ML20199A742
| ML20199A742 | |
| Person / Time | |
|---|---|
| Issue date: | 01/16/1998 |
| From: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Nelson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 9801280075 | |
| Download: ML20199A742 (3) | |
Text
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January 16, 1998 e
MEMORANDUM TO: Robert A. Nelson, Section Chief Regulatory Issues Section Low Level Waste 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 Waste Management, NMSS
SUBJECT:
FINANCIAL ASSURANCE INSTRUMENT SECURITY EVALUATION l cm 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 appucable to Regulatory Issues Section projects that need to be corrected. At'achment 2 is a table that outlines these items and the needed corrective actions. Please provide us with you*
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i corrective actions by February 13,1998. L. Bykotki and T. C. Johnson will provide any assistance you need.
Attachments: As stated pi l
CONTACT: L. Bykoski, DWM/NMSS g (301) 415-6754 j T. C. Johnson, DWM/NMSS
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- DISTRIBUTION: Central File /f NMSS r/f RJohnson PUBLIC . LBykoski LLDP r#.
ACN'A Ta receive a copy of this document in small box on "OFC:" line enter: "C" = Copy without attachmentlenclosure; "E" = C';y with attachmentlenclosure;"N" = No copy Path & File Name: S:\DWM\LLDP\TCJ\FAAUDRN CFC LLQ , LL(g() tL l NAME' TC s n/bg Jikkey DATE il 98 1//[/98 '
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- January 16, 1998 .
MEMORANDUM TO: Robert A. Nelson, Section Chief Regulatory issues Section Low LevelWaste and Decommissioning Projects Branch ;
Division of Waste Management, NMSS ,
FROM: John W. N. Hickey, Chief Low-LevelWaste and Dec '
f['issioning 3 Projects Branch Division of Was'e Management. NMSS
SUBJECT:
FINANCIAL ASSURANCE INSTRUMENT SECURITY EVALUATION I am attaching a copy of the financial assurance instrument security avaluation recently performed by T. C. Johnson (see Attachment 1). The evaluation indicates a number of items applicable to Regulatory issues Section projects that need to be corrected. Attachment 2 is a table that outlines thase 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
January 16, 1998 ,
MEMORANDUM TO: Robert A. Nelson, Section Chief '
Regulatory issues Section Low-Level Waste and Decommissioning Projcets Branch Division of Waste Management, NMSS FROM: John W. N. Hickey, Chief [ Original signed by]
Low Level Wasto and Decommissioning Projects Branch Division of Waste Management, NMSS -
SUBJECT:
FINANCIAL ASSURANCE INS rRUMENT SECURITY EVALUATION I am attaching a copy of the financial assurance instrument security evaluation recently performed by T. C. Johnson (see Attachinent 1). The evaluation indicates a number of items applicable to Regulatory lesues Section projects thet need to be corrected. Attachment 2 :s a l table that outlines these items and the needed cc:rective actions. Please provide us with your corrective actions by February 13,1998. L. Byke a.i 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 TlCKET: N/ ANT DISTRIBUTION: Central File LLDP r/f NMSS r/f RJohnson PUBLIC LBykoski ACNW To receive a copy of this document in Small box on "OFC;" line enter: "C" = Copy without attachment / enclosure; "E" = Copy with Cttachment/ enclosure;"N" = No copy Path & Filo Name: S:\DWM\LLDP\TCJ\FAAUDRN OFC LLQ , I LLQ!
NAME TC s n/bt JSckey I
DATE 1/ 98 1//[/98 OFFICIAL RECORD COPY
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- NUCLEAR REEULATORY COMMISSION o f W ASHINGToN. D.C. 20%1W001
\ q,(, January 14, 1998 MEMORANDUM 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 Section Low Level Waste and Decommissioni Projects Branch Division of Waste Management
SUBJECT:
FINANCIAL ASSURANCE INSTRUMENT SECURITY EVALUATION In accordancc with Management Directive 8.12, Decommissioning Financial Assurance Instrument Secunty Program,' on December 30 and 31,1997, and January 2,1998, I conducted an evaluation of the financial assuiance instruments held within the NMSS Headquaders instrument safe. My evaluation was based on the evaluation form attached as Attachment 1. I also checked to venfy that current financial assurance information is in the Licensing Tracking System (LTS).
My findings are prcvided 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 tha* proper dates, instruments, and signatures are identified. Outdated instruments shoulc . 6 'emoved from the safe and returned to the licensee. When new instruments are submitted, th,s information needs to be included not er.ly in the lnventory 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 e.Nated. Not all the LTS update recommendations made in L. Bykoski's December 1996 evaluation arsoear to have been incorporated. While recommendations were forwarded to the appropriate groups, there was ro 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 1
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Financial Assurance Instrument Evaluation Commentt
- 1. Inventory Loa Sheels Most entries under" Signature of Person Removing or Returning Instrument and Date" use initials and not signatures. Signatures should be used for these entries. Also, many entries do not have dates. Dates should be included for all entnes.
- 2. Kerr McGee. Cimarron Need to remove superseded parent guarantse documents and re um to licensee.
- 3. Babcock & Wilcox Need to remove outdated instruments.
The Morgan letter of credit is undated - should this be 12 18-967 l The Scotiabank letter of credit amendment dated 7 28 97 was not on the inventory log.
l Inver"ory log sheet dates do not match some instrument dates.
Need to check the BWT standby trust value of $16,032,000.
- 4. Framatome l- Remove outdated instruments.
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- 5. Siement Was a parent guarantee instrument submitted with the 12 20-96 CFO and auditor's letters?
If so, it should be checked to 03e if it is still valid and whether or not it has t,een superseded.
The standby trust amendment dated 416-97 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 standoy 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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Need to remove outdated instruments. ;
- 8. Jefferson Provino Ground Remove outdated instruments.
The Statement of Intent is unhted. Need to have it dated.
- 9. Fort St. Vr.g.in i
~ The license was terminated in August 1997. The instruments need to be canceled and retumed to the licensee. ;
- 10. Cintichem The standby trust document is not an original. Need to obtain an originalif possible.
- 11. Volycore it appears that the parent guarantee documents dated 8 3194 have been superseded. If so, remove the outdated parent guarantee instrument.
- 12. Hartlev & Hartlev. SCA f it appears that insurance policy documents dated 3-3194 and 4 26 94 have been !
superseded. If so, these documents should be removed. !
- 13. tiartley & Hartlev. MONR lt appears that the statement of intent dated 9-5-95 has been superseded. Remove I 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. Seouovah 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. Wettinohouse The Westinghouse financial assurance instruments in ins safe were not listed on the inventory log.
D. Rio Alaom. 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. LEp(
The letter of credit is issued to Sohio Westem and not Kennecott. Is this an acceptable name for the licensee?
- 22. Pathfinder. Lucky Me Have the letters of credit issued b/the Banque National de Paris been superseded? If so, they should be removed from the cafe.
23- ARCO. Bluewater 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, they should be removed from the safe. ,
25, Quivers 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 Alaom. Smith Ranch Superseded and draft copies of the parent guarantee should be removed from the safe.
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- 27. Licensino Trackina 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)
Sohio Westem, LBar (SUA 1472)
Kennecott, Sweetwater (SUA 1350)
Pathfinder, Lucky Mc (SUA-672)
Pathfinder, Shirley Basin (SUA 442)
Petrotomics (SUA 551) l Plateau Resources (SUA-1371)
Quivera, Ambrosia Lake (SUA 1473)
Rio Algom, Lisbon (SUA 1119) l Rio Algom, Smith Ranch (SUA 1548) not in LTS l Umetco, White Mesa (SUA 1358)
! UNC, Church ' sck (SUA 1475)
BWX (SNid 20vi)
BWX (SNM 42, SNM 414) P 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(SMR 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 abovo 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 tne number of the-letter of credit, bond, etc. These numbers should be removed from the LTS ac the LTG is not a controlled database.
5-The following licenses have listings in the LTS. but there are no instruments in the safe:
American Nuclear (SUA 667)
Bear Creek (SUA 1310)
Cogema (SUA-1341)
Crow Butte (SUA 1534)
Intemational Uranium (SUA 1558)
Pathfinder (SUA 1540)
Power 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)
Pennsylvarla State Univ. (SNM 95)
Purdue Univ. (SNM 142) l The LTS entries for the above licenses need to be checked to v3nfy 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 forwarded to DWM or the Regions f( ' placcment in the instrumerit si fe), and the LTS entries need to be updated as necessary.
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1 Reaulatory issues Section Financial Assurance Evaluation Fo.iow-uo items Action Needed Disposition Status item Cinding Cintichem The standby trust ' Naed to obtain an original, if OPEN 1.'
document is not an original. possible.
- 2. Molycorp: It appears that the Remove the superseded OPEN parent guarantee documents documents and retum originals to cated 8-31-94 have been licensee.
superseded.
- 3. The LTS contains outdated The LTS entries need to be OPEN information for the following updated to reflect the correct licenses: name of the licensee; the correct instrument type, issuer, and Cabot, Reading and Revere ' amount; and whether the -
(SMC-1562) instrument has been approved Cintichem (SNM-639)-not in LTS and the correct date of approval.
Molycorp (SMB-1408)- not in LTS Shield.siloy (SMB-743, SMB-1507)
Attachment 2 :
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