ML26029A330
| ML26029A330 | |
| Person / Time | |
|---|---|
| Site: | 07103104 |
| Issue date: | 11/14/2025 |
| From: | Cheng K US Dept of Transportation (DOT), Office of Hazardous Materials Safety |
| To: | Garcia-Santos N Division of Fuel Management |
| Shared Package | |
| ML26029A328 | List: |
| References | |
| CAC A33010, EPID L-2025-DOT-0001 | |
| Download: ML26029A330 (0) | |
Text
From:
Cheng, Kinwai (PHMSA)
To:
Norma Garcia Santos Cc:
ext_Ryan_Vierling
Subject:
[External_Sender] FW: SUMI-4816 NT-XII Package Revalidation -- Response to RAIs Date:
Friday, November 14, 2025 9:03:36 AM Attachments:
RAIs_NT-XII_Clean.pdf NFK-MPCF-2510001-01_response to RAIs_NT-XII (1)_rev1_ (10.9.25).pdf Affidavit on the proprietary documents (2025_NT-XII_Response to RAI)_sign (10.6.25).pdf Hello Norma,
Attached is the updated RAIs which include the RAI (RAI-ST-3) that they were working on. For simplicity, please disregard my previous email. Let me know if you have any questions.
-Alex
Alex Cheng General Engineer, Division of Sciences, Engineering and Research US Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave SE, Washington, DC 20590 Office: (771)-215-0938
From: Adrian Rony <arony@edlow.com>
Sent: Thursday, October 9, 2025 9:45 AM To: Cheng, Kinwai (PHMSA) <kinwai.cheng@dot.gov>; Andrew Moore <amoore@edlow.com>
Cc: Franchone Oshinowo <foshinowo@edlow.com>; Russell Neely <rneely@edlow.com>; Vierling, Ryan (PHMSA) <ryan.vierling@dot.gov>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation -- Response to RAIs
CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe.
Dear Alex,
Further to our email below, please find attached REV 1 (dated 10.9.25) of responses to ALL RAIs with the corresponding affidavit.
Can you now please confirm that we have provided all that is required for the open RAIs up until this point?
When possible, we would appreciate your confirmation of receipt.
Thank you.
- Regards,
Adrian Rony Edlow International Co.
O: 202-483-4959 D: 202-706-5531 M: 301-651-7262 arony@edlow.com
From: Adrian Rony Sent: Monday, October 6, 2025 9:51 AM To: Cheng, Kinwai (PHMSA) <kinwai.cheng@dot.gov>; Andrew Moore <amoore@edlow.com>
Cc: Franchone Oshinowo <foshinowo@edlow.com>; Russell Neely <rneely@edlow.com>; Vierling, Ryan (PHMSA) <ryan.vierling@dot.gov>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation Importance: High
Dear Alex,
Please find attached responses to the following RAIs along with the corresponding affidavit:
RAI-Ma-1, Ma-2, Ma-3 St-1, St-2, St-4 Op-1
NFI is still working on RAI-St-3 and we will forward their response separately as soon as received.
Can you please confirm that all is in order for what we have provided so far?
Thank you.
- Regards,
Adrian Rony Edlow International Co.
O: 202-483-4959 D: 202-706-5531 M: 301-651-7262 arony@edlow.com
From: Cheng, Kinwai (PHMSA) <kinwai.cheng@dot.gov>
Sent: Thursday, September 25, 2025 5:23 PM
To: Andrew Moore <amoore@edlow.com>
Cc: Franchone Oshinowo <foshinowo@edlow.com>; Russell Neely <rneely@edlow.com>; Adrian Rony <arony@edlow.com>; Vierling, Ryan (PHMSA) <ryan.vierling@dot.gov>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation
Good afternoon Andrew,
Attached is a draft RA for the NT-XII. The NRC has requested Edlow to perform a review of the draft RAI for proprietary and non-proprietary information. Please provide a markup or specify sections (i.e., list) that would contain proprietary information so that DOT can forward this information to the NRC. If you need any clarifications, please feel free to reach out.
Sincerely, Alex
Alex Cheng General Engineer, Division of Sciences, Engineering and Research US Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave SE, Washington, DC 20590 Office: (771)-215-0938
From: Andrew Moore <amoore@edlow.com>
Sent: Wednesday, September 24, 2025 12:43 PM To: Cheng, Kinwai (PHMSA) <kinwai.cheng@dot.gov>
Cc: Falat, Lad (PHMSA) <lad.falat@dot.gov>; Franchone Oshinowo <foshinowo@edlow.com>;
Russell Neely <rneely@edlow.com>; Adrian Rony <arony@edlow.com>; Vierling, Ryan (PHMSA)
<ryan.vierling@dot.gov>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation
CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe.
Dear Alex,
Following our September 10 submission of the affidavit and NFIs remarks, we would like to follow up to confirm the current status of the review.
Could you kindly advise whether DOT/NRC anticipates issuing any additional RAIs for the NT-XII Package?
Thank you for your continued support. Please let us know if you require any additional
information from our side.
- Regards,
Andrew Moore EdlowInternationalCo.
Office: 202-483-4959 Direct: 202-706-5532 amoore@edlow.com
From: Andrew Moore Sent: Wednesday, September 10, 2025 9:33 AM To: 'Cheng, Kinwai (PHMSA)' <kinwai.cheng@dot.gov>
Cc: 'Falat, Lad (PHMSA)' <lad.falat@dot.gov>; Franchone Oshinowo <foshinowo@edlow.com>;
Russell Neely <rneely@edlow.com>; Adrian Rony <arony@edlow.com>; 'Vierling, Ryan (PHMSA)'
<ryan.vierling@dot.gov>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation
Dear Alex,
Please find attached the affidavit for the observations along with NFIs remarks on NRCs preliminary observations, including observation #4. The information provided contains proprietary details, and the affidavit has been prepared accordingly.
Please let us know if you have any comments.
- Regards,
Andrew Moore EdlowInternationalCo.
Office: 202-483-4959 Direct: 202-706-5532 amoore@edlow.com
From: Andrew Moore Sent: Wednesday, September 3, 2025 3:17 PM To: Cheng, Kinwai (PHMSA) <kinwai.cheng@dot.gov>
Cc: Falat, Lad (PHMSA) <lad.falat@dot.gov>; Franchone Oshinowo <foshinowo@edlow.com>;
Russell Neely <rneely@edlow.com>; Adrian Rony <arony@edlow.com>; Vierling, Ryan (PHMSA)
<ryan.vierling@dot.gov>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation
Dear Alex,
Thank you for sending the revised RAI. We will review the document with our Japanese counterpart.
We expect to have their feedback by tomorrow and will update you accordingly.
- Regards,
Andrew Moore EdlowInternationalCo.
Office: 202-483-4959 Direct: 202-706-5532 amoore@edlow.com
From: Cheng, Kinwai (PHMSA) <kinwai.cheng@dot.gov>
Sent: Wednesday, September 3, 2025 2:03 PM To: Andrew Moore <amoore@edlow.com>
Cc: Falat, Lad (PHMSA) <lad.falat@dot.gov>; Franchone Oshinowo <foshinowo@edlow.com>;
Russell Neely <rneely@edlow.com>; Adrian Rony <arony@edlow.com>; Vierling, Ryan (PHMSA)
<ryan.vierling@dot.gov>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation
Good afternoon Andrew,
We accidentally attached the wrong PDF for the RAI. The previous RAI omitted observation #4.
Please see the revised RAI.
Speaking with Norma, it appears observation #4 will need to have a detailed answer in order to have a smooth approval process. If it takes a little longer for your customer to respond to observation 4, thats fine. In the interest of the schedule, Norma has agreed to allow for observation #4 to be submitted separately. Let me know what you think.
Sincerely, Alex
Alex Cheng General Engineer, Division of Sciences, Engineering and Research US Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave SE, Washington, DC 20590 Office: (771)-215-0938
From: Cheng, Kinwai (PHMSA)
Sent: Wednesday, September 3, 2025 11:09 AM To: Andrew Moore <amoore@edlow.com>
Cc: Falat, Lad (PHMSA) <lad.falat@dot.gov>; Franchone Oshinowo <foshinowo@edlow.com>;
Russell Neely <rneely@edlow.com>; Adrian Rony <arony@edlow.com>; Vierling, Ryan (PHMSA)
<ryan.vierling@dot.gov>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation
Good morning Andrew,
Can you have your customer verify that the information supplied contains any proprietary information? If it does, can you ask them to provide an affidavit?
For future replies to RAI responses, this may be required every time that a response is issued, unless if the information is non-proprietary.
Sincerely,
-Alex
Alex Cheng General Engineer, Division of Sciences, Engineering and Research US Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave SE, Washington, DC 20590 Office: (771)-215-0938
From: Andrew Moore <amoore@edlow.com>
Sent: Tuesday, September 2, 2025 4:34 PM To: Vierling, Ryan (PHMSA) <ryan.vierling@dot.gov>; Ramcert (PHMSA) <ramcert@dot.gov>
Cc: Falat, Lad (PHMSA) <lad.falat@dot.gov>; Franchone Oshinowo <foshinowo@edlow.com>;
Russell Neely <rneely@edlow.com>; Adrian Rony <arony@edlow.com>; Cheng, Kinwai (PHMSA)
<kinwai.cheng@dot.gov>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation
CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe.
Dear Dr. Vierling,
Please find attached NFIs remarks on NRCs preliminary observations for the NT-XII Package. This is not an official RAI response but is shared proactively to support the review and assist with the overall timeline.
Please let us know if you have any comments.
- Regards,
Andrew Moore EdlowInternationalCo.
Office: 202-483-4959 Direct: 202-706-5532 amoore@edlow.com
From: Andrew Moore Sent: Tuesday, August 26, 2025 4:14 PM To: Vierling, Ryan (PHMSA) <ryan.vierling@dot.gov>
Cc: Falat, Lad (PHMSA) <lad.falat@dot.gov>; Franchone Oshinowo <foshinowo@edlow.com>;
Russell Neely <rneely@edlow.com>; Adrian Rony <arony@edlow.com>; Ramcert (PHMSA)
<ramcert@dot.gov>; Cheng, Kinwai (PHMSA) <kinwai.cheng@dot.gov>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation
Dear Dr. Vierling,
Thank you for your detailed update and for providing the NRCs preliminary observations. We appreciate the effort you and your team are making to advance the review within the proposed timeline.
Would 10:00 AM tomorrow, Wednesday, August 27, be a suitable time for a 30-minute Teams meeting? If so, please feel free to share the meeting invitation at your convenience.
We look forward to discussing the proposed schedule and the next steps.
- Regards,
Andrew Moore EdlowInternationalCo.
Office: 202-483-4959 Direct: 202-706-5532 amoore@edlow.com
From: Vierling, Ryan (PHMSA) <ryan.vierling@dot.gov>
Sent: Tuesday, August 26, 2025 3:50 PM To: Andrew Moore <amoore@edlow.com>
Cc: Falat, Lad (PHMSA) <lad.falat@dot.gov>; Franchone Oshinowo <foshinowo@edlow.com>;
Russell Neely <rneely@edlow.com>; Adrian Rony <arony@edlow.com>; Ramcert (PHMSA)
<ramcert@dot.gov>; Cheng, Kinwai (PHMSA) <kinwai.cheng@dot.gov>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation
Good afternoon Mr. Moore,
DOT has received formal acceptance from NRC to review your package, the SUMI-4816, NT-XII for revalidation. They have acknowledged your need-by date (December 31, 2025) and are going to work aggressively to meet that. That being said, we have a very tight window to work in for responses to RAIs, so we will need to turn around information quickly. See attached some early observations from NRC on discrepancies in the application:
The document attached to this e-mail includes a staffs observations related to general information. The staff included observations to allow you to start earlier on items containing the potential to be asked at a later date. Responses to observations are not required for staff to begin a detailed technical review.
Observations are not the result of a detailed technical review and may be resolved once staff begins a detailed review.
The staff would try to expedite the review, which would depend on the quality,
timeliness, and completeness of the information provided by the DOTs applicant. The schedule includes the issuance, if needed, of a request for additional information (RAI) by September 2025 and receiving your response by October 2025. The staff goal is to complete the review by December 2025. These estimates are based on the staffs initial review of the application and may change due to several factors, including, unanticipated expansion of the review scope involvement, or if the submittal is provided to the NRC in advance of or concurrently with industry program initiatives or pilot applications. The schedule, above, is also based, in part, on DOTs applicant providing RAI responses by the specified timeline, unless another date is agreed upon, RAI responses resolving issues with limited need for follow-up RAIs, and clarification calls being scheduled and conducted promptly, and any additional supporting non-docketed information being provided timely.
Alex and I are available this week for a brief 30 minute Teams meeting to discuss the proposed schedule and to ensure we are all on the same page.
Ryan J. Vierling, Ph.D.
Chief, Sciences Branch Office of Hazardous Materials Safety USDOT, PHMSA 1200 New Jersey Ave SE, Washington, DC, 20590 Cell: 202.527.5391
From: Andrew Moore <amoore@edlow.com>
Sent: Thursday, August 21, 2025 9:41 AM To: Ramcert (PHMSA) <ramcert@dot.gov>
Cc: Vierling, Ryan (PHMSA) <ryan.vierling@dot.gov>; Falat, Lad (PHMSA) <lad.falat@dot.gov>;
Franchone Oshinowo <foshinowo@edlow.com>; Russell Neely <rneely@edlow.com>; Adrian Rony
<arony@edlow.com>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation
CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe.
Dear Dr. Vierling,
Could you kindly confirm receipt of our letter dated August 5, 2025,regarding the request for priority review of the NT-XII package revalidation?
- Regards,
Andrew Moore EdlowInternationalCo.
Office: 202-483-4959 Direct: 202-706-5532 amoore@edlow.com
From: Andrew Moore Sent: Tuesday, August 5, 2025 3:54 PM To: Ramcert (PHMSA) <ramcert@dot.gov>
Cc: Vierling, Ryan (PHMSA) <ryan.vierling@dot.gov>; Falat, Lad (PHMSA) <lad.falat@dot.gov>;
Franchone Oshinowo <foshinowo@edlow.com>; Russell Neely <rneely@edlow.com>; Adrian Rony
<arony@edlow.com>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation
Dear Dr. Vierling,
Please find attached a formal letter from Edlow International Company requesting priority review of the NRC evaluation and DOT revalidation process for the Japanese NT-XII package. Our client is targeting revalidation by December 31, 2025, to support time-sensitive project requirements in Japan. The certificate is additionally required for the fuel fabrication by U.S. fuel fabricators, which is currently planned to begin in January 2026.
We thank you in advance for your attention to this matter and ask that you please let us know if you need additional information.
- Regards,
Andrew Moore EdlowInternationalCo.
O: 202-483-4959 amoore@edlow.com
From: Andrew Moore Sent: Monday, June 16, 2025 10:33 AM To: 'Vierling, Ryan (PHMSA)' <ryan.vierling@dot.gov>; Russell Neely <rneely@edlow.com>; Adrian Rony <arony@edlow.com>
Cc: Falat, Lad (PHMSA) <lad.falat@dot.gov>; Franchone Oshinowo <foshinowo@edlow.com>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation
Dear Dr. Vierling,
The NT-XII package is currently planned to be used for transport within the United States in early 2026.
- Regards,
Andrew Moore EdlowInternationalCo.
O: 202-483-4959 amoore@edlow.com
From: Vierling, Ryan (PHMSA) <ryan.vierling@dot.gov>
Sent: Monday, June 16, 2025 10:18 AM To: Andrew Moore <amoore@edlow.com>; Russell Neely <rneely@edlow.com>; Adrian Rony
<arony@edlow.com>
You don't often get email from amoore@edlow.com. Learn why this is important Cc: Falat, Lad (PHMSA) <lad.falat@dot.gov>; Franchone Oshinowo <foshinowo@edlow.com>
Subject:
RE: SUMI-4816 NT-XII Package Revalidation
Hi Andrew,
Confirming that the need date is still December 31, 2025. When are you planning a shipment?
Ryan J. Vierling, Ph.D.
Chief, Sciences Branch Office of Hazardous Materials Safety USDOT, PHMSA 1200 New Jersey Ave SE, Washington, DC, 20590 Cell: 202.527.5391
From: Andrew Moore <amoore@edlow.com>
Sent: Tuesday, May 27, 2025 2:53 PM To: Vierling, Ryan (PHMSA) <ryan.vierling@dot.gov>; Russell Neely <rneely@edlow.com>; Adrian Rony <arony@edlow.com>
Cc: Falat, Lad (PHMSA) <lad.falat@dot.gov>; Franchone Oshinowo <foshinowo@edlow.com>
Subject:
SUMI-4816 NT-XII Package Revalidation
CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe.
Dear Mr. Vierling:
We are contacting you to follow up on a pending package validation that was sent to DOT on February 4, 2025, for the Japanese package model NT-XII; the transmittal was accepted by DOT on the same date. On February 19, we were informed by Rick Boyle that the application was undergoing acceptance review by DOT and NRC (please see attached email) and that a review/approval schedule would be developed. The application was submitted with the need date of December 31, 2025.
We are requesting an update on the status of the application, and confirmation that NRC has accepted our application and started its review process.
We thank you in advance for your attention in this matterand ask that you please let us know if you need additional information.
Sincerely,
Andrew Moore EdlowInternationalCo.
O: 202-483-4959 amoore@edlow.com