ML22153A471
| ML22153A471 | |
| Person / Time | |
|---|---|
| Site: | 15000035 |
| Issue date: | 06/14/2022 |
| From: | Scott(Ois) Morris Region 4 Administrator |
| To: | Busby S Advanced Inspection Technologies |
| Kramer J | |
| References | |
| 4-2021-005, EA-21-129, NUREG/BR-0254, OI 4-2021-005 IR 2020002 | |
| Download: ML22153A471 (14) | |
See also: IR 015000035/2020002
Text
June 14, 2022
Ms. Sharon Busby, President
Advanced Inspection Technologies, Inc.
3820 Charles Page Blvd.
Tulsa, OK 74127
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL
PENALTY - $8,000 AND EXERCISE OF ENFORCEMENT DISCRETION,
NRC INSPECTION REPORT 150-00035/2020-002 AND INVESTIGATION
REPORT 4-2021-005
Dear Ms. Busby:
This letter refers to the investigation completed on August 30, 2021, by the U.S. Nuclear
Regulatory Commission (NRC) Office of Investigations at Advanced Inspection Technologies,
Inc., (AIT or licensee) in Tulsa, Oklahoma. The investigation was conducted to determine
whether licensee employees willfully conducted licensed activities in NRC jurisdiction without
filing for reciprocity. The NRCs investigation results were discussed with you during a telephone
conversation on February 2, 2022. A factual summary of the investigation was issued as an
enclosure to our letter dated February 15, 2022, Agencywide Documents Access and
Management System (ADAMS) Accession No. ML22040A362.
In the February 15, 2022, letter transmitting the inspection report, we informed you that two
apparent violations were being considered for escalated enforcement action. In the letter, we
provided you the opportunity to address the apparent violations identified in the report by either
attending a predecisional enforcement conference, engaging the NRC in alternative dispute
resolution mediation, or by providing a written response before we made our final enforcement
decision. In a letter dated March 8, 2022, ADAMS Accession No. ML22112A253, you provided
your response to the apparent violations.
Based on the information developed during the investigation, the in-office review by the
inspection staff, and the information that you provided in your written response to the inspection
report, the NRC has determined that two violations of NRC requirements occurred. These
violations are cited in Enclosure 1, Notice of Violation and Proposed Imposition of Civil Penalty
(Notice), and the circumstances surrounding them are described in detail in the subject
inspection report. The violations involved the failure to: (A) file a submittal containing an NRC
Form 241, Report of Proposed Activities in Non-Agreement States, a copy of your Agreement
State specific license, and the appropriate fee with the Regional Administrator of the appropriate
NRC regional office at least 3 days before engaging in activity in a Non-Agreement State; and
(B) ensure that information provided to the Commission by a licensee is complete and accurate
in all material respects.
S. Busby
2
The NRC considers Violation A to be a significant violation because your deliberate failure to file
a submittal containing an NRC Form 241 and conduct of licensed activities in a Non-Agreement
State prevents the NRC from inspecting these areas to ensure that licensed material is being
used safely and in accordance with NRC requirements. Therefore, Violation A has been
categorized in accordance with the NRC Enforcement Policy at Severity Level III. The current
Enforcement Policy is included on the NRCs website at http://www.nrc.gov/about-nrc/
regulatory/enforcement/enforce-pol.html.
The NRC considers Violation B to be of low safety significance and thus has categorized it in
accordance with the NRC Enforcement Policy as a Severity Level IV violation. This violation is
being formally cited as Severity Level IV rather than as a non-cited violation because it was
identified by the NRC.
In accordance with the NRC Enforcement Policy, a base civil penalty in the amount of $16,000
is considered for Severity Level III Violation A.
Because your facility is the subject of a willful escalated enforcement action, the NRC
considered whether credit was warranted for Identification and Corrective Action in accordance
with the civil penalty assessment process in Section 2.3.4 of the NRC Enforcement Policy. The
NRC has determined that Identification credit is not warranted because the NRC staff identified
the violation. The NRC determined that Corrective Action credit is warranted based on your
prompt corrective action to submit an NRC Form 241 after the NRC staff identified the
non-compliance with the NRC regulation and your comprehensive corrective action to not
perform licensed activities outside the state of Oklahoma as you committed to in your letter
dated March 8, 2022. As a reminder, there are areas of exclusive Federal jurisdiction within the
state of Oklahoma on military installations and tribal lands that would require submission of an
Normally for a willful Severity Level III violation, without credit for Identification, the NRC would
assess a base civil penalty in the amount of $16,000. However, NRC considered the
information that you provided regarding AITs financial hardship. Therefore, in consultation with
the Director, Office of Enforcement, I have been authorized to exercise enforcement discretion,
in accordance with Section 3.6 of the NRC Enforcement Policy, and issue the enclosed Notice
of Violation and Proposed Imposition of Civil Penalty in the amount of $8,000 for Severity
Level III Violation A.
You may choose to pay the proposed civil penalty by submitting your payment with the invoice
enclosed to this letter (Enclosure 2), to the following address:
Office of the Chief Financial Officer
U.S. Nuclear Regulatory Commission
P.O. Box 979051
St. Louis, MO 63197
In addition, you may pay the proposed civil penalty in accordance with NUREG/BR-0254
Payment Methods, Enclosure 3 or ADAMS Accession No. ML19163A244. When using
NUREG/BR-0254 to pay the civil penalty, the bill number, EA-21-129, should be used as the
enforcement action identifier when submitting your payment through one of the approved
methods listed in the brochure. The NRC may consider a request for additional time to pay the
proposed civil penalty, including the option to enter into an installment agreement, if payment of
the civil penalty as a lump sum in the required timeframe would pose a financial hardship. To
S. Busby
3
request additional time to pay, you must submit a written request, with appropriate justification
explaining your financial hardship, to NRCCollections.Resource@nrc.gov. All requests should
be submitted in sufficient time to allow the NRC the ability to review your request for additional
time to pay before the 30-day payment period expires.
If you disagree with this enforcement sanction, you may deny the violations, as described in the
Notice, or you may request alternative dispute resolution (ADR) mediation with the NRC to
resolve this issue. Alternative dispute resolution is a general term encompassing various
techniques for resolving conflicts using a neutral third party. The technique that the NRC has
decided to employ is mediation. Mediation is a voluntary, informal process in which a neutral
mediator works with parties to help them reach resolution. If the parties agree to use ADR, they
select a mutually agreeable neutral mediator who has no stake in the outcome and no power to
make decisions. Mediation gives parties an opportunity to discuss issues, clear up
misunderstandings, be creative, find areas of agreement, and reach a final resolution of the
issues. Additional information concerning the NRCs ADR program can be found at
http://www.nrc.gov/about-nrc/regulatory/enforcement/adr.html.
The Institute on Conflict Resolution at Cornell University has agreed to facilitate the NRCs ADR
program as a neutral third party. If you are interested in pursuing this issue through the ADR
program, please contact: (1) the Institute on Conflict Resolution at 877-733-9415; and
(2) Mr. Neil OKeefe at 817-200-1156 within 10 days of the date of this letter. Your submitted
signed agreement to mediate using the NRC ADR program will stay the 30-day period for
payment of the civil penalties, as identified in the enclosed Notice, until the ADR process is
completed.
The NRC has concluded that information regarding: (1) the reason for the violations; (2) the
corrective steps that have been taken and the results achieved; and (3) the date when full
compliance was achieved is already adequately addressed on the docket in this letter and in
your letter dated March 8, 2022. Therefore, you are not required to respond to this letter unless
the description therein does not accurately reflect your corrective actions or your position. In that
case, or if you choose to provide additional information, you should follow the instructions
specified in the enclosed Notice.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice and Procedure, a copy of
this letter, its enclosures, and your response, if you choose to provide one, will be made
available electronically for public inspection in the NRC Public Document Room and from the
NRCs ADAMS, accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html.
To the extent possible, your response should not include any personal privacy or proprietary
information so that it can be made available to the public without redaction. The NRC also
includes significant enforcement actions on its website at http://www.nrc.gov/reading-rm/doc-
collections/enforcement/actions.
S. Busby
4
If you have any questions concerning this matter, please contact Mr. Neil OKeefe of my staff,
at 817-200-1156.
Sincerely,
Scott A. Morris
Regional Administrator
Docket No. 150-00035
License No. General License
pursuant to 10 CFR 150.20
Enclosures:
1.
Notice of Violation and Proposed
Imposition of Civil Penalty
2.
Civil Penalty Invoice
3.
NUREG/BR-0254 Payment Methods
cc w/ enclosures:
Michael Broderick
Environmental Program Manager II
Oklahoma Environmental Agency
Signed by Morris, Scott
on 06/14/22
SUNSI Review
By: JGK
Yes No
Publicly Available
Non-Publicly Available
Non-Sensitive
Sensitive
Keyword:
OFFICE
ES:ACES
C:MLB
TL:ACES
RC
NAME
JKramer
NOKeefe
JGroom
DCylkowski
MBurgess
JPerelta
SIGNATURE
/RA/ E
/RA/ E
/RA/ E
/RA/ E
/RA/ E
/RA/ E
DATE
04/11/22
04/13/22
04/22/22
04/14/22
05/23/22
05/25/22
OFFICE
D:DNMS
NAME
RAugustus
MMuessle
SMorris
SIGNATURE
/NLO/ E
/RA/ E
/RA/ E
DATE
06/01/22
06/13/22
06/14/22
Enclosure 1
AND
PROPOSED IMPOSITION OF CIVIL PENALTY
Advanced Inspection Technologies, Inc.
Docket No. 150-00035
Tulsa, Oklahoma
License No. General License
During an NRC investigation conducted from November 12, 2020, to August 30, 2021, two
violations of NRC requirements were identified. In accordance with the NRC Enforcement
Policy, the NRC proposes to impose a civil penalty pursuant to Section 234 of the Atomic
Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular
violations and associated civil penalty are set forth below:
I.
Violation Assessed a Civil Penalty
A. 10 CFR 150.20(a)(1) states, in part, that any person who holds a specific license from
an Agreement State is granted a general license to conduct the same activity in
Non-Agreement States subject to the provisions of 10 CFR 150.20(b).
10 CFR 150.20(b)(1) requires, in part, that any person engaging in activities in a
Non-Agreement State shall, at least 3 days before engaging in each activity for the first
time in a calendar year, file a submittal containing an NRC Form 241, Report of
Proposed Activities in Non-Agreement States, a copy of its Agreement State specific
license, and the appropriate fee with the Regional Administrator of the appropriate NRC
regional office.
Contrary to the above, between April 1 and October 12, 2020, Advanced Inspection
Technologies, Inc., a licensee of the state of Oklahoma, engaged in licensed activities in
a Non-Agreement State without filing a submittal containing an NRC Form 241, a copy of
its Agreement State specific license, and the appropriate fee with the Regional
Administrator of the appropriate NRC regional office at least 3 days before engaging in
each activity. Specifically, Advanced Inspection Technologies Inc., performed
radiography for 20 days (April 1; June 4; July 12, 14, 17, 23, 29; August 5, 12, 16, 20,
27; September 2, 9, 14, 16, 23; and October 1, 10, 12, 2020) in Joplin, Missouri, but did
not request reciprocity until October 14, 2020. Since the work was performed in a
Non-Agreement State beginning on April 1, 2020, Advanced Inspection Technologies,
Inc., was required to provide this information to the NRC by March 29, 2020.
This is a Severity Level III violation (Enforcement Policy Section 6.9.c.2). Civil Penalty -
$8,000. EA-21-129
II.
Violation Not Assessed a Civil Penalty
B. 10 CFR 30.9(a) requires, in part, that information provided to the Commission by a
licensee shall be complete and accurate in all material respects.
Contrary to the above, on October 14, 2020, Advanced Inspection Technologies, Inc., a
licensee of the state of Oklahoma, provided information to the Commission that was not
complete and accurate in all material respects. Specifically, Advanced Inspection
Technologies, Inc. submitted an NRC Form 241 that failed to include 14 dates
2
(April 1; June 4; July 12, 14, 17, 23, 29; August 5, 12, 16, 20, 27; and September 2, 9,
2020) on which the company had already performed radiography in Joplin, Missouri.
This information is material to the NRC because it is used to determine inspections of
the licensees radiography performed in a Non-Agreement State.
This is a Severity Level IV violation (Enforcement Policy Section 6.9.d).
The NRC has concluded that information regarding: (1) the reason for the violations; (2) the
corrective actions taken and planned to correct the violations and prevent recurrence; and
(3) the date when full compliance was achieved is already adequately addressed on the docket
in this letter and in your letter dated March 8, 2022.
However, if the description therein does not accurately reflect your position or your corrective
actions, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201
within 30 days of the date of the letter transmitting this Notice of Violation and Proposed
Imposition of Civil Penalty (Notice). In that case, or if you choose to respond, clearly mark your
response as a Reply to a Notice of Violation, EA-21-129, and send it to the Director, Office of
Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North, 11555 Rockville
Pike, Rockville, MD 20852-2738, with a copy to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, DC 20555-0001, and a copy to the Regional
Administrator, U.S. Nuclear Regulatory Commission, Region IV, 1600 East Lamar Blvd.,
Arlington, Texas 76011-4511, and email it to R4Enforcement@nrc.gov.
You may pay the civil penalty proposed above through one of the following two methods:
1.
Submit the payment with the enclosed invoice for Civil Penalty EA-21-129, issued to
Advanced Inspection Technologies, Inc., to the following address:
Office of the Chief Financial Officer
U.S. Nuclear Regulatory Commission
P.O. Box 979051
St. Louis, MO 63197
2.
Submit the payment in accordance with NUREG/BR-0254.
You may protest the imposition of the civil penalty in whole or in part, by a written answer
addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within
30 days of the date of this Notice. Should you elect to file an answer in accordance with
10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly
marked as an Answer to a Notice of Violation, EA-21-129, and may: (1) deny the violation(s)
listed in this Notice, in whole or in part; (2) demonstrate extenuating circumstances; (3) show
error in this Notice; or (4) show other reasons why the penalty should not be imposed. In
addition to protesting the civil penalty in whole or in part, such answer may request remission or
mitigation of the penalty. Should you fail to answer or pay the civil penalty within 30 days of the
date of this Notice, the NRC may issue an order imposing the civil penalty.
In requesting mitigation of the proposed penalty, the response should address the factors
addressed in Section 2.3.4 of the Enforcement Policy. Any written answer addressing these
factors pursuant to 10 CFR 2.205 should be set forth separately from the statement or
3
explanation provided pursuant to 10 CFR 2.201 but may incorporate parts of the 10 CFR 2.201
reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The
attention of the licensee is directed to the other provisions of 10 CFR 2.205 regarding the
procedure for imposing a civil penalty.
Upon failure to pay any civil penalty which subsequently has been determined in accordance
with the applicable provisions of 10 CFR 2.205 to be due, this matter may be referred to the
Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be
collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c.
The responses noted above, i.e., Reply to a Notice of Violation, EA-21-129 and Answer to a
Notice of Violation, EA-21-129, should be addressed to: Director, Office of Enforcement,
U.S. Nuclear Regulatory Commission, One White Flint North, 11555 Rockville Pike, Rockville,
MD 20852-2738, with a copy to the U.S. Nuclear Regulatory Commission, ATTN: Document
Control Desk, Washington, DC 20555-0001, and a copy to the Regional Administrator,
U.S. Nuclear Regulatory Commission, Region IV, 1600 East Lamar Blvd., Arlington, Texas
76011-4511, and email it to R4Enforcement@nrc.gov.
If you choose to respond, your response will be made available electronically for public
inspection in the NRC Public Document Room or in the NRCs Agencywide Documents Access
and Management System (ADAMS), accessible from the NRC website at
http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, the response
should not include any personal privacy or proprietary information so that it can be made
available to the public without redaction.
If personal privacy or proprietary information is necessary to provide an acceptable response,
then please provide a bracketed copy of your response that identifies the information that
should be protected and a redacted copy of your response that deletes such information. If you
request that such material is withheld from public disclosure, you must specifically identify the
portions of your response that you seek to have withheld and provide in detail the bases for your
claim (e.g., explain why the disclosure of information will create an unwarranted invasion of
personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for
withholding confidential commercial or financial information).
In accordance with 10 CFR 19.11, you are required to post this Notice within 2 working days of
receipt.
Dated this 14th day of June 2022
Enclosure 2
Civil Penalty Invoice
Page 1 of 2
06/14/2022
Address/Customer Information
Advanced Inspection Technologies, Inc.
3820 Charles Page Blvd
Tulsa, OK 74127
Customer Codes
Account Code:
L000003709/1
Bill Information
Bill Number:
Amount Due:
$8,000.00
Due Date:
07/14/2022
Contact Us
Phone Number:
301-415-7554
Fax Number:
301-415-4135
Email Address:
Fees.Resource@nrc.gov
Remit to Address
Office of the Chief Financial Officer
U.S. Nuclear Regulatory Commission
P.O. Box 979051
St. Louis, MO 63197
Bill Summary
Initial Charges
$8,000.00
Discount
0.00
Surcharge
0.00
Interest Charges
0.00
Penalty Charges
0.00
Admin Charges
0.00
Bill Amount
$8,000.00
Collected
0.00
Applied Credit
0.00
Adjustments
0.00
Amount Due
$8,000.00
Credit Summary
Applied Credit
$0.00
Unapplied Credit
0.00
Credit Total
$0.00
Comments:
For questions, contact the NRC Financial Services and Operations Branch at (301) 415-7554 or by email at Fees.Resource@nrc.gov. For NRC debt collection
procedures, including interest and penalty provisions, see 31 U.S.C. 3717, 4 CFR 101-105 and 10 CFR 15. If this invoice is related to an Order Imposing a Civil
Penalty, Advanced Inspection Technologies, Inc. is required to pay the Civil Penalty within 30 days of the Order date. If payment is in response to a Notice of
Violation and Proposed Imposition of a Civil Penalty, please follow the instructions in the Notice. The NRC may consider a request for additional time to pay the Civil
Penalty, including the option to enter into an installment agreement, if appropriate. All requests for additional time to pay an invoice must be submitted in writing, with
appropriate justification, to NRCCollections.Resource@nrc.gov, and should be submitted sufficiently ahead of time to allow the NRC time to review the request for
additional time to pay within the 30-day payment period. This Invoice is related to the Civil Penalty proposed or imposed under EA-21-129, issued to Advanced
Inspection Technologies, Inc. Please include this reference number on your payment method (see attached Payments Methods Brochure)
Page 2 of 2
Customer Information
L000003709/1
Advanced Inspection Technologies, Inc.
3820 Charles Page Blvd
Tulsa, OK 74127
Change of Address:
Phone:
Remittance Information
Office of the Chief Financial Officer
U.S. Nuclear Regulatory Commission
P.O. Box 979051
St. Louis, MO 63197
This Payment References the following Bill:
Outstanding Amount Due:
$8,000.00
Amount Enclosed:
Enclosure 3
Payment Methods
QUESTIONS?
If you have questions, please visit https://www.nrc.gov and search
for License Fees.
Questions may also be directed to the NRC Accounts Receivable
Help Desk by e-mail at nrc@fiscal.treasury.gov, by phone at
(301) 415-7554, or by writing to the address below:
U.S. NUCLEAR REGULATORY COMMISSION
OCFO/DOC/ARB
Mail Stop T9-E10
Washington, DC 20555-0001
U.S. NUCLEAR REGULATORY COMMISSION
OCFO/DOC/ARB
Mail Stop T-9-E10
Washington, DC 20555-0001
PH (301) 415-7554
NUREG/BR-0254, Rev. 9
June 2019
APPROVED BY OMB: NO. 3150-0190
Estimated burden per response to comply with this voluntary collection
request: 10 minutes. This brochure provides information about
available payment methods. Forward comments about to burden
estimate to the Records Management Branch (T6-F33), U.S. Nuclear
Regulatory Commission, Washington, DC 20555-0001, and to the
Paperwork Reduction Project (3150-0190), Office of Management
and Budget, Washington, DC 20503. If a means used to impose an
information collection does not display a currently valid OMB control
number, the NRC may not conduct or sponsor, and a person is not
required to respond to, the information collection.
NRC accepts the methods described below.
PAYMENT BY AUTOMATED
CLEARINGHOUSE
To pay by Automated Clearinghouse/Electronic Data Interchange (ACH/
EDI), provide a copy of NRC Form 628 to your financial institution.
You may obtain a copy of NRC Form 628 from the NRC Web site at
http://www.nrc.gov by searching for NRC Form 628. You can also
obtain a form by calling the NRC Accounts Receivable Help Desk at
(301) 415-7554.
PAYMENT BY CREDIT CARD
The NRC is currently accepts credit card payments of up to
$24,999.99. For payment by credit card, go to Pay.gov, search for
,U.S. Nuclear Regulatory Commission Fees and enter the required
information.
You may also mail or fax NRC
Form 629 following the directions on
the form. To obtain a copy of NRC
Form 629 go to http://www.nrc.gov
and search for NRC Form 629 or call
the NRC Accounts Receivable Help
Desk at (301) 415-7554.
PAYMENT BY FEDWIRE DEPOSIT
SYSTEM
The NRC can receive funds through the U.S. Department of the
Treasury (Treasury) Fedwire Deposit System. The basic wire message
format below complies with the Federal Reserve Boards standard
structured third-party format for all electronic funds transfer (EFT)
messages.
The optimum format for fields 7, 8, 9, and 10 using an 8-digit ALC is as
follows:
TREAS NYC/CTR/BNF=/AC-31000001 OBI=
The optimum format, shown above, will allow 219 character positions of
information following the OBI= indicator.
If the licensees bank is not a member of the Federal Reserve System, the
nonmember bank must transfer the necessary information and funds to
a member bank, which then must transfer the information and funds to
the local Federal Reserve Bank.
For a transfer of funds from local Federal Reserve Banks to be recorded
on the same day, the transfer must be received at the New York Federal
Reserve Bank by 4 p.m., EST. Otherwise, the deposit will be recorded on
the next workday.
PAYMENT BY CHECK
Checks should be made payable to the U.S. Nuclear Regulatory
Commission with the invoice number, Enforcement Action number,
or other information that identifies the payment, written on the check.
Mail the check to the following address:
U.S. Nuclear Regulatory Commission
U.S. Bank
P.O. Box 979051
St. Louis, MO 63197-9000
FedEx or overnight mailings must be delivered to the following address:
U.S. Nuclear Regulatory Commission
U.S. Bank Government Lockbox
SL-MO-C2GL
1005 Convention Plaza
St. Louis, MO 63101
TAXPAYER IDENTIFICATION
NUMBER
You must file your Taxpayer Identification Number (TIN) with the NRC.
Use NRC Form 531 to provide your TIN. You may obtain NRC
Form 531 from the NRC Web site at http://www.nrc.gov by searching
for NRC Form 531 or by calling the NRC Accounts Receivable Help
Desk at (301) 415-7554.
See the sample EFT message to Treasury below. Each numbered field is
described below.
RECEIVER-DFI# - Treasurys ABA number for deposit messages is
021030004.
TYPE-SUBTYPE-CD - The sending bank will provide the type and subtype
code.
SENDER-DFI# - The sending bank will provide this number.
SENDER-REF# - The sending bank will insert this 16-character reference
number at its discretion.
AMOUNT - The transfer amount must be punctuated with commas and
decimal point; use of the $ is optional. The depositor will provide this
item.
SENDER-DFI-NAME - The Federal Reserve Bank will automatically insert
this information.
RECEIVER-DFI-NAME - Treasurys name for deposit messages is TREAS
NYC. The sending bank will enter this name.
PRODUCT CODE - A product code of CTR for customer transfer should
be the first item in the reciever text field. Other values may be entered, if
appropriate, using the ABAs options. A slash must be entered after the
product code.
AGENCY LOCATION CODE (ALC) - THIS ITEM IS OF CRITICAL
IMPORTANCE. IT MUST APPEAR ON THE FUNDS TRANSFER DEPOSIT
MESSAGE IN THE PRECISE MANNER AS STATED TO ALLOW FOR THE
AUTOMATED PROCESSING AND CLASSIFICATION OF THE FUNDS
TRANSFER MESSAGE TO THE AGENCY LOCATION CODE OF THE
APPROPRIATE AGENCY. The ALC identification sequence can, if necessary,
begin on one line and end on the next line; however, the field tag BNF=
must be on one line and cannot contain any spaces. The NRCs 8-digit ALC
is: BNF=/AC-31000001
THIRD-PARTY INFORMATION - The Originator to Beneficiary Information
(OBI) field tag OBI= signifies the beginning of the free-form third-party text.
All other identifying information intended to enable the NRC to identify the
depositfor example, NRC annual fee invoice number, description of fee,
10 CFR 171 annual fee, and licensee nameshould be placed in this field.