ML24248A223
| ML24248A223 | |
| Person / Time | |
|---|---|
| Site: | 07103043 |
| Issue date: | 12/08/2023 |
| From: | Shaw D Mitsubishi Nuclear Fuel Co, Ltd, Orano TN Americas, TN Americas LLC |
| To: | Boyle R Office of Nuclear Material Safety and Safeguards, US Dept of Transportation, Pipeline & Hazardous Materials Safety Admin |
| Shared Package | |
| ML24248A221 | List: |
| References | |
| E-62910 | |
| Download: ML24248A223 (1) | |
Text
December 8, 2023 E-62910 Orano TN 7160 Riverwood Drive Suite 200 U.S. Department of Transportation Columbia, MD 21046 Attn: Mr. Richard W. Boyle USA Tel: 410-910-6900 Pipeline & Hazardous Materials Safety Administration Fax: 434-260-8480 Radioactive Materials Branch 1200 New Jersey Avenue, S.E.
East Building, PHH-20 Washington, DC 20590
Subject:
Materials Package Design Certificate USA/0535/AF-96, Revalidati on of Japanese Competent Authority Certificate J/105/AF-96
Reference:
[1] Competent Authority of Japan, Certification for Approval of Package Design for Transport of Radioactive Materials, Identifi cation Mark: J/105/AF, dated September 13, 2023
[2] Competent Authority Certification for Type Fissile Radioact ive Materials Package Design, Certificate USA/0535/AF-96, Revision 5, Revalidation of Japanese Competent Authority Certificate J/105/AF-96, dated October 7, 2019
Dear Mr. Boyle:
TN Americas LLC (TN), on behalf of Mitsubishi Nuclear Fuel Co., Ltd. (MNF),
requests a U.S. Department of Transportation (DOT) revalidation of the Competent Authority of Japan, Certification for Approval of Package Desig n for Transport of Radioactive Materials, Identification Mark: J/105/AF [1] in acc ordance with §173.473.
The request being submitted is to revalidate the MFC-1 as a Typ e AF package design that meets the applicable requirements for fissile material pac kages in Section VI of the International Atomic Energy Agency Regulations for the Safe Transport of Radioactive Material, SSR-6, Revision 1, 2018 Edition.
The DOT previously issued Competent Authority Certification (CA C) USA/0535/AF-96, Revision 5 [2], to revalidate the Japanese Competent Author ity (ASN) certificate J/105/AF-96, Revision 3. This current DOT CAC expires on July 7, 2024. TN requests that the DOT reissue a revalidation as USA/0535/AF, Revision 6 to approve changes and renew the revalidation through July 2029.
Enclosures transmitted herein contain SUNSI. When separated fr om enclosures, this transmittal document is decontrolled.
E-62910 U.S. DOT Page 2 of 3
The following enclosures are provided for the review of changes to the MFC-1 package design:
x Enclosure 1 provides the English version of Japanese Approval Certificate of a Package Design, Number J/105/AF x Enclosure 2 provides a summary of changes in the MFC-1 SAR x Enclosure 3 provides a revision comparison table for MFC-1 SAR Rev. August, 2016 and Rev. December, 2023 (Proprietary version) x Enclosure 4 provides the proprietary version of the MNF Safety Analysis Report for MFC-1, Rev. December 2023 (Proprietary version) x Enclosure 5 provides the MNF Fundamental Policy of Quality Man agement, Rev.
December 2023 (Proprietary version)
Non-proprietary versions of Enclosures 3, 4, and 5 will be prov ided in a supplement to this application. Due to the size of the enclosure files, a secure file sharing application is used for submission of Enclosures 4.
Issuing of the DOT revalidation allows for ongoing export shipm ents of the PWR fuel from a fuel fabricator in the U.S. to commercial utilities in Japan. The r evalidation certificate is needed by June 2024.
Should you have any questions or require additional information to support review of this application, please contact Mr. Peter Vescovi by telephone at 3 36-420-8325, or by e-mail at Peter.Vescovi@orano.group.
Sincerely,
Digitally signed by SHAW Donis SHAW Donis Date: 2023.12.08 10:43:40
-05'00'
Don Shaw Licensing Manager TN Americas LLC
cc: Peter Vescovi, Licensing Engineer, TN Americas, LLC Laurence Labbe, Senior Project Manager, TN Americas, LLC Toshihiro Matsuoka, MNF Norihiko Kaneko, MNF
E-62910 U.S. DOT Page 3 of 3
Enclosures:
- 1) Competent Authority of Japan, Certification for Approval of Package Design for Transport of Radioactive Materials, Identification Mark: J/105/AF (English v ersion)
- 2) Summary of Changes in Revision 0 of the Safety Analysis Repo rt for the Model MFC-1 Package
- 3) Revision Comparison Table of Contents for MFC-1 SAR (Propr ietary version)
- 4) Safety Analysis Report for Model MFC-1 Package, Rev. Decembe r, 2023 (Proprietary version)
- 5) Fundamental Policy of Quality Management, Rev. December, 202 3 (Proprietary version)
Enclosure 1 to E-62 910
Competent Authority of Japan, Certification for Approval of Package Design for Transport of Radioactive Materials, Identification Mark: J/105/AF (English version)
Enclosure 2 to E-62 910
Summary of Changes in Revision 0 of the Safety Analysis Report for the Model MFC -1 Package Mitsubishi Nuclear Fuel Co., Ltd.
November 2023 Doc No.: TPD-23-036
Summary of Change in Revision 0 of the Safety Analysis Report for the Model MFC-1 Package
The safety analysis report for the model MFC-1 package (SAR for short) has been modified.
The principal items revised are as follows;
- 1. Consideration of impact due to aging has been added to comply with requirement of IAEA transport regulation, SSR-6 (Rev.1).
- 2. Three-dimensional model has been employed in critical analysis for improvement of analysis precision.
- 3. Structure of SAR including chapter number and chapter title has been revised in accordance with Japanese regulatory guide revised.
- 4. QMS document has been separated from SAR in accordance with Japanese regulatory guide revised and it has been updated.
- 5. Other minor revisions including update of information, corrections of phrase etc. has been performed.
Detail of the changes is summarized in attached Revision Comparison Tables.
Attachment Revision Comparison Table Comparison Table
<Appendix-1> Safety Analysis Report for Model MFC-1 Package
<Appendix-2> Fundamental Policy of Quality Management
Enclosure 6 to E-62910
STATEMENT OF PROPRIETARY INFORMATION PURSUANT TO 49 CFR 7.14, 49 CFR 105.30, AND 10 CFR 2.390
I, Isao Nakajima, depose and say that I am the General Manager of the Transportation and Service Department of Mitsubishi Nuclear Fuel Co., Ltd. (MNF), duly authorized to execute this statement of proprietary information and have reviewed or caused to have reviewed the information which is identified as proprietary and referenced in the paragraph immediately below. TN Americas LLC on behalf ofMNF, is submitting this statement of proprietary information in conformance with the provisions of 49 CFR 7.14 and 49 CFR 105.30 of the U.S. Department of Transportation's (U.S. DOT) regulations, and with the provisions of 10 CFR 2.390 of the Nuclear Regulatory Commission's (NRC) regulations. This information is exempt from public disclosure under the Freedom oflnformation Act, 5 U.S.C. 552, as amended, for withholding this information.
The information for which withholding is requested is listed below :
- Enc losure 3 - Revision Comparison Table of "Contents" for MFC-1 SAR
- Enc losure 4 - Safety Analysis Report for Model MFC-1 Package, Rev. December 2023
- Enclosure 5 -Fundamental Policy of Quality Management, Rev. December 2023
These documents have been appropriately designated as proprietary.
Pursuant to the provisions of paragraph 7.14 of Pait 7 and paragraph (a) (3) of Part 105 of the U.S. DOT regulations, and the provisions of paragraph (b) ( 4) of Section 2.390 of the NRC regulations the following is furnished for consideration by the U.S.DOT and by the NRC in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.
- 1) The information sought to be withheld contains trade secret or confidential or privileged commercial for Model MFC-1 Packaging. The information in the Revalidation request is owned and has been held in confidence by MNF.
- 2) The information is of a type customarily held in confidence by MNF and not customarily disclosed to the public. MNF has a rational basis for determining the types of information that is customarily held in confidence by it.
- 3) Public disclosure of the information is likely to cause substantial harm to the competitive position of MNF because the information consists of descriptions of the design and analysis of the MFC-1 Packaging, as well as company business sensitive information, the application of which provides a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with MNF, take marketing or other actions to improve their product 's position or impair the position of MNF product, and avoid developing similar data and analyses in support of their processes, method s, or apparatus.
Further the deponent sayeth not.
Isao Nakajima General Manag ransportation and Service Department Mitsubishi Nuclear Fuel Co., Ltd.