for all entnes.

2. Kgrr McGee. Cimarron Need to remove superseded parent guarantee documents and retum to licensee.

3. Sabcock & Wilcox Need to remove outdated instruments.

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

Inveroory log sheet dates do not matc5 some +stniment dates.

Need to check the BWT standby trust value of $16,832,000.

4. Ramatome Remove outdated instruments.

5. Siemens Was a parent guarantee instrument submitted with the 12 20 96 CFO and auditor's 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 416-97 was not listed correctly on the inventory log.

Need to remove ou' dated 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 .' 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 agreements dated 217 97 and 9-24 97 are not shown on the inventory log.

Need to remove outdated instruments.

Attachment 2

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7. Dow Need to remove outdated instruments

8. Lefferson Provino Ground Remove outdated instruments.

The Statement of Intent is undated. Need to have it dated.

9. fort St Vrain The license was terminated in August 1997. The instruments need to be canceled and returned to the licensee.

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

ii. hiolycoro 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. tia_ rtley & Hartlev. MDNR lt appears that the statement of intent dated 9 5 95 has been superseded. Remove outdated 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  !

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The Westinghouse financial assurance instruments in the safe were not listed on the  !

inventory log. l t

- 20. Rio Afoom. Lisbon U

, 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 i The letter of credit is issued to Sohio Western and not Kennecott. Is this an acceptable  !

l name for the licensee?

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22. Pathfinder. Lucky M: 4 Have the letters of credit issued by the Banque National de Paris been superseded? If so,

! they should be removed from the safe.

i- l 23 ARCO. Blu twater There is oniy a copy of the standby trust. The orijinal should be located, if possible.

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24. Pathfinder. Shirley Basis

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

l 4 25, Quivera r

j lt appears that the parent guarantees cated 3 2191,6 8 95, and 6 26 96 have been -

superseded. If so, they should be removed from the safe.

26. Rio Alaom. Smith Ranch

( Superseded and draft copies of the parent guarantee should be removed from the safe.

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27. Licensino Trackino Systen) ' '

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)

Sohio Western, LBar (SUA 1472)

Kennecott, Sweetwater (SUA 1350)

Pathfinder, Lucky Me (SUA-672)

Pathfinder, Shiriey 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)

UNC, Church Rock (SUA 1475)

BWX (SN .r2001)

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 (2100265 06 STB 527, R 108)

Fansteel(SMB 911)

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

General Electric (vanous licenses)

Hartley & Hartley, MONR 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) n, t 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 been 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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Thd following licenses have listings in the LTS, but there are no instruments in the safe:  ;

Amencan Nuclear (SUA 667) ,

Bear Creek (EUA 1310) i Cogema (SUA 1341)  !

2 Crow Butte (SUA 1534)

International Uranium (SUA 1558) i

- PatMnder (SUA 1540)-

P,..er Resources (SUA 1511)

Umetco (SUA 648)

U.S. Energy (SUA 1524)

Westem Nuclear (SUA 56) ,

Baltimore Gas & Electric (SNM 2505)  ;

Massachusetts institute of Technology (SNM 986) i 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 ib ,

required; that instruments have been provided and we know where the instruments are (if the '

instruments are not in Regional safes, the instr"ments need to be forwarced to DWM or the

Regions f( c placement in the instru. .at safe); and the .TS entries need to b.. updated as i

necessary.

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i Materials Decommisseomna Section Fmanoal Assurarv e Evaluahon Followup item _s 4

' i item Fmdmg Action Needed Disposition Status  !

$ 1. Dow- it appears that there are . Remove superseded items and . OPEN

' superseded instruments in the retum onginals to iscensee safe..-

} Remove superseded items and OPEN a 2; Hartley & Hartley, SCA. It appears  !

that insurance policy documents retum ongenals to licensee. I i dated 3-31-94 and 4-26-94 have j i r

3. Whittalter- The letter of credit Need to ensure that the standby OPEN l' l trust properly references the numberis different from that ,

' stated on Schedule A of the correct letter of credit. i standby trust.

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1 4. The LTS contains outdated - The LTS entnes need to be I information for the folic #.ag updated to reflect the correct , .

licenses: name of the Iscensee; the correct instrument type, issuer, and amount; and whether the ~

j. BP Chemicals (SUB-908)

Dow (21-00265-06, STB-527. R- instrument has been approved and l

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the correct date of approval.

Hartley & Hartley, SCA RMi (SMB-602) i l

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