ML25230A068

Orano Tn Letter to DOT Regarding Materials Package Design Certificate USA/0839/AF-96 for MX-6P Package

ML25230A068
Person / Time
Site:	07103100
Issue date:	08/05/2025
From:	Shaw D Orano TN Americas
To:	Vierling R Office of Nuclear Material Safety and Safeguards, US Dept of Transportation, Pipeline & Hazardous Materials Safety Admin, US Dept of Transportation, Radioactive Materials Branch
Shared Package
ML25230A066	List: ML25230A067 ML25230A068
References
E-64719
Download: ML25230A068 (1)

Text

Orano TN 7160 Riverwood Drive Suite 200 Columbia, MD 21046 USA Tel: 410-910-6900 Fax: 434-260-8480 Enclosures transmitted herein contain SUNSI. When separated from enclosures, this transmittal document is decontrolled.

August 5, 2025 E-64719 U.S. Department of Transportation Attn: Mr. Ryan Vierling Pipeline & Hazardous Materials Safety Administration Radioactive Materials Branch 1200 New Jersey Avenue, S.E.

East Building, PHH-20 Washington, DC 20590

Subject:

Materials Package Design Certificate USA/0839/AF, Revalidation of Japanese Competent Authority Certificate J/2037/AF

Reference:

[1] Competent Authority of Japan, Certification for Approval of Package Design for Transport of Radioactive Materials, Identification Mark: J/2037/AF-96, dated March 11, 2021

[2] Competent Authority Certification for A Type Fissile Radioactive Materials Package Design, Certificate USA/0839/AF-96, Revision 0, Revalidation of Japanese Competent Authority Certificate J/2037/AF-96, dated January 3, 2023

Dear Mr. Vierling:

TN Americas LLC, on behalf of Transnuclear Tokyo, requests a U.S. Department of Transportation (DOT) revalidation of the Competent Authority of Japan, Certification for Approval of Package Design for Transport of Radioactive Materials, for the model MX-6P package [1] in accordance with 49 CFR 173.473.

The DOT previously issued Competent Authority Certification (CAC)

USA/0839/AF-96, Revision 0 [2], to revalidate the Japanese Competent Authority (ASN) certificate J/2037/AF-96, Revision 0. This current DOT CAC expires on March 10, 2026. TN requests that the DOT reissue a revalidation as USA/0839/AF, Revision 1 to approve changes and renew the revalidation.

E-64719 U.S. DOT Page 2 of 3 The following enclosures are provided for the review of changes to the MX-6P package design:

x provides the Statement of Proprietary Information x provides the English version of Japanese Approval Certificate of a Package Design, Number J/2037/AF x provides a revision comparison table between the current SAR and the new SAR for the MX-6P Package (Proprietary version) x provides a revision comparison table between the current SAR and the new SAR for the MX-6P Package (Public version) x provides the proprietary version of the MX-6P Safety Analysis Report for MX-6P (Proprietary version) x provides the public version of the MX-6P Safety Analysis Report for MX-6P, Rev. 1 (Public version) x provides the MX-6P maintenance activities applied to MX-6P packaging x provides the MX-6P Quality Management Method Due to the size of the enclosure files, a secure file sharing application is used for submission of Enclosures 5 and 6.

Issuing of the DOT revalidation allows for ongoing import shipments of the PWR fuel from commercial utilities in Japan to a fuel fabricator in the U.S. for uranium recovery. The revalidation certificate is needed by January 2026 to allow packing operations to start in Japan in February 2026.

Should you have any questions or require additional information to support review of this application, please contact Mr. Doug Yates by telephone at 434-832-3101, or by e-mail at Douglas.Yates@orano.group.

Sincerely, Don Shaw Licensing Manager TN Americas LLC cc:

Doug Yates, Licensing Engineer, TN Americas, LLC Laurence Labbe, Senior Project Manager, TN Americas, LLC SHAW Donis Digitally signed by SHAW Donis Date: 2025.08.05 06:39:18 -04'00'

E-64719 U.S. DOT Page 3 of 3

Enclosures:

1) Statement of Proprietary Information

2) Competent Authority of Japan, Certification for Approval of Package Design for Transport of Radioactive Materials, Identification Mark: J/2037/AF (English version)

3) Comparison between current SAR and new SAR of MX-6P package (Proprietary version)

4) Comparison between current SAR and new SAR of MX-6P package (Public version)

5) MX-6P Safety Analysis Report (Proprietary version)

6) MX-6P Safety Analysis Report (Public version)

7) Maintenance activities applied to MX-6P packaging

8) MX-6P Quality Management Method

to E-64719 Competent Authority of Japan, Certification for Approval of Package Design for Transport of Radioactive Materials, Identification Mark:

J/2037/AF (English version)

to E-64719 Comparison between current SAR and new SAR of MX-6P package (Proprietary version)

Sent as separate enclosure

to E-64719 Comparison between current SAR and new SAR of MX-6P package (Public version)

Comparison between current SAR and new SAR of MX-6P package MX-6P package Japanese design approval has been updated. At this updating, SAR was revised considering SAR of MX-6 (1F4) recently approved and requests from NRA during discussion.

This documents explains comparison between current SAR and new SAR of MX-6P package referring MX-6(1F4) SAR, which evaluations are incorporated to the new SAR.

1. Outline of updating Table-1summarizes changes of each approval to show its history of revising.

Table-1 Changes of each approval Packages US Certificates Changes Packaging design Contents Aging evaluation MX-6 USA/0848/AF-96 Rev. 0 1F6 BWR fuel Not required Rev. 1 Same as Rev.0 1F4 & 1F6 BWR fuels Required MX-6P USA/0839/AF-96 Rev. 0 PWR fuel Not required Rev. 1 Same as Rev.0 A part of Rev.0 *1 Required

• 1: According to a suggestion of NRA, 10 feet fuel has been removed because no transport is planned within this license, 12 feet fuel only is the contents of new SAR.

As shown in the Table-1, difference of evaluation between current SAR and new one is aging evaluation basically.

The Table-2 shows comparison of packaging materials between MX-6 and MX-6P.

As shown in the Table-2. materials used for MX-6 covers the materials for MX-6P.

Therefore, aging evaluation for MX-6P can be covered by the evaluation for MX-6.

Table-2 Comparison of packaging materials between MX-6 and MX-6P Packagings Body Shock absorbing cover (SAC)

Main materials of basket MX-6 Same Same f Aluminum alloy *1 f Borated stainless steel MX-6P f Aluminum alloy *2 f Borated stainless steel f stainless steel *3

• 1: AW-, AW-etc. are used. *2: AW-is only used. *3: Same material with SAC plates

2. Comparison of SAR Concerning evaluations for each analysis item, differences between current SAR and new SAR of MX-6P package are detailed in the following Table-3.



Table-3 Comparison of SAR among MX-6 and MX-6P packages (1/12)

Chapter Section Subsections / Items *1 Comparison of SAR (descriptions for evaluation)

Remarks MX-6P (current)

MX-6 (1F4&6) *2 MX-6P (new) *3 Chapter-I Description of nuclear fuel package I-A Purpose and conditions 5. Transport index 0.2 or less 10 or less No change from current

12. Assumed ambient temperature

-40°C38°C

Å No change from current

13. Planned number of years for use (Not described) 50 years

Å New description

14. Planned number of usage of packaging (Not described) 200 times

Å New description Table I-A.1 Specification of nuclear material containing in packaging Weight of contents (kg) 4800 or less 4150 or less No change from current 10 feet fuel was deleted Weight of fuel assembly (kg) 3920 or less (1414 10 feet) 4720 or less (1414 12 feet) 3100 or less 4720 or less (1414 12 feet) only 10 feet fuel was deleted Total activity (GBq) 5.85RUOHVV(Total major nuclides:

4.89RUOHVVIHHW

7.05RUOHVV(Total major nuclides:

5.90RUOHVVIHHW

1.15RUOHVV

(Total major nuclides: 2.59RUOHVV

7.05RUOHVV(Total major nuclides:

5.90RUOHVVIHHWRQO\\

10 feet fuel was deleted I-B Type of package Type AF

Å No change from current I-C Packaging C-1 Design summary MX-6 Body + PWR basket MX-6 Body + BWR basket No change from current C-2 Structure C-3 Material C-4 Dimensions C-5 Weight Weight of components Weight of components and gross weigh

Å (Basket and contents are different)

No change from current Note 1) contents weight Fuel assemblies + packing materials Fuel assembly (including channel boxes)

+ packing materials + fuel cans No change from current I-D Contents of packaging (1) Fuel assemblies Type 1414 10 feet & 1414 12 feet C-lattice fuel & D-lattice fuel 1414 12 feet only 10 feet fuel was deleted Contamination (Not described)

Contamination from SF pool and rubble No change from current Table I-D.1 Fuel assembly type and spec.

Material, dimensions and weights Material, dimensions and weights Material, dimensions and weights (1414 12 feet only) 10 feet fuel was deleted Other tables (Not described)

Channel box, Fuel can etc.

No change from current (2) Stool Used for 1414 10 feet fuel Not used (loaded into fuel can)

(Deleted) 10 feet fuel was deleted (3) Fuel composition specifications U235, U238 and impurities specifications U235, U238 and impurities specifications No change from current (4) Quantity of radioactive material Specific activity Specific activity No change from current Activity (10 feet and 12 feet)

Activity Activity (12 feet only) 10 feet fuel was deleted Appendix-1 Causes of contamination Spent fuel pool water Spent fuel pool water + rubble No change from current Measurement dose equivalent rate of surface of fuel assembly (Not described)

Comparison with the operational criteria No change from current Assumption of activity due to contamination

[60Co TBq/package]

TBq/package

[137Cs and other nuclides(63Ni, 134Cs, 90Sr, 137mBa, 90Y)]

No change from current

• 1: Subsections or items are based on the MX-6(1F4&6) SAR *2: Items indicated by blue color letter are incorporated to new SAR. *3: Differences between MX-6P current and new are indicated by red color letters.



Table-3 Comparison of SAR among MX-6 and MX-6P packages (2/12)

Chapters Sections Subsections / Items *1 Comparison of SAR (descriptions for evaluation)

Remarks MX-6P (current)

MX-6 (1F4&6) *2 MX-6P (new) *3 Chapter-II Safety analysis of nuclear fuel package

1. Structural analysis Summary of structural analysis

Å No change from current

2. Thermal analysis Summary of thermal analysis

Å No change from current

3. Containment analysis Summary of containment analysis

Å No change from current

4. Shielding analysis Summary of shielding analysis

Å No change from current

5. Criticality analysis Summary of criticality analysis

Å No change from current

6. Consideration of aging of nuclear fuel package (Not described)

Summary of evaluation for aging of packaging

Å New description

7. Evaluation of conformity to Regulation and Notification Summary of evaluation to Regulation and Notification

Å No change from current Chapter II-A Structural analysis A.1 Structural design A.1.1 Summary Summary of structural design

Å No change from current A.1.2 Design criteria Criteria for mechanical tests

Å No change from current A.2 Weight and center of gravity Weight and position of center of gravity

Å (except differences due to basket and contents)

No change from current A.3 Mechanical properties of materials Mechanical properties of materials

Å (except basket)

No change from current A.4 Requirements for nuclear fuel package A.4.1 Chemical and galvanic reactions List of contact of different materials

Å (except differences due to basket and contents)

No change from current A.4.2 Low temperature strength Strength at -40°C

Å No change from current A.4.3 Containment system Structure related to openings

Å No change from current A.4.4 Lifting devices Stress and fatigue evaluation for trunnion and handling belts Results of Appendix-6

Å For fatigue evaluation, number of service cycle are added based on planned number of usage (based on Chap. IA 14).

Å Additional description A.4.5 Tie down devices Stress evaluation for body supported by transport frame

Å (except differences due to basket and contents)

No change from current A.4.6 Pressure Pressure due to temperature changes during transport Results of Appendix-7

Å No change from current A.4.7 Vibration Comparison between natural frequency and vibration given by transport means.

Results of Appendix-8

Å (except differences due to basket and contents)

No change from current A.5 Normal conditions of transport A.5.1.1 Summary of temperatures and pressures Results of B.4

Å No change from current A.5.1 Thermal test A.5.1.2 Thermal expansion Evaluation for clearance between basket and packaging body, contents and packaging Results of Appendix-9

Å (except differences due to basket and contents)

No change from current

• 1: Subsections or items are based on the MX-6(1F4&6) SAR *2: Items indicated by blue color letter are incorporated to new SAR. *3: Differences between MX-6P current and new are indicated by red color letters.



Table-3 Comparison of SAR among MX-6 and MX-6P packages (3/12)

Chapters Sections Subsections / Items *1 Comparison of SAR (descriptions for evaluation)

Remarks MX-6P (current)

MX-6 (1F4&6) *2 MX-6P (new) *3 Chapter II-A Structural analysis A.5.1 Thermal test A.5.1.3 Stress calculation Evaluation for stresses of body components and for fatigue of lid tightening bolt

Å

1) For fatigue evaluation, number of service cycle are added based on planned number of usage (based on Chap. IA 14).

2) Results of fatigue evaluation shown in Appendix-13 is summarized.

Å Additional description A.5.1.4 Comparison with allowable stress Conclusion of A.5.1.3

Å No change from current A.5.2 Water spray Explanation for surface condition of cask against water spray

Å No change from current A.5.3 Free drop (1) Packaging body, SAC (2) Basket (3) Fuel cladding Evaluation for plastic strain of packaging components, deformation of SAC, stress of lid tightening bolt and plastic strain of fuel cladding Results of Appendix-10

Å (except differences due to basket and contents)

No change from current (Evaluation for 10 feet fuel cladding was deleted) 10 feet fuel was deleted A.5.4 Stacking test (1) Vertical position (2) Horizontal position Evaluation for stresses of packaging body under stacking test on vertical and horizontal positions Results of Appendix-11

Å No change from current A.5.5 Penetration Evaluation for no penetration against external plate Results of Appendix-12

Å No change from current A.5.6 Corner or edge drop Not applicable

Å No change from current A.5.7 Summary of results and evaluation (1) Thermal test Conclusion of evaluation for stress and clearance Conclusion of evaluation for displacement of opening in lid gasket part

Å No change from current (2) Water spray Conclusion of water spray

Å No change from current (3) Free drop Conclusion of evaluation for plastic strain and stress Conclusion of evaluation for displacement of opening in lid gasket part

Å (except differences due to basket and contents)

No change from current (4) Stacking test Conclusion of evaluation for stress Conclusion of evaluations for SAC outer plate and displacement of opening in lid gasket part

Å No change from current (5) Penetration Conclusion of evaluation for external plate Conclusion of evaluations for SAC plate

Å No change from current A.6 Accident condition of transport Not applicable

Å No change from current A.7 Enhanced water immersion test Not applicable

Å No change from current

• 1: Subsections or items are based on the MX-6(1F4&6) SAR *2: Items indicated by blue color letter are incorporated to new SAR. *3: Differences between MX-6P current and new are indicated by red color letters.



Table-3 Comparison of SAR among MX-6 and MX-6P packages (4/12)

Chapters Sections Subsections / Items *1 Comparison of SAR (descriptions for evaluation)

Remarks MX-6P (current)

MX-6 (1F4&6) *2 MX-6P (new) *3 Chapter II-A Structural analysis A.8 Radioactive contents Conclusion of evaluation for fuel cladding in A.9 Package containing fissile material

Å No change from current A.9 Package containing fissile material Purpose of this section which is evaluation of damage condition assumed in criticality analysis

Å No change from current A.9.1 NCT for package containing fissile material Summary of A.5.2 to A.5.5

Å (except differences due to basket and contents)

No change from current A.9.2 ACT for package containing fissile material (1) 9m drop test Evaluation for plastic strain of packaging components, deformation of SAC, stress of lid tightening bolt and plastic strain of fuel cladding

Å (except differences due to basket and contents)

No change from current (Evaluation for 10 feet fuel cladding was deleted) 10 feet fuel was deleted (2) 1m drop test Evaluation for deformation of lid part, bottom part and shell part by mock-up test Evaluation for plastic strain of basket under horizontal drop by analysis

Å (except differences due to basket and contents)

No change from current (3) Thermal test (fire test)

Evaluation for plastic strain of packaging components and stress of lid tightening bolt Evaluation for clearance between body and basket due to thermal expansion Evaluation for stress of fuel cladding due to internal pressure

Å (except differences due to basket and contents)

No change from current (Evaluation of fuel cladding is replaced by 12 feet) 10 feet fuel was deleted (4) 0.9 m water immersion test Not applicable because water immersion is assumed for criticality analysis

Å No change from current A.10 Appendix A.10.1 Appendix-1 Design fatigue strength curves Design fatigue strength curves of austenitic stainless steel and high strength bolt

Å No change from current A.10.2 Appendix-2 model drop test verification analysis Comparison between drop tests and verification analyses Confirmation of applicability of the analysis conditions

Å No change from current A.10.3 Appendix-3 model drop test verification analysis Comparison between drop tests and verification analyses Confirmation of applicability of the analysis conditions

Å No change from current A.10.4 Appendix-4 Strength of packaging body subjected to 15m water immersion test Evaluation for stress of packaging body against external pressure on 15m water immersion test

Å No change from current A.10.5 Appendix-5 Strength of rear trunnions under horizontal lifting operation Evaluation for stress of trunnions under horizontal lifting operation

Å No change from current A.10.6 Appendix-6 Strength of packaging body against lifting operation Evaluation for stress of packaging body components under lifting operation

Å (except differences due to basket and contents)

No change from current

• 1: Subsections or items are based on the MX-6(1F4&6) SAR *2: Items indicated by blue color letter are incorporated to new SAR. *3: Differences between MX-6P current and new are indicated by red color letters.



Table-3 Comparison of SAR among MX-6 and MX-6P packages (5/12)

Chapters Sections Subsections / Items *1 Comparison of SAR (descriptions for evaluation)

Remarks MX-6P (current)

MX-6 (1F4&6) *2 MX-6P (new) *3 Chapter II-A Structural analysis A.10 Appendix A.10.7 Appendix-7 Strength of packaging body against pressure/temperature changes Evaluation for stress of packaging body and displacement of opening in lid gasket part due to pressure/temperature changes

Å No change from current A.10.8 Appendix-8 Effect of load amplification due to vibration during transport Calculation of load amplification Evaluation for stress of lid and bottom during transport considering the load amplification

Å (except differences due to basket and contents)

No change from current A.10.9 Appendix-9 Evaluation of thermal expansion in case of -40°C or °C reference Evaluation for clearance between body and basket, between contents and packaging considering reference temperatures of -40°C or °C

Å (except differences due to basket and contents)

No change from current A.10.10 Appendix-10 Displacement of opening during thermal test or free drop under NCT Evaluation for displacement of opening in lid gasket part at thermal test and free drop under NTC

Å (except differences due to basket and contents)

No change from current A.10.11 Appendix-11 Deformation and opening in shock absorbing covers during stacking test Evaluation for deformation of SAC in case that load of stacking test is given to SACs.

Evaluation for displacement of opening in lid gasket part

Å No change from current A.10.12 Appendix-12 Evaluation for penetration to outer plate of shock absorbing cover Evaluation for penetration to outer plate of SAC

Å No change from current A.10.13 Appendix-13 Fatigue evaluation on internal pressure change during transport (Not described)

Evaluation for fatigue strength of packaging body components due to internal pressure change during transport

Å New description A.10.14 Appendix-14 Selection of inclined angle for slap-down drop (Not described)

Explanation for reason of selection of inclined angle applied to slap-down drop in A.9.2

Å (except differences due to basket and contents)

New description

• 1: Subsections or items are based on the MX-6(1F4&6) SAR *2: Items indicated by blue color letter are incorporated to new SAR. *3: Differences between MX-6P current and new are indicated by red color letters.



Table-3 Comparison of SAR among MX-6 and MX-6P packages (6/12)

Chapters Sections Subsections / Items *1 Comparison of SAR (descriptions for evaluation)

Remarks MX-6P (current)

MX-6 (1F4&6) *2 MX-6P (new) *3 Chapter II-B Thermal analysis B.1 Summary Thermal design features Packaging design for heat transfer and counter measures for fire test

Å (except differences due to basket and contents)

No change from current Table II-B.1 Analysis conditions and methods Heat generation, ambient temperature, solar insolation, ambient emissivity and analysis code

Å No change from current B.2 Thermal properties of materials Physical properties of materials

Å (except differences due to basket)

No change from current B.3 Technical specification of components (1) resin (2) EPDM Service temperature range

Å No change from current B.4 Normal condition of transport Consideration for solar insolation

Å No change from current B.4.1 Thermal analysis model Heat supply and heat dissipation

Å No change from current B.4.1.1 Analysis model Shape of model Thermal condition

Å No change from current B.4.1.2 Test model Not applicable

Å No change from current B.4.2 Maximum temperature Calculation of temperature of package surface by formula

Å No change from current B.4.3 Minimum temperature Minimum temperature Embrittlement for packaging materials at the minimum temperature

Å No change from current B.4.4 Maximum internal pressure Calculation of internal pressure considering saturated vapor pressure

Å No change from current B.4.5 Maximum thermal stresses Result of thermal test

Å No change from current B.4.6 Summary of results and evaluation Summary of B.4.2 to B.4.5

Å No change from current B.5 Accident condition of transport Analysis code

Å No change from current B.5.1 Thermal analysis model 5.1.1 Analysis model Shapes and dimensions of analysis models and thermal conditions

Å (except differences due to basket)

No change from current 5.1.2 Test model Not applicable

Å No change from current B.5.2 Evaluation conditions of nuclear fuel package (1) Damage condition of package Summary of deformation at 9m drop and 1m drop

Å (except differences due to basket)

No change from current (2) Impact on thermal performance Consideration of damages on thermal analysis

Å No change from current B.5.3 Temperature of nuclear fuel package Maximum temperature of each part

Å (except differences due to basket)

No change from current B.5.4 Maximum internal pressure Calculation of internal pressure considering saturated vapor pressure

Å (except differences due to basket)

No change from current B.5.5 Maximum thermal stresses Result of thermal test

Å (except differences due to basket)

No change from current B.4.6 Summary of results and evaluation Summary of B.5.3 to B.5.5

Å (except differences due to basket)

No change from current

• 1: Subsections or items are based on the MX-6(1F4&6) SAR *2: Items indicated by blue color letter are incorporated to new SAR. *3: Differences between MX-6P current and new are indicated by red color letters.



Table-3 Comparison of SAR among MX-6 and MX-6P packages (7/12)

Chapters Sections Subsections / Items *1 Comparison of SAR (descriptions for evaluation)

Remark MX-6P (current)

MX-6 (1F4&6) *2 MX-6P (new) *3 Chapter II-C Containment analysis C.1 Summary Leaktightness of package

Å No change from current C.2 Containment system C.2.1 Containment system Components consisting of containment system and summary of II-A and II-B

Å No change from current C.2.2 Penetrations of containment system Parts of penetration and referred figures

Å No change from current C.2.3 Gaskets and welds of containment system Temperature condition and maintenance for gaskets

Å No change from current C.2.3.1 Gasket C.2.3.2 Welding area Inspections applied to welds

Å No change from current C.2.4 Lid Structure and integrity of lid part components Structure and integrity of lid part components Summary of the results for displacement of opening in lid gasket part

Å Additional description C.3 Normal condition of transport Conclusion of containment performance under normal condition of transport Conclusion of containment performance under normal condition of transport Summary of the results for displacement of opening in lid gasket part

Å Additional description C.3.1 Leakage of radioactive material Conclusion of NTC

Å No change from current C.3.2 Pressurization of containment system Maximum internal pressure and its impact Maximum internal pressure and its impact Summary of the results for displacement of opening in lid gasket part

Å Additional description C.3.3 Contamination of coolant Not applicable

Å No change from current C.3.4 Loss of coolant Not applicable

Å No change from current C.4 Accident conditions of transport Not applicable

Å No change from current C.5 Summary of results and evaluation Refer to C.2 and C.3 and conclusion for compliance to the Regulation

Å No change from current

• 1: Subsections or items are based on the MX-6(1F4&6) SAR *2: Items indicated by blue color letter are incorporated to new SAR. *3: Differences between MX-6P current and new are indicated by red color letters.



Table-3 Comparison of SAR among MX-6 and MX-6P packages (8/12)

Chapters Sections Subsections / Items *1 Comparison of SAR (descriptions for evaluation)

Remarks MX-6P (current)

MX-6 (1F4&6) *2 MX-6P (new) *3 Chapter II-D Shielding analysis D.1 Summary Assumption for surface contamination Main shielding parts Followings are added Consideration of contamination due to rubble Operational criteria applied to measurement of dose equivalent rate on surface of fuel assembly No change from current D.2 Source specification (1) Source derived from fuel composition Fuel composition and source analysis specification

Å (except differences due to fuel assembly)

No change from current

[MX-6P]

(2) Surface contamination with pool water Radioactive materials contained in poot water No change from current

[MX-6]

(2) Sources derived from fuel assembly surface contamination Nuclides of contamination contained in rubble D.2.1 Gamma sources (1) Source derived from fuel composition Gamma source intensity related to fuel composition

Å (except differences due to fuel assembly)

No change from current

[MX-6P]

(2) Surface contamination with pool water Assumption of activity in pool water and amount of pool water on assembly No change from current

[MX-6]

(2) Sources derived from fuel assembly surface contamination Nuclides of contamination contained in rubble Source intensity based on the operational criteria D.2.2 Neutron sources Negligible

Å No change from current D.3 Model specification D.3.1 Analysis model Analysis model Modeling for components of packaging and fuel assembly

Å (except differences due to basket and/or contents)

No change from current D.3.2 Atomic number density in each region of analysis model Atomic number density

Å (except differences due to basket and/or contents)

No change from current D.4 Shielding evaluation (1) Shielding evaluation method (2) Calculation results Analysis code Calculation results

Å (except differences due to basket and/or contents)

No change from current D.5 Summary of results and evaluation Conclusion of analysis Summary of results

Å (except differences due to basket and/or contents)

No change from current D.6 Appendix D.6.1 Appendix-1 Surface contamination of fuel assembly (Not described)

Detail information and study concerning contamination of fuel assembly from rubble and pool water No change from current D.6.2 Appendix-2 Setting of source intensity for surface contamination of fuel assembly (Not described)

Setting of source intensity by contamination and the operational criteria based on shielding calculation of a fuel assembly No change from current D.6.3 Appendix-3 Amounts of activity of nuclides of contamination per packaging (Not described)

Maximum possible activity contained in package due to contamination and comparison with A2 values No change from current D.6.4 Appendix-4 Conservativeness of shielding analysis model (Not described)

Evaluation for conservativeness of analysis model of package No change from current

• 1: Subsections or items are based on the MX-6(1F4&6) SAR *2: Items indicated by blue color letter are incorporated to new SAR. *3: Differences between MX-6P current and new are indicated by red color letters.



Table-3 Comparison of SAR among MX-6 and MX-6P packages (9/12)

Chapters Sections Subsections / Items *1 Comparison of SAR (descriptions for evaluation)

Remarks MX-6P (current)

MX-6 (1F4&6) *2 MX-6P (new) *3 Chapter II-E Criticality analysis E.1 Summary Analysis code, Summary of damage conditions and modeling and analysis conditions, Conclusion

Å No change from current E.2 Analysis items E.2.1 Contents Major specification of PWR fuel assembly Assumption of modeling of PWR fuel assembly Major specification of BWR fuel assembly Assumption of modeling of BWR fuel assembly No change from current E.2.2 Packaging Damage conditions of packaging

Å No change from current E.2.3 Neutron poison 10B content of stainless steel of basket material

Å No change from current E.3 Model specification E.3.1 Analysis model Shape of analysis model Components consisting of model Assumptions on modeling

Å (except differences due to basket and contents)

No change from current E.3.2 Atomic number density in each region of analysis model Atomic number density

Å (except differences due to basket and contents)

No change from current E.4 Subcriticality evaluation E.4.1 Calculation conditions Modeling for fuel rod pitch

Å (except differences due to contents)

No change from current (1) Contents (2) Packaging Assumption for axial length and components ignored

Å No change from current (3) Neutron poison Consumption of 10B

Å Reference of Appendix showing the evaluation (Chap. II-F Appendix-1)

Å Additional description E.4.2 Leakage of water into nuclear fuel package Assumption for leakage of water into package and boundary condition of outside of package Effect of packing materials

Å (except differences due to contents)

No change from current E.4.3 Calculation method System of analysis code applied (SCALE version 6.2.3)

Å (except SCALE version (6.1))

No change from current E.4.4 Calculation results Effective multiplication factors

Å (value is different)

No change from current E.5 Bench mark test Summary and conditions and results of bench mark test

Å (except results due to SCALE version)

No change from current E.6 Summary of results and evaluation Required conditions and conclusion

Å No change from current E.7 Appendix E.7.1 Appendix-1 Damaged condition of packages and modeling for criticality analysis Details of damaged condition of package and modeling and complementary explanation

Å (except differences due to basket and contents)

No change from current E.7.2 Appendix-2 Evaluation of effect of fuel rod pitch

[Appendix-4]

Parameter calculation for fuel rod pitch

Å (except conditions and results due to differences of basket and contents)

No change from current E.7.3 Appendix-3 Evaluation of effect of water density in space inside/outside packaging

[Appendix-2]

Parameter calculation for water density in space inside/outside packaging

Å (except conditions and results due to differences of basket and contents)

No change from current

• 1: Subsections or items are based on the MX-6(1F4&6) SAR *2: Items indicated by blue color letter are incorporated to new SAR. *3: Differences between MX-6P current and new are indicated by red color letters.



Table-3 Comparison of SAR among MX-6 and MX-6P packages (10/12)

Chapters Sections Subsections / Items *1 Comparison of SAR (descriptions for evaluation)

Remarks MX-6P (current)

MX-6 (1F4&6) *2 MX-6P (new)

Chapter II-E Criticality analysis E.7.4 Appendix-4 Effective multiplication factor with deformation of inner shell and aluminium spacer taken into account

[Appendix-5]

Calculations by models considering deformations of inner shell and aluminum spacer due to 1m drop

Å (except conditions and results due to differences of basket and contents)

No change from current E.7.5 Appendix-5 Effective multiplication factor with inner shell expansion taken into account

[Appendix-3]

Calculation by model considering deformation of inner shell with expansion of diameter

Å (except conditions and results due to differences of basket and contents)

No change from current E.7.6 Appendix-6 Consideration for additional shielding and tie rod in analysis model (Not described)

Comparison calculation between with and without additional shielding and tie rod (only for BWR basket)

No change from current E.7.7 Appendix-7 Effect of packing materials on effective multiplication factor

[Appendix-6]

Parameter calculation for packing material density

Å (except conditions and results due to differences of basket and contents)

No change from current

• 1: Subsections or items are based on the MX-6(1F4&6) SAR *2: Items indicated by blue color letter are incorporated to new SAR. *3: Differences between MX-6P current and new are indicated by red color letters.

Chapters Sections Subsections / Items *1 Comparison of SAR (descriptions for evaluation)

Remark MX-6P (current)

MX-6 (1F4&6) *2 MX-6P (new) *3 Chapter II-F Consideration of aging of nuclear fuel package F.1 Factors of aging to be considered (Not described)

Assuming duration of use and temperature and number of cyclic load Factors of aging to be considered (Heat, radiation, chemical change, fatigue)

Å New description F.2 Evaluation for necessity of consideration of aging on safety analysis Table II-F.1 Materials to be evaluated

Å (Materials of basket and contents are different)

New description (Materials of MX-6P are covered by MX-6)

Table II-F.2 Evaluation for necessity of consideration of aging

Å (Materials of basket and contents, and source condition are different)

New description F.3 Considerations of aging on safety analysis Conclusion of evaluation for necessity of consideration of aging

Å (except differences due to basket and contents)

New description F.4 Appendix F.4.1 Appendix-1 Neutron irradiation and loss ratio of boron Calculation of neutron irradiation and loss ratio of 10B in resin or borated stainless steel

Å (except difference due to weight of uranium)

New description F.4.2 Appendix-2 Weight loss of resin Calculation of weight loss of resin against period of use

Å New description F.4.3 Appendix-3 Strength degradation of aluminum alloys Calculation of strength degradation of aluminum alloys against period of use

Å (except difference due to basket materials)

New description F.4.4 Appendix-4 Fatigue strength of fuel can against variation of internal-external pressure difference during transport Calculation of fatigue strength of fuel can against variation of internal-external pressure difference during transport (Not applicable because of no fuel can is used)

• 1: Subsections or items are based on the MX-6(1F4&6) SAR *2: Items indicated by blue color letter are incorporated to new SAR. *3: Differences between MX-6P current and new are indicated by red color letters.



Table-3 Comparison of SAR among MX-6 and MX-6P packages (11/12)

Chapters Sections Subsections / Items *1 Comparison of SAR (descriptions for evaluation)

Remarks MX-6P (current)

MX-6 (1F4&6) *2 MX-6P (new)

Chapter II-G Evaluation of compliance to the Ordinance and the Notification Table II-G.1 Evaluation of compliance with the technical standards of the Ordinance and the Notification

[Chapter II-F]

Not only results but also outline of contents (condition and method) of each analysis are summarized Not only results but also outline of contents (condition and method) of each analysis are summarized including for Chap. II-F and fatigue evaluations

Å (except differences results of evaluations)

Additional description (Summary of Chap. II-F and fatigue evaluations and a note of change of contents specification)

• 1: Subsections or items are based on the MX-6(1F4&6) SAR *2: Items indicated by blue color letter are incorporated to new SAR. *3: Differences between MX-6P current and new are indicated by red color letters.

Chapters Sections Subsections / Items *1 Comparison of SAR (descriptions for evaluation)

Remarks for MX-6P MX-6P (current)

MX-6 (1F4&6) *2 MX-6P (new) *3 Chapter III Maintenance of packaging and handling procedure of nuclear fuel package III-A Handling procedure of nuclear fuel package (1) Preparation of the packaging and preliminary work Sequence of operations on;

- Fuel assembly

- Lifting devices

- Packaging Sequence of operations on;

- Lifting devices

- Packaging No change from current A.1 Loading operation (2) Preparation of the contents and inspection (Not described)

Sequence of operations on;

- Fuel assembly No change from current (3) Fuel loading operation Sequence of operations on;

- Packaging

- Fuel assembly Sequence of operations on;

- Packaging

- Fuel assembly

- Fuel can No change from current (4) Installation of shock absorbing covers Sequence of operations on;

- Shock absorbing covers

Å No change from current A.2 Inspection before shipment

1. Visual inspection Content of visual inspection

Å No change from current

2. Dose rate inspection Content of dose rate inspection

Å No change from current

3. Subcriticality inspection Content of subcriticality inspection

Å No change from current

4. Lifting inspection Content of lifting inspection

Å No change from current

5. Weight inspection Content of weight inspection

Å No change from current

6. Contents inspection Content of contents inspection Content of contents inspection including dose rate measurement for fuel assembly No change from current

7. Surface contamination inspection Measurement of contamination of package

Å No change from current A3 Unloading method (1) Preparation Sequence of operations on;

- Lifting devices

- Packaging

Å No change from current (2) Fuel unloading Sequence of operations on;

- Packaging

- Fuel assembly Sequence of operations on;

- Packaging

- Fuel assembly

- Fuel can No change from current A.4 Preparation of empty packaging Operations for checking integrity of packaging Operations for checking integrity of packaging including operation for fusible plug, pressure regulation valve and bolts

Å Additional description

• 1: Subsections or items are based on the MX-6(1F4&6) SAR *2: Items indicated by blue color letter are incorporated to new SAR. *3: Differences between MX-6P current and new are indicated by red color letters.



Table-3 Comparison of SAR among MX-6 and MX-6P packages (12/12)

Chapters Sections Subsections / Items *1 Comparison of SAR (descriptions for evaluation)

Remarks for MX-6P MX-6P (current)

MX-6 (1F4&6) *2 MX-6P (new) *3 Chapter III Maintenance of packaging and handling procedure of nuclear fuel package III-B Maintenance conditions Interval and contents of periodical inspections

Å No change from current B.1 Visual inspection Content of visual inspection

Å No change from current B.2 Pressurized inspection Content of pressurized inspection

Å No change from current B.3 Leak tightness inspection Content of leak tightness inspection

Å No change from current B.4 Shielding inspection Content of shielding inspection

Å No change from current B.5 Subcriticality inspection Content of subcriticality inspection

Å No change from current B.6 Thermal test Not applicable

Å No change from current B.7 Lifting inspection Content of lifting inspection

Å No change from current B.8 Workability inspection Not applicable

Å No change from current B.9 Maintenance of subsystem Not applicable

Å No change from current B.10 Maintenance of valve and gasket of containment system Content of maintenance of baskets

Å No change from current B.11 Storage of packaging Content of storage of packaging

Å No change from current B.12 Storage of record Content of storage of record

Å No change from current B.13 Miscellaneous Not applicable

Å No change from current

• 1: Subsections or items are based on the MX-6(1F4&6) SAR *2: Items indicated by blue color letter are incorporated to new SAR. *3: Differences between MX-6P current and new are indicated by red color letters.

to E-64719 MX-6P Safety Analysis Report (Proprietary version)

Sent as separate enclosure

to E-64719 MX-6P Safety Analysis Report (Public version)

Sent as separate enclosure

to E-64719 Maintenance activities applied to MX-6P packaging

Maintenance activities applied to MX-6P packaging This material presents maintenance activities applied to MX-6P packaging so that the packaging components are capable of performing their requisite safety functions throughout the period of use. The maintenance activities are explained from the following viewpoints.

- Inspection methods for detection of corrosion

- Inspection equipment and personnel qualification requirements

- Visual criteria for detection of aging effects

- Surface cleaning requirements

- Flaw evaluation methods

1. Inspection methods for detection of corrosion For stainless steel components which surfaces are exposed to outdoor air environments, MNF will add the inspection shown in the Table-1 into the internal procedure of the periodical inspection to consider possible defects due to localized corrosion effect. In addition, the inspection for alloy steel bolts is included.

Table-1 Inspection method applied to MX-6P packaging Type of inspection Inspection method Acceptance criteria Visual inspection (Detection of corrosion)

1. For external surface of the body (Top flange, trunnion, outer envelope and bottom), the handling belts and the shock absorbing covers, visual appearance shall be inspected visually.

1. There is no corrosion (pitting corrosion, crevice corrosion, and stress corrosion cracking) that might affect integrity of the component performance.

2. For surface of the tightening bolts (Lid and shock absorbing covers), visual appearance shall be inspected visually.

Note)

Inspected surfaces of the packaging shall be clean to make sure visibility of any kind of defect. And appropriate brightness shall be given.

2. There is no damage of the plating and no corrosion.

2. Inspection equipment and personnel qualification requirements MNF will add requirements to the internal procedure of the periodical inspection to clarify the conditions for visual inspection to be considered.

For these additional requirements concerning illumination, access of testing and personnel qualification, national and international codes will be referred and similar conditions will be specified in the procedure. The conditions mentioned in the reference codes are shown in the Table-2.

Table-2 Conditions for Visual Inspection Given by Reference Codes Conditions Requirements Reference Codes Illumination The illuminance at the surface with white light shall be a minimum of 350 lx; wearing of tinted goggles (e.g. protective sunglasses) increases the minimum illuminance. However, 500 lx is recommended.

JIS Z3090 ISO 17637 Access to testing (direct inspection)

The access shall be sufficient to place the eye within 600 mm of the surface to be examined and at an angle not less than 30° (see Figure 1). An auxiliary tool such as a mirror is used as necessary.

Figure-1 Access for Testing JIS Z3090 ISO 17637 Surface cleanliness The surface shall be free from contamination before visual inspection. If contamination is present, cleaning shall be carried out before inspection.

(N/A)

Personnel a) be familiar with relevant standards, rules, specifications, equipment and procedures /

instructions; b) be familiar with the relevant manufacturing procedure used and/or with the operating conditions of the component to be tested; c) have satisfactory vision in accordance with JIS Z 2305 (ISO 9712).

EN 13018 JIS Z 2305 ISO 9712 JIS Z3090: Visual testing method of fusion-welded joints JIS Z2305: Non-destructive testing-Qualification and certification of NDT personnel ISO 17637: Non destructive testing of welds - Visual testing of fusion-welded joint ISO 9712: Non-destructive testing - Qualification and certification of NDT personnel EN 13018: Non-destructive testing - Visual testing - General principle Range

3. Visual criteria for detection of aging effects For detection of aging effect, acceptance criteria shown in the Table-1 are referred as the visual criteria.

4. Surface cleaning requirements MNF will add the following requirement to the internal procedure related to storage of packaging.

- The outer surface of packaging shall be cleaned between the completion of transport and the next transport.

MNF will add the following requirement to the internal procedure of the periodical inspection.

- The surface shall be free from contamination before visual inspection. If contamination is present, cleaning shall be carried out before inspection. (See the Table-2)

5. Flaw evaluation methods As basic policy, defects found during visual inspection are treated as follows.

- Defects in welds Defects identified in welds (crack, pits, craters), regardless of their size, must be repaired in any case because they affect the structural integrity of the package. This is similar to CODAP code* where planar defects, cracks and pores at surface are not permitted.

- Discolouration If there is discolouration on the weld or base metal that is suggestive of corrosion, first check whether it is only on the very surface. If the discolouration disappears after polishing with Scotch-Brite or similar, no repair is necessary. If the discolouration is not removed and it is suspected that corrosion has penetrated with a certain depth, necessary treatment including repair is analyzed and applied.

- Defects on tightening bolts If plating of bolt is damaged and corrosion protection could be lost, this bolts is replaced.

Note)

• CODAP code: Code for Construction of unfired Pressure Vessel Requirement : CODAP 2005 Division 2 Part 1 Testing and Inspection Annex I 1 Visual examination

to E-64719 MX-6P Quality Management Method

MX-6P Quality Management Method Explanation concerning quality management method etc.

for packaging (relating to design only)

(English translation)

According to The Notification Article 41 Item 2 No. 12

I-1 Chapter I Explanation on quality management method etc. for packaging (relating to design only)

I-A Quality management system Mitsubishi Nuclear Fuel Co.,Ltd (hereinafter referred to as MNF) shall establish and maintain the quality management system based on ISO9001:2015 to ensure the conformity with the customers requirements and regulatory technical standards.

A.1 Quality manual (1)

Quality manual The quality manual is a first-tier document in the QMS documentation system that documents the requirements of ISO9001(2015). It provides for the clarification of quality policy and quality objectives, and clarifies the standards of practice for quality assurance activities required at each stage of the procurement, design, fabrication, use (including handling), maintenance, etc. of transportation containers.

The Safety and Quality Assurance Department shall prepare, issue and revise a quality manual under the quality policy decided by the president (&CEO).

(2)

Quality assurance program The Safety and Quality Assurance Department and the related departments shall establish and document quality assurance programs concerning design, fabrication, procurement, use (including handling), maintenance, etc. of the packaging considering the following items properly based on the quality manual. In addition, it shall ensure that the packaging conforms to the customers requirements, regulatory technical standards, design specification in the application for the design approval, fabrication methods in the application for the packaging approval, etc. Procedures and other documents issued by the Safety and Quality Assurance Department, the Manufacturing Department, the Procurement Department, the General Affairs Department and the Transportation and Service Department shall constitute the quality assurance programs.

(a)

Each related department shall clarify respective responsibility for management of design, fabrication, procurement, use, maintenance, etc. of the packaging. The Transportation and Service Department shall reasonably carry out part of work of design, fabrication, use, maintenance, etc. of the packaging by receiving supplies of services from professional companies with appropriate quality management systems as needed.

(b)

The Transportation and Service Department shall establish and implement inspection procedures concerning fabrication and performance retention of the packaging to verify fabrication and maintenance of the packaging at appropriate stages of the work. In addition, the Transportation and Service Department shall provide the requirements from MNF for the inspection to the packaging manufacturer, etc. if the inspection is conducted based on the inspection procedures prepared by the packaging manufacturer, etc., and review that the requirements from MNF are reflected appropriately in the inspection

I-2 procedures prepared by the packaging manufacturer, etc., and approve the procedures.

The departments shall verify that the manufacturer has conducted inspections according to the procedures.

(c)

Each department shall prepare effective procedures (procedures, manuals, and instructions) according to the quality assurance programs and perform quality assurance activities according to the procedures. The extent provided in the procedures, etc. and the level of their details shall be determined depending on operation complexity, operation methods, and skill and extent of training of a worker who carries out the operation.

(d)

The Safety and Quality Assurance Department shall clarify quality records affecting quality concerning design, fabrication, procurement, use, maintenance, etc. of the packaging and define procedures for documentation and storage of the quality records.

(3)

Quality policy and quality objectives (a)

Quality policy The president (&CEO) shall establish the following as quality policy:

< Quality policy for products >

Mitsubishi Nuclear Fuel Co.,Ltd. continuously challenges ourselves, placing top priority on safety, to maintain and improve QUALITY, COST and DELIVERY for our customers and for the future of our country as a member of the MHI Group, based on its corporate philosophy, management policies and the employees code of conduct.

(1) Safety First We foster an organization culture where it innovates and changes to an autonomous organization and people can have casual discussion, properly understanding the impact of our products and activities on nuclear safety, and placing top priority on ensuring all of safety for nuclear energy according to not only laws, regulations and standards but also social norms and ethics.

(2) Continuous Improvement We continuously improve our quality management system for sustainable growth with responding to expectation of the society and customers in a prompt and flexible manner.

(3) Customer Value Creation We increase customer satisfaction and create new value by providing safe and reliable products and services that exceed expectations based on an accurate understanding of social trends and customer preferences.

(4) Maintaining and Strengthening Basis We maintain and strengthen core technologies, human resources and facilities that support a basis of product quality, and strengthen bases including supply chains that support quality.

The president (&CEO) is responsible for assigning as an executive officer as a quality

I-3 control officer, distributing required resources and developing the quality management system, to ensure achievement of the above quality policy.

(b)

Quality objectives Each involved department manager shall set quality objectives with an evaluable attainment level, evaluate the status of the achievement and be approved by a management representative as a process for continuous improvement of the quality management system for quality objectives in order to achieve the quality policy.

(4)

Management review The president (&CEO) shall hold regular management review meeting to confirm that the quality management system meets the quality policy and quality objectives and is operated effectively, and to review the quality management system.

The management review shall be conducted for the following items.

1. Results of internal audit and external audit

2. Customer feedback

3. Process performance, product conformity and quality trend

4. Non-conformities and corrective actions

5. Implementation status of activities to foster safety culture

6. Follow-up actions from previous management review meeting

7. Changes that could affect the quality management system

8. Others A.2 Document control (1)

Scope of documents and data control The scope of control shall be applied to documents and data concerning packaging quality.

The documents to be controlled are contract specifications, drawings, order specifications, quality assurance programs, operation procedures, inspection procedures including quality manuals. They also include external documents of official standards such as JISs.

(2)

Approval and publication of documents and data

1. Appropriateness of documents and data shall be discussed and approved by the authorized representatives of each department who are entrusted with the discussion and the approval by each department head prior to their publication.

When the packaging structure is changed and the change has some influence on the use or the operation, the order specifications, etc. shall be reviewed by the related departments.

2. The current version of each document shall be controlled by a register ensuring the following:

(a)

Use of appropriate documents/versions (b)

Disposal of invalid and/or obsolete documents (c)

Appropriate identification of obsolete document to be retained

I-4 (3)

Changes of documents and data

1. Identification of extent affected by changes (a) Systematization of documents concerning fabrication specification of the packaging (b) When there are changes in a higher document, the presence or absence of the influence shall be confirmed sequentially on the basis of the above systematization of documents to ensure that the changes are reflected in a lower document. In case there is some influence on the fabrication specification of the packaging as a result of confirmation, a notification of changes shall be submitted to the packaging owner or the packaging manufacturer to instruct them to confirm the presence or absence of the influence.

2. Implementation of changes (a) When a document has an influence of changes, the document shall be listed and follow-up shall be conducted to issue the revised version.

(b) Any changes of documents and data shall be implemented in accordance with the same procedure as when the documents and data are issued.

(c) Each involved department shall provide supporting evidences to checkers and approvers to change the documents and data. In addition, the details of the changes shall be identified in the document or its attachment.

(d) The revised version of the documents which require changes shall be issued as soon as possible so that the lower documents can be revised and issued sequentially as necessary.

In addition, when there is some influence on a fabrication specification of the packaging, the packaging owner or the packaging manufacturer shall be instructed to revise the corresponding documents and submit the revised version.

A.3 Control of quality records (1)

Types of quality records Each department shall identify the scope of records to be controlled by reference to the following representative documents.

Records of management review Quality documents (quality assurance programs, standards, procedures, etc.)

Review records of contract Order specifications, drawings, etc.

Inspection records (inspection during fabrication, periodical voluntary inspections, inspections before shipment)

Audit records (for internal and the suppliers)

Nonconformance reports and corrective action reports Education and training records (2)

Storage of quality records

1. Quality records shall be legible, and stored in an environment suitable to prevention of their deterioration, damage and loss.

2. Quality records shall be retained in an easily-retrievable condition.

I-5

3. The storage period of quality records shall be identified.

(3)

Disposal of quality records Each department in charge shall dispose of quality records after storage periods. Quality records shall be incinerated or shredded.

I-B Responsibility of applicants Figure I-1 shows a diagram of a quality assurance system concerning design, fabrication, procurement, maintenance, etc. of the packaging. MNF submits an order for fabrication of the packaging through the packaging owner or directly to the packaging manufacturer evaluated as having sufficient supplying capacity, under MNFs responsibility. Services for a part of maintenance and maintenance control of the packaging are outsourced to maintenance companies that have sufficient supplying capacity, as needed.

MNFs quality assurance organization is shown in Figure I-2. Work and responsibility of each department in MNF is described below. The final responsible person for the activities in each department shall be the corresponding general manager.

(1)

President and CEO The president (&CEO) shall have responsibility and authority for the following items.

1. Establishment of organization with clear responsibility and authority of each position involved in quality assurance, and proper assignment of management resources such as budget, personnel, equipment, etc. to ensure quality meeting requirements of the customer.

2. Setting and documentation of quality policy.

3. Appointment of a management representative and assignment of his/her responsibility and authority for quality assurance activities.

(2)

Quality control officer (Executive officer)

An executive officer appointed by the president (&CEO) will be a quality control officer and have responsibility and authority for the following items regardless of other responsibility.

1. Establishment and promotion of quality assurance programs.

2. Overall responsibility for quality including the following five items and assessment for validity and effectiveness of the quality assurance programs. Appropriate actions taken when any improvement is required.

(a)

Implementation of actions to prevent nonconformance regarding products, processes and quality management systems.

(b)

Clarification and records of the problems related to products, processes and quality management systems.

(c)

Search, recommendation and offer of a solution in a specified manner.

(d)

Verification of implementation of the solution.

I-6 (e)

Suspension of delivery of nonconformance products to the next process until the nonconformance is corrected.

3. Reports to the president (&CEO) on the implementation for the above items in 1 and 2 and need for their improvement.

4. Promoting to each organization to enhance its recognition of importance of meeting requirements of the customer.

(3)

Safety and Quality Assurance Department The Safety and Quality Assurance Department shall be independent of other departments in the organization and have responsibility and authority for the following items.

1. Planning and implementation of quality management systems.

2. Implementation of internal quality audits and instructions of corrective actions.

3. Coordination of evaluation and certification of the packaging suppliers.

4. Implementation of quality audits and instructions of corrective actions to the packaging suppliers.

5. Approval of nonconformance reports and approval of operation stop instructions, corrective and preventive actions when needed.

6. Implementation of education and training.

7. Approval of reports and corrective actions on nonconformance of a packaging observed in the process of product packing, on-site inspections, UF6 cylinder cleaning, retests, evaporation and storage (hereinafter referred to as usage step).

8. Confirmation of procurement management records (4)

Transportation and Service Department The Transportation and Service Department shall have responsibility and authority for the following items.

1. Application services for a license related to the packaging.

2. Inspection prior to shipment of the package (including service procurement) and application for confirmation on transportation.

3. Receiving of the packaging and check of its expiration date.

4. Maintenance control of the packaging (including service procurement).

5. Preparation of nonconformance reports and consideration of corrective and preventive actions.

6. Implementation of education and training.

7. Packaging control at a usage step (except for control by the Manufacturing Department).

8. Confirmation of contract details related to the design.

9. Evaluation of the packaging suppliers technical capability.

10. Preparation of order specifications related to the packaging design.

11. Examination and approval of design documents such as drawings and analysis documents

I-7 related to the packaging design.

12. Preparation of attachments for a license application related to the packaging.

13. Preparation of design and quality requirements and order specifications related to fabrication of the packaging.

14. Approval of application documents for the fabrication (drawings for fabrication, inspection procedures, etc.).

15. Inspections related to fabrication of the packaging.

16. Preparation of order specifications related to the packaging components and implementation of inspections.

(5) Manufacturing Department The Manufacturing Department shall have responsibility and authority for the following items.

1. Cleaning of uranium hexafluoride cylinders

2. 5-year periodic inspection (hereinafter referred to as retest) for uranium hexafluoride cylinders.

3. Uranium hexafluoride cylinder control at a usage step (storage and evaporation process)

4. Packaging control at a usage step (product packing)

(6)

General Affairs Department The General Affairs Department shall have responsibility and authority for the following items.

1. Management of education/training programs.

2. Management of personnel.

(7)

Procurement Department The Procurement Department shall have responsibility and authority for the following items.

1. Signing contracts.

2. Order concerning design, fabrication and procurement of the packaging and its components.

3. Order concerning usage and maintenance of the packaging.

(8)

Business Plan and Process Re-engineering Department The Business Plan and Process Re-engineering Department shall have responsibility and authority for the following items.

1. Confirmation of customer requirements for the packaging.

I-8 Figure III.1: Quality system of design, fabrication, procurement, maintenance of the packaging (Offer of services)

(Commission)

M N F (Applicant)

[Packaging quality final confirmation on the basis of the requirements of ISO9001]

(Witnessed inspections and audit) (Note 3)

(Order of packaging)

(Quality records)

(Order of materials /parts)

(Quality records)

(Witness inspections and audit)

(Note 3)

Offer of design and quality requirements Quality records (Note 1) Omit the box of Packaging Owner when MNF orders the packaging directly.

(Note 2) Only when new packaging is fabricated.

(Note 3) To be implemented as needed.

(Witnessed inspections and audit) (Note 3)

M a i n t e n a n c e C o m p a n y o f P a c k a g i n g Supply of services for a part of inspection and maintenance of packaging Packaging Manufacturer Fabrication of the packaging complying with the requirements of ISO9001 Subcontractor Offer of materials/parts complying with the requirements of the packaging manufacturer Design Contractor Packaging design conforming to design requirements Packaging Owner (Note 1)

Compliance with the requirements of ISO9001 and order of the packaging (Confirmation of records)

(Witnessed inspections and audit)

(Witnessed inspections and audit) (Note 2)

(Design document Order

I-9 Figure III.2: Organization of MNF packaging quality Safety and Quality Assurance Department Product Quality Management Review Meeting President and CEO Quality control officer (Executive Officer)

Transportation and Service Department General Affairs Department Business Plan and Process Re-engineering Department Manufacturing Department Procurement Department

I-10 I-C Education and training Necessary education and training programs shall be planned and implemented for personnel involved in services affecting quality concerning the packaging to their needs. Similarly, it shall be confirmed that such education and training programs are implemented for the packaging manufacturer, etc.

(1) Implementation outline The followings shall be implemented for personnel involved in services affecting the packaging quality.

1. Periodical evaluation of competence of the personnel, establish objectives for competence, and planning of education and training for objective.

2. Periodical evaluation of effectiveness on the implemented education and training programs, and storage of their records.

3. Requiring packaging manufacturers to determine the necessary competence of persons doing work and to implement needed education and training according to the quality assurance program..

I-11 I-D Design control The following items shall be conducted to ensure that the packaging design conforms to the design requirements.

D.1 Design control for commission to outside the company (1)

Design control (a)

When the Transportation and Service Department concludes a contract with a packaging design contractor (hereinafter referred to as designer), the order specification shall include design specifications based on the customers requirements, regulatory technical standards, performance and functional requirements, etc. and be provided to the designer.

(b)

When employing new design and technology or special materials, the Transportation and Service Department shall promote exchange of information between the designer and material suppliers on relations between safety and the specification and reasons behind the decision of the specification as needed to have the designer fully understand the design requirements.

(c)

The Transportation and Service Department shall examine whether the design requirements are reflected appropriately in design documents (drawings, calculation sheets, analysis documents, etc.) prepared by the designer.

(2)

Design verification The Transportation and Service Department shall examine that the designer has conducted design verification with verification tests and/or alternative calculations, etc. as needed when employing new design and technology or special materials based on the above design results.

(3)

Design change The Transportation and Service Department shall provide the designer. with written details of changes in the design specification.

When the department asks the designer to change or the designer himself changes the design due to the changes in the design specification, it shall be examined whether the design requirements are reflected appropriately in design documents (drawings, calculation sheets, analysis documents, etc.) prepared by the designer for approval. In addition, the Transportation and Service Department shall inform the involved organizations with the written details of the design changes.

D.2 Design control for in-house design (1)

Design plan The packaging shall be designed by summarizing the design requirements for the packaging based on the long-term transportation plan of packages.

(2)

Input into design

I-12 Details of the requirements for the packaging shall be confirmed. To design the packaging, the Transportation and Service Department shall document design input information including written design preconditions, applicable laws/rules and other requirements and confirm that the requirements are appropriate based on the confirmation results of the requirements for the packaging. The design shall be reviewed and input based on the information obtained from a previous similar design, if applicable. The input information shall be recorded.

(3)

Output from the designer Output of packaging design (specifications, drawings, test/inspection procedures, etc.) shall satisfy the requirements for safety required for the packaging, interface between the packaging and its transportation methods, applicable laws/rules and safety analysis documents, which shall be approved by the Transportation and Service Department. Further, design requirements, acceptance/rejection criteria and characteristics of fabrication, handling and inspections shall be incorporated in output information.

(4)

Design review Output of the packaging design shall satisfy the requirements. Problems detected as a result of the review shall be identified to take appropriate actions. A person in charge of other work shall be assigned for review in addition to the involved person in charge (the designer) as required.

(5)

Design verification The Transportation and Service Department shall verify that the output from the packaging designer satisfies the requirements provided by input to the packaging design. The verification results shall be recorded.

(6)

Design validation The Transportation and Service Department shall conduct the design validation to ensure that the requirements according to the specified application or the intended application are achieved. The validation results shall be recorded.

(7)

Management of design changes (a) Management of design changes The Transportation and Service Department shall identify and document design changes to review their details.

When the details of the design changes can affect the supplier, the Transportation and Service Department shall notify the written details of the design changes to those involved.

(b) Management of changes in specification

I-13 The Transportation and Service Department shall identify the changes in the specification at the stage of packaging fabrication, and review, verify and validate the plan documents considering any effects on other specifications. The changes in the specification shall be recorded.

I-14 I-E Production order of packaging The following items shall be conducted to ensure that the packaging conforms to the customers requirements, regulatory technical standards, design specification in the application for the design approval, its fabrication methods in an application for the packaging approval, etc.

1.

Evaluation of the packaging manufacturer The manufacturing capability of the packaging shall be evaluated considering the following items on the responsibility of the Safety and Quality Assurance Department.

(a)

Technology, personnel and manufacturing facility related to manufacturing of the packaging (b)

Quality policy, quality assurance programs and their implementation of the packaging owner and the packaging manufacturer (c)

Supply history of the packaging or similar products (d)

Usage history of the packaging or similar products and their quality records (e)

Evaluation of prototypes, samples, etc. (in case of no similar products)

2.

Requirements for quality management systems toward the packaging manufacturer When placing a fabrication order to the packaging owner or the packaging manufacturer, the Transportation and Service Department shall clearly instruct in specifications and make them fulfill the following requirements on the responsibility of the Transportation and Service Department.

(a)

Scope of service for the packaging owner or the packaging manufacturer (b)

Technical requirements for design, fabrication, inspections, applicable laws, etc.

(c)

Requirements for submission of quality assurance programs (d)

Requirements for access to sites of the packaging manufacturer for quality audits and inspections (e)

Requirements for submission and storage of documents and records (f)

The packaging manufacturer shall establish and implement quality control programs specifying organization and procedures for quality control of the products ordered by MNF.

The quality control programs shall conform to section III. Quality management details conducted by packaging manufacturers, of the Quality management guideline of packaging fabrication method (annex of the Nuclear Regulation Authoritys application procedure guide for design approval and packaging approval for nuclear fuel material transport, enacted on February 26th, 2020 as Regulation ordinance No.2002264 and amended on November 18th, 2020 as Regulation ordinance No.2011188).

When the packaging manufacturer places an order for part of the packaging structure with its subcontractors, the quality management system requirements toward the subcontractors shall be included in the quality control programs of the packaging manufacturer.

I-15 (g)

MNF and regulatory authority staff shall conduct inspections during fabrication and quality control checks of the packaging at the sites of the packaging owner, the packaging manufacturer and their subcontractors.

(h)

MNF shall examine and approve criteria for selection of the packaging manufacturer by the packaging owner.

Or, MNF shall examine and approve criteria for selection of the packaging manufacturer and its subcontractors and also check the selection criteria.

(i)

The responsibility among service providers involved in fabrication of the packaging shall be identified by written agreements.

(j)

Adequate understanding for values of safety important material specification provided by MNF and their meanings shall be given to the packaging owner, the packaging manufacturer and their subcontractors.

(k)

Exchange of information and technical study for execution, analyses, inspection methods of manufacturing among service providers involved in fabrication of the packaging shall be promoted when employing special materials with more safety importance.

(l)

Arrangements of operation instructions and delivery shall be identified to establish a close connection in the process where several providers are involved in fabrication of the packaging.

(m) When the packaging with nonconformance will be repaired, written notification shall be given to MNF to receive their instructions.

In addition, procedures for corrective actions shall be established and retained to prevent its recurrence.

(n)

Conditions of special processes for the packaging manufacturer shall be established in procedures. An important change in the fabrication process and any supplier change of the packaging manufacturer and its subcontractors shall be reported to MNF immediately for approval.

(o)

The packaging owner and the packaging manufacturer shall conduct the following items toward their subcontractors.

(i)

Evaluate their subcontractors ability.

(ii) Instruct the subcontractors to comply with the requirements that MNF asked the packaging owner and the packaging manufacturer to meet.

(iii) Verify that the MNF requirements are satisfied by conducting quality audits and inspections on the packaging manufacturer and its subcontractors by the packaging owner and on its subcontractors by the packaging manufacturer.

However, the following cases are not applied to the above requirements.

(i)

Contract work that is approved to be unrelated to inspection items of the packaging license.

(ii) Work under direct control with witness inspections by the packaging manufacturer.

I-16 (iii) Permissible manufacturing according to official standards like JIS and official qualification systems.

(iv) Allowable work only with inspections at the time of acceptance because of simple and general checking items.

When procuring the packaging already fabricated as a whole or in part, the Safety and Quality Assurance Department shall confirm based on records, etc. that the packaging manufacturer conforms to section III. Quality management details conducted by packaging manufacturers, of the Quality management guideline of packaging fabrication method (annex of the Nuclear Regulation Authoritys application procedure guide for design approval and packaging approval for nuclear fuel material transport, enacted on February 26th, 2020 as Regulation ordinance No.2002264 and amended on November 18th, 2020 as Regulation ordinance No.2011188).or has the quality management system (ISO9001, etc.) equivalent to it.

3.

Verification by inspection and quality audit related to packaging fabrication The following items shall be conducted to verify that the packaging conforms to procurement requirements.

(1)

The Safety and Quality Assurance Department shall conduct quality audits as follows to confirm the implementation of the system provided in the quality assurance programs.

Timing of implementation:

At the time when completion inspection for the first fabrication lot becomes ready to be conducted and at the time when fabrication is conducted after three years or more passed from the previous audit.

Audit details:

Process control, identification control, control items concerning inspections and tests, control of subcontractors, control of nonconforming products, corrective actions and statistical method and so on, directly related to fabrication.

Implementation outline:

To prepare an audit notification and send it to an audited organization. To conduct an audit using a check sheet in which necessary items are listed.

The Safety and Quality Assurance Department shall establish audit procedures and audit programs and conduct quality audits according to them.

The department also shall identify quality audits on the subcontractors by the packaging manufacturer and take responsibility for conducting quality audits directly on the subcontractors when the need arises.

I-17 (2)

The Transportation and Service Department shall prepare inspection procedures, etc. considering safety importance, official standards, official qualification systems, special process conditions, quality control of the packaging owner, manufacturer and their subcontractors for witnessed inspections and record check.

When procuring the packaging already fabricated as a whole or in part, the Safety and Quality Assurance Department and the Transportation and Service Department shall conduct additional inspections or re-inspections on the packaging as needed as well as the confirmation of records, etc.

on the status of quality activities at the time of fabrication and inspection results to verify that the packaging was fabricated appropriately.

I-18 I-F Handling and maintenance F.1 Maintenance control (1) The Transportation and Service Department shall prepare procedures that clarify requirements including ones described in the safety analyses report (SAR) and perform periodical inspections and maintenance in accordance with the procedures. As to some of periodical inspections and maintenance services concerning maintenance control of the packaging, the Transportation and Service Department outsources them to maintenance companies with sufficient supplying capacity, if needed.

(2)

Results of periodical voluntary inspections and maintenance shall be retained during a specified period.

(3)

If part of periodical inspection and maintenance service of the packaging is outsourced, the Transportation and Service Department shall check the records of periodical inspections and maintenance of the packaging submitted by outsourcing companies to verify their implementation status.

(4)

When nonconformance products are detected by periodical voluntary inspections and maintenance of the packaging, necessary actions shall be taken according to control, corrective and preventive actions for nonconformance products.

(5)

The Safety and Quality Assurance Department shall confirm the implementation status of the maintenance control of the packaging by conducting periodical internal audit for the Transportation and Service Department.

F.2 Inspection prior to shipment (1)

Before transportation, the Transportation and Service Department shall conduct inspections prior to shipment of packages in accordance with the procedures that clarify the requirements. When a witness check or safety check is conducted by the authorities at departure, the Transportation and Service Department shall be subjected to the check.

(2)

Before transportation, the Transportation and Service Department shall apply for verification of package transport. In the application, it shall confirm that the packaging to be used has been approved and passed the specified periodical voluntary inspections. However, in the case of transportation which does not use the packaging approved beforehand, it shall confirm that the packaging conforms to the details written in the application for verification of package transport.

(3)

Inspection results prior to shipment shall be retained during a specified period.

(4)

When nonconformance products are detected by inspections prior to shipment, necessary actions shall be taken according to control, corrective and preventive actions for nonconformance products.

I-19 I-G Measurement, Analysis and Improvement G.1 Internal Quality Audits Internal quality audits shall be conducted to verify the status and appropriateness of quality assurance activities with respect to MNF activities that affect the packaging quality.

Internal quality audits are conducted as follows.

(1)

The Safety and Quality Assurance Department shall plan internal quality audits based on the status and importance of quality assurance activities. Auditors shall be appointed by those who have been certified in accordance with auditing guidelines.

(2)

In principle, internal quality audits shall be conducted once a year for departments engaged in quality activities.

G.2 Control of nonconforming products (1) Procedures for dealing with nonconforming products When nonconforming products are found at the stage of packaging fabrication, the following procedures shall be implemented to prevent misuse of nonconforming products.

(a) The Transportation and Service Department shall have suppliers report details of the nonconforming products.

(b) The Transportation and Service Department shall communicate with a person who makes the reports and confirm the occurrence.

(c) The Transportation and Service Department, together with the Safety and Quality Assurance Department and related departments, shall review and evaluate the reports from suppliers, decide on actions and give written instructions to suppliers.

(d) The Transportation and Service Department shall conduct a witness inspection or record confirmation as necessary in the event of repair or alteration of the packaging.

(2) Holding of nonconforming products Nonconforming products shall be attached an identification label or physically isolated.

(3) Implementation of necessary actions and Release of Holding Nonconforming products shall be re-inspected before removing the identification label on the nonconforming products after implementation of necessary actions.

(4) Action reports The Transportation and Service Department instructs suppliers to report the following actions.

(a) Confirmation of actions and reporting to relevant internal departments (including departments in charge of quality assurance)

I-20 (b) Submission of action reports on nonconforming products to MNF Action reports of nonconforming products submitted by suppliers shall be submitted to the Safety and Quality Assurance Department via the Transportation and Service Department.

G.3 Corrective actions for Nonconformity and preventive actions (1)

Corrective actions Corrective actions shall be implemented in accordance with the following procedures.

(a)

Investigations of the cause of nonconformity by suppliers, planning recurrence prevention actions by suppliers, reporting to MNF and validation by MNF (i) MNF shall review and check the report from the supplier and instruct to consider the cause investigations and the recurrence prevention actions.

(ii) MNF shall review and evaluate the reports on recurrence prevention actions from suppliers and shall instruct implementation of specific recurrence prevention actions as necessary.

(b)

Implementation of recurrence prevention actions by suppliers, reporting to MNF and validation by MNF (2)

Preventive actions The Safety and Quality Assurance Department shall detect potential causes of nonconformities from the results of general witness inspections, external quality audits, internal quality audits and other nonconformance reports and shall instruct suppliers to implement preventive actions through the Transportation and Service Department. In the case of internal departments, the Safety and Quality Assurance Department instructs the related department to implement preventive actions.