ML23349A186
| ML23349A186 | |
| Person / Time | |
|---|---|
| Site: | 07103103 |
| Issue date: | 12/14/2023 |
| From: | Boyle R US Dept of Transportation (DOT), Office of Hazardous Materials Safety |
| To: | Mark King Storage and Transportation Licensing Branch, Secured Transportation Services, US Dept of Transportation (DOT), Office of Hazardous Materials Safety |
| Shared Package | |
| ML23349A155 | List: |
| References | |
| 001794 | |
| Download: ML23349A186 (2) | |
Text
From: Boyle, Rick (PHMSA)
To: Mat King Cc: Sumrall, Matthew (PHMSA); Norma Garcia Santos; Roy Boyd
Subject:
[External_Sender] RE: Notice: Opportunity to Withdraw Application, Certificate of Approval No. CZ/100/B(U)F-6, Revision 0, model No. SKODA (Docket No. 71-3103, EPID No. L-2023-DOT-0004)
Date: Thursday, December 14, 2023 11:45:26 AM Attachments: image001.png image002.png
Good morning Mat,
The passage of time and need to keep our casework current has changed. The NRCs email that I forwarded lists a few examples of problems with translation and clarity of drawings and figures. We are of the opinion that your complete review, correction and update of the application will take longer than 30 days. Accordingly, you are requested to withdraw the application and resubmit when you have updated, verified the application and all supporting material.
Thank you for your time and consideration.
Rick Boyle Chief, Radioactive Materials Transport
USDOT, PHMSA 1200 New Jersey Avenue SE, Washington, DC, 20590 Office: 202.366.2993 Mobile: 202.697.1301
From: Mat King <mdk@stsnuclear.com>
Sent: Thursday, December 14, 2023 11:35 AM To: Boyle, Rick (PHMSA) <rick.boyle@dot.gov>
Cc: Sumrall, Matthew (PHMSA) <matthew.sumrall@dot.gov>; norma.garciasantos@nrc.gov; Roy Boyd <rab@stsnuclear.com>
Subject:
Re: Notice: Opportunity to Withdraw Application, Certificate of Approval No. CZ/100/B(U)F-6, Revision 0, model No. SKODA (Docket No. 71-3103, EPID No. L-2023-DOT-0004)
CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe.
Hi Rick,
In your previous email on 11/16 you identified these issues and our DOE project sponsors have already instructed us to begin working to correct them. We were intending to have the necessary documents translated and to try to get the affidavit requested. It now sounds like there is no longer the option to correct them? Was there some time limit that has expired or has something else changed?
Any clarification is appreciated.
Thank you,
Mat D. King Secured Transportation Services, LLC An Onium Company Office: +1 (770) 932-4166 Mobile: +1 (509) 339-5194 mdk@stsnuclear.com
This email message is intended only for the use of the named recipient. Information contained in this email message and its attachments may be privileged, confidential and protected from disclosure. If you are not the intended recipient, please do not read, copy, use or disclose this communication to others. Also please notify the sender by replying to this message and then delete it from your system.
From: Boyle, Rick (PHMSA) <rick.boyle@dot.gov >
Date: Thursday, December 14, 2023 at 11:27 AM To: Mat King <mdk@stsnuclear.com>
Cc: Sumrall, Matthew (PHMSA) <matthew.sumrall@dot.gov>, norma.garciasantos@nrc.gov <norma.garciasantos@nrc.gov >
Subject:
FW: Notice: Opportunity to Withdraw Application, Certificate of Approval No. CZ/100/B(U)F-6, Revision 0, model No. SKODA (Docket No. 71-3103, EPID No. L-2023-DOT-0004)
Good morning Mat,
Your SKODA package design approval application failed to satisfy acceptance criteria and has been rejected. It is much better (and I strongly advise) that you withdraw your application.
There is an oddity with your application. The application and all the supporting data is posted on ADAMS whether or not you withdraw it. Since portions of the application are proprietary, you will need to provide a public copy with an affidavit justifying the withholding or provide approval to post the proprietary material.
Thank you for your time and consideration.
Rick Boyle Chief, Radioactive Materials Transport
USDOT, PHMSA 1200 New Jersey Avenue SE, Washington, DC, 20590 Office: 202.366.2993 Mobile: 202.697.1301
From: Norma Garcia Santos < Norma.GarciaSantos@nrc.gov>
Sent: Thursday, December 14, 2023 8:17 AM To: Boyle, Rick (PHMSA) <rick.boyle@dot.gov >
Subject:
Notice: Opportunity to Withdraw Application, Certificate of Approval No. CZ/100/B(U)F-6, Revision 0, model No. SKODA (Docket No. 71-3103, EPID No. L-2023-DOT-0004)
CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe.
Good morning,
The purpose of this email is to inform you that the application submitted by the U.S. Department of Transportation requesting the U.S. Nuclear Regulatory Commission to provide a recommendation to revalidate Certificate of Approval No. CZ/100/B(U)F-6, Revision 0, Model No. SKODA, will not be accepted for review due to deficiencies identified during the administrative review of the application. First, the application lacks of translations to the English language and includes inappropriate or poor resolution of figures or graphs. The table provided in this email includes examples of such deficiencies. Note that the information included in the table is not all inclusive and the applicant is responsible for ensuring that the application, including supporting documentation, are fully translated to English and that the material (e.g., figures, graph, etc.) is legible, clear, and appropriate to proceed with the review. Second, the application does not include an affidavit identifying documents consider as proprietary by the applicant. Therefore, if an affidavit is not received by the date stated in this email, the application will be released as public documents, independently if the applicant decides to withdraw.
Third, the staff noted that the Certificate of Approval No. CZ/100/B(U)F-6, Revision 0, was approved for 10 years and it will be appropriate to include in the applicants request if the intent is to seek revalidation for the package in the U.S. is also for 10 years.
Lastly, Given the deficiencies in the application, the staff wants to provide you the opportunity to withdraw the application and to provide an affidavit identifying each document submitted as part of the application considered proprietary information per 10 CFR 2.390. I will appreciate that you inform us about your decision by not later than January 5 th, 2024.
Please contact me if you have questions about this communication.
Document Title Examples of Deficiencies Czech Language and English Translation of the Certificate of the Competent Authority for the Model No.
SKODA MTR TRIGA Package, CZ/100/B(U)F-6, Revision 0 Needs translation of packages drawing Document No. Ae 22 294/Dok, Rev. 00 (English), Safety Report of the SKODA MTR-TRIGA Transport and The legend of figure No. 8 is not clear.
Storage Cask Needs translation of figure in Section 6.1 Document No. Ae 11543 (English), TRANSPORT AND STORAGE CASK FOR SPENT FUEL FROM Needs translation of figure 3 in section 2.1; pages RESEARCH REACTORS (SKODA VPVR/M CASK), (SAR) Safety Documentation, Acc. to Subj Decree 47-48; and figures 4 and 5 317/2002 Col.
Document No. Ae 21517/Dok, Rev. 2 (English), Technical Report, Initials Technical Data "Design Basis" for Needs translation of name of annex and Figure 7.
SKODA MTR-TRIGA Cask Project 8 Document No. Ae 21713/DOk, Rev. 1 (English), Technical Document, SKODA MTR-TRIGA Cask Shielding Needs translation of name of figures 2.7, 3.1, 3.2, Calculation and 3.3 Document No. Ae 21722/Dok, Rev. 00 (English), Calculation Report for External Customer, SKODA MTR-TRIGA Cask - Thermal Calculation - Transport Needs translation of name of page 1 Document No. Ae 21723/DoK, Rev. 00 (English), Calculation Report for an External Customer, SKODA MTR-TRIGA Cask - Mechanical Resistance Calculation - Transport Needs translation of name of figure 1.1 Appendix No. 1, CALCULATION OF SKODA VPVR/M SPENT FUEL TRANSPORT AND STORAGE CASK Needs translation of name of figures, SHIELDING, Stage III, Revision 4, Reg. No. A 1287 R, T, Nuclear Research Institute plots/graphs, and packages drawings Figures need to be translated. The applicant App 2 SKODA Drop test Analysis VPVRM cask needs to provide legible figures as well as better resolution.
Sincerely, Norma Garcia Santos Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards