ML20199B834
| ML20199B834 | |
| Person / Time | |
|---|---|
| Issue date: | 01/16/1998 |
| From: | Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Schwink W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 9801290027 | |
| Download: ML20199B834 (3) | |
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January 16, 1998 MEMORANDUM TO: Walter Schwink, Acting Chief
, Licensing Brach Division of Fuel-Cycle Safety and Safeguards, NMSS FROM: John W. N. Hickey, Chief [0riginalsignedby]
Low Level Waste and Decommissioning Projects Branch Divisior, 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 Licensing Branch projects that need to be corrected. Attachment 2 is a table that out:ines 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, DWMINMSS 9fM [
(301)415-7299 TICKET: N/A ,
QlSTRIBUTION: *Ceratal Flie " LLDP r/f NMSS r/f RJohnson PUBLIC LBykoski MWeber To receive a copy of this document in small bor. on "OFC:" line enter: "C" = Cop; without attachment / enclosure; "E" = Copy with tttachment/ enclosure;"N" = No copy P th & Fils Narae: S:\DWM\LLDP\TCJ\FAAUDFC OFC LLDPh LLDP 2f NAME TC% bbg JHickey DATE il /98 il((/98 l l ~
OFFICIAL RECORD COPY
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- January 16, 1998 MEMORANDUM TO: Walter Schwink, Acting Chief Licensing Brane'.
Division of Fuel-Cycle Safety and Safeguards, NMSS -- /, 7 FRCM: John W. N. Hickey, Chief G/
N /// $M Low Level Waste and Decommissioning 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 Licensing Branch 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 13,1938. L. Bykoski and T. C. Johnson will provide any assistance you need.
Attachments: As stated CONTACT: L. Bykosxi, DWM/NMSS (301)4154 754 T. C. Johnson, DWM/NMSS (301)415-7299 1
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l January 16, 1998 MEMORANDUM TO: Walter Schwink, Acting Chief '
Licensing Branch Division of Fuel-Cycle Safety and Safeguards, 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 am attaching a cepy of the financial assurance instrument security ovaluation recently performed by T. C. Johnson (see Attachment 1). The evaluation indicates a number of items applicable to Licensing Branch 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 13,1FR L. Bykoski and T. C. Johnson will provide any assistance you need.
Attachmentn: As stated CONTACT: L. By e aski, DWM/NMSS (301; 415-6754 T. C. Johnson, DWM/NMSS (301) 415-7299 TICKET: N/A
' DISTRIBUTION: Central Fi'e LLDP r/f NMSS r/f RJohnson PUBLIC LBykoski MWeber To receive a copy of this document in small box on "OFC:" line enter: "C" = Copy without attachmentlenclosure; "E" = Copy wiU1 f ttachmentlenclosure;"N" = No copy Path & File Name: S:\DWM\LLDP\TCJ\FAAUDFC OFC LLDPh LLDP 2)
Jy ' TCgh/bg JHickey DATE 1/h/98 1/ /d98 l l OFFICIAL RECORD COPY I
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NUCLEAR REGULATOI!Y COMMISSION W AsMiNQtoN. o C 20h0001
% ,',,,, Janua ry 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 Facihties 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 Instrumen Securt Proyan ' cr. Decemt 3r 0 and N 1997, cnd January 2.1998, I conducted an evaluation of the financial assur
- ie instruments held within the NMSS Heaoquarters 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 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 imnlemented. 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 appropnate 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, DWMINMSS (301)415-7299 Attachment 1 h % O i i 1 C l 7--Tr--
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t Financial Assurance instrument Evaluation Comments
- 1. Inventory Loa Sheets Most entnes under" Signature of Person Removing or Retuming inst'rument and Date" use initials and not signatures. Signatures should be used for these entnes. Also, many entries do not have dates, Dates should be included for all entnes.
- 2. KerrWeGee. Cimarron Need to remove superseded parent guarantee documents and retum to licensee.
- 3. Babcock & Wilcox Need to remove outdated instruments.
The Morgan letter of credit is undated - should this be 12-18-96?
The Scotiabank letter of credit amendment dated 7-28-97 was not on the inventory log.
Inventory .ag sheet dates do not match somt ;strument 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 an zor's letters?
If so, it should be checked to see if it is still valid and whether or not it has b n 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 venfy 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. Neco te determine which of these standby trusts are valid and which trust the amendment applies to.
- 6. NFS The escrow agreements dated 2-17-97 arid 9-24-97 are not shown on the inventory Iog.
Need to remove outdated instruments.
Attachment 2
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Need to remove outdated instruments.
- 8. Jefferson Provina Groyrid Remove outdated instruments.
The Statement of Intent is undated. Need to ha"e 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 The standby trust document is not an onginal. Neeo to obtain an onginalif possible.
- 11. Molvuaro 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 3154 and 4-26-94 have been superseded. if so, these documents should be removed.
- 13. Hartley & Hartley. MONR 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. Se_quoyah Fuels There are two escrow agreements in the safe. Has one been superseded? If so, please remove the superseded instrument.
16, General Electnc Need to remove superseded self-guarantee documents.
e 3-19 Westinahouse The Westinghouse financial assurance instruments in the sole were.not listed on the inventory log.
- 20. Rio Atoom. Lisbon Have the parent guarantees dated 3-2191,6-25-92, and 6-8-95 been superseded? If so, they shou:d be removed from the safe.
- 21. Kennecott. LBar The letter of credit is issued to Sohio Western and nr.,t Kennecott. Is this an acceptable name for the licensee?
- 22. Pathfinder. Lucky Mc Have the letters of credit issued by the Banque National de Pans been superseded? If so, they thould be removed from the saf-23 ARCO. Bluewater There is only a copy of the standby trust The onginal should be located, if possible.
- 24. Pathfinder. Shirtev Basis Have the letters of credit issued by the Banque National de Paris been superseded? If so, a 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 Alaom. STiith 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 heenses:
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 Mc (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 hock (SUA 1475)
BWX (SNM 2001)
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 Electnc (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)- 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 been approved and the correct date of approvct. Some of the uranium milllicense entries have the number of the letter of credit, bond, etc. These r, umbers should be removed from the LTS as the LTS is not a controlled database.
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The fpilowing licenses have listings in the LTS, bu ere are no instruments in the safe:
Amencan Nuclear (SUA-667)
Bear Creek (SUA 1310)
Cogema (SUA-1341)
Crow Butte (SUA-1534)
International 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)
Pennsylvania Stcte Univ. (SNM 95)
Purdue Univ. (SNM 142)
The LTS entnes for the above licenses neJd 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 instrume ts need to be forwarced to DWM or the Regions for placement in the instrument safe); and the LTS entries need to be updated as necessary.
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Licensina Branch Financial Assurance Evaluation Followup items Action Needed Disposition l Status Item Finding Remove superseded items and OPEN
- 1. B W X: There appear to be several superseded documents in the return onginals to licensee; have safe; the Morgan letter of credit is the Morgan letter of credit dated.
undated- the standby trust value is venfy the correct amount on the stated as $16,832,000, but may standby trust.
not be current.
Remove superseded items and OPEN
- 2. Framatome. There appear to be several superseded documents in retum onginals to licensee.
the safe.
The 12-20-96 package should be OPEN
- 3. Siemens: 11is unknown if a parent guarantee instrument was checked to see if a parent submitted with the 12-20-96 CFO guarantee was submitted, if it is and auditor's letters; still valid, and whether or not it has been superseded; There appear to be superseded Remove superseded items and documents in the safe; retum originals to licensee; Th inventory log shows Parent Need to venfy what Amendrnant 1 Guarantee Amendment No.1; is; In the safe are standby trusts from Need to determine which of these Wachovia Bank and First Citizens standby trusts ara valid and whit. i
' Bank and a standby trust trust the amendment applies to.
l amendment from Bank of New York; it appears that some may have been superseded.
Attachment 2
2 Remove superseded items and OPEN
- 4. NFS: There appear to be superseded instruments in the return originals to licensee.
safe.
OPEN The LTS contains outdated The LTS entries need to be 5.
information for the following updated to reflect the correct name of the licensee; the correct licenses:
instrument type, issuer, and amount; and whether the BWX (S JM-42. SNM-414) instrument has been approved and Fansteil (SMB-9. ') the correct date of approval.
General Atomics (SNM-696, R-67, R-38)
General Electric (various licenses)
McDermott Technologies (SUB-1259, BPM-34-03043-03)- not in LTS '
Nuclear Fuel Services (SNM-124)
Shieldalloy (SMB-743)
Siemens (SNM-1227)
Department of Commerce, NIST (SNM-362)
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3 The LTS entries need to be OPEN
- 6. The following licenses have listings in the LTS, but there are checked to verify that financial -
no instruments in the safe: assurance is required; that instruments have been provided snd we know where the j Baltimore Gas & Electric (SNM-2505). instruments are (if the instruments Massachusetts institute of are not in Regional safes, the Technology (SNM-986) instruments need to be forwarded Pennsylvania State Univ. (SNM- to DWM or the Regions for
- 95) placement in the instrument safe);
Purdue Univ. (SNM-142) and the LTS entries need to be updated as necessary.
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