ML23058A285

Part 1 - Transmittal Letter Dated 2/23/23 from Russell Neely (Edlow International) to Rick Boyle (Dot), Responses of Request for Supplemental Information from NRC on Completeness of the Application for the Model No. JRF-90Y-950K (J/2043/B(U

ML23058A285
Person / Time
Site:	07103036
Issue date:	02/23/2023
From:	Neely R Edlow International Co
To:	Boyle R Storage and Transportation Licensing Branch
Shared Package
ML23058A255	List: ML23058A279 ML23058A281 ML23058A283 ML23058A284 ML23058A285 ML23058A286 ML23058A287 ML23059A252 ML23059A254 ML23061A185 ML23061A186
References
CAC 001794, EPID L-2023-DOT-0000
Download: ML23058A285 (5)

Text

Edlow International Company 1666 Connecticut Ave., N.W., Suite 201 Washington, D.C. 20009 U.S.A.

Tel (202) 483-4959 Fax (202) 483-4840 February 23, 2023 Mr. Rick Boyle U.S. Department of Transportation, PHMSA 1200 New Jersey Avenue, S.E.

Washington, D.C. 20590-0001

Subject:

Request for Revalidation of Japanese Certificate of Competent Authority No.

J/2043/ B (U) F, Model No. JRF-90Y-950K, Dated July 29, 2022 - Responses to Clarification Questions from US DOT and US NRC

Dear Mr. Boyle:

We have worked with our Japanese client and have the following responses to the questions raised with respect to the JRF Package:

For the JRF Package:

(1) Provide the date in which the applicant has a shipment scheduled using this package or the date in which a revalidation recommendation for the JRF package is needed. This information will be helpful for planning and managing staffs workload.

Response: After consultation with the impacted federal entities, the need date for the revalidation of the JRF Package has been adjusted to June 15, 2023.

(2) Provide an affidavit listing the documents and enclosures that are considered proprietary by the applicant. The affidavit only mentions one document considered as proprietary (i.e., Enclosure 1, North American Version of the Safety Analysis for JRF), which does not seem to be accurate, since the submittal to DOT includes 7 documents in English (without counting DOTs cover letter) and more than one document may be considered proprietary by the applicant.

Response: A revised affidavit has been provided by the Japanese (No. 5 An affidavit on the Proprietary Documents (JRF) R1, dated February 20, 2023). In addition, 1

each uploaded document in the Application has been identified as either Proprietary or Non-proprietary consistent with the Affidavit.

(3) Clarify if documents Nos. 4 and No. 6 are considered proprietary by the applicant. If this is the case, submit an affidavit stating the documents submitted to DOT as part of the application for the JFR-90Y-950K package that are considered proprietary.

If document No. 6 is considered proprietary by the applicant, provide an affidavit including the document and send a public version of the document. Document No. 6 is not included in the affidavit provided with the application for the JFR-90Y-950K package. It is not clear if the entire document or portions of it may be considered proprietary by the applicant.

Also, NRC usually, when possible, ask for a public version of an application and related to documents to keep the public informed about the licensing actions submitted for review.

Response: Yes, correct, those documents are considered Proprietary. This is now corrected in the revised Affidavit No. 5 being submitted with this letter. Please note that the identifying file number on these documents has changed:

• Document No. 4 is now Document No. 2 (Proprietary English version of SAR for JRF-90Y-950K). A public version of this document has been prepared (No. 2-1 Non-proprietary English version of SAR for JRF-90Y-950K).

• Document No. 6 is now Document No. 4 (Proprietary Comparison Table of SAR for Type JRF-90Y-950K). A public version of this document has been prepared (No. 4-1 Non-proprietary version of Comparison Table of SAR for Type JRF-90Y-950K).

All submitted documents with the Application are now clearly marked Proprietary and Non-proprietary to comply with the NRC requirement for public versions of documents.

(4) Provide documents submitted as part of the application must be fully translated to English. The following are some examples of text that need to be translated:

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Revision Comparison Table for the Type JRF-90Y-950K SAR, Figures in section D.

Revision Comparison Table for the Type JRF-90Y-950K SAR, a portion of the table of contents.

Response #1: The above two examples have been corrected and the file is now identified as Document No. 4 (Proprietary Comparison Table of SAR for Type JRF-90Y-950K). This has also been corrected in the Non-proprietary version.

Response #2: In double-checking all the documents, we discovered that Pages 61 -

68 in Document No. 2 Proprietary English version of SAR for JRF-90Y-950K contain tables that have not been translated into English. Our Japanese client is working on the translation now and we will re-submit the tables as soon as possible with the English translation. This issue is not present in the Non-proprietary version (Document No. 2-1 Non-proprietary English version of SAR for JRF-90Y-950K) as Pages 61- 68 were redacted.

(5) Clarify the following:

Since the application provides a comparison of the 2017 and 2022 versions of the SAR with the 2022, does this application include any of the changes in the revalidation recommendation issued in April 2022 for this package.

Response: Yes. Changes in the revalidation recommendation issued in April 2022 for the JRF package are:

• Consideration of Aging of the JRF Package; and

• Deletion of registered contents without a plan for transportation in the future.

Please refer top Document No. 3 Proprietary Summary of Change of SAR for JRF-90Y-950K (1) for further details.

Do the text highlighted in gray and the text in blue boxes in different documents correspond to the changes to the SAR from the 2017 version?

Response: Yes. The gray highlights are items changed in the new version of the SAR submitted with this application. The blue boxes show fuel deleted in the new version of the SAR.

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There are instances in which there is a phrase Modifications reflecting the changes to the contents on the right-hand side of the page, but there is no text highlighted or marked as a change. It will be more efficient for the review to consistently mark/identify the proposed changes in the documents submitted in the application, including the SAR.

Response: This phrase occurs on 3 pages. The explanation is below:

Page 44: Three JRR 4 fuel elements listed in the 2017 version of the SAR were deleted in the new version of the SAR (2022). The deleted elements are highlighted in blue. The new table in the 2022 version just list two JRR3 elements and 2 JMTR elements.

Page 45: Five JMTRC fuel elements listed in the 2017 version of the SAR (in top table) were deleted in the new version of the SAR (2022). The deleted elements are highlighted in blue. The new table lists just four JMTRC fuel elements. With respect to the bottom table on Page 45, it is entirely deleted in the new version of the SAR (2022).

Page 68: Three JRR 4 fuel elements listed in the 2017 version of the SAR were deleted in the new version of the SAR (2022). Also, certain JMTRC fuel elements listed in the 2017 version of the SAR were deleted in the new version of the SAR (2022). The deletions here are highlighted in yellow in the 2017 version.

Thank you for all of your assistance and please let us know of any other questions or clarifications needed.

Today, the following documents were uploaded to replace the previous documents:

No. 1 Proprietary Japanese JRF-90Y-950K Validation (Eng)

No. 1-1 Non-proprietary version of Japanese JRF-90Y-950K Validation (Eng)

No. 2 Proprietary English version of SAR for JRF-90Y-950K No. 2-1 Non-proprietary English version of SAR for JRF-90Y-950K No. 3 Proprietary Summary of Change of SAR for Type JRF-90Y-950K No. 3-1 Non-proprietary version of Summary of Change of SAR for JRF-90Y-950K No. 4 Proprietary Comparison Table of SAR for Type JRF-90Y-950K No. 4-1 Non-proprietary version of Comparison Table of SAR for Type JRF-90Y-950K No. 5 An Affidavit on the proprietary documents (JRF) R1 4

I am available to answer any questions or provide additional information.

Sincerely yours, Russell Neely Chief Operating Officer 5