ML23160A086

Email Dated 2/14/23 from Rneely (Edlow) to Rboyle (DOT)-Initial Need Dates (Clarification), Japanese Certificate of Competent Authority No. J/2043/B(U)F, Model No. JRF-90Y-950K

ML23160A086
Person / Time
Site:	07103036
Issue date:	02/14/2023
From:	Neely R Edlow
To:	Boyle R Office of Nuclear Material Safety and Safeguards, US Dept of Transportation, Office of Hazardous Materials Safety
Garcia-Santos N
Shared Package
ML23160A010	List: ML23160A081 ML23160A082 ML23160A084 ML23160A085 ML23160A086 ML23160A087
References
001794, L-2023-DOT-0000
Download: ML23160A086 (5)

Text

From: Russell Neely To: Boyle, Rick (PHMSA)

Cc: Norma Garcia Santos; Bernie White; Pierre Saverot; Adrian Rony; Franchone Oshinowo

Subject:

[External_Sender] RE: Teleconference to discuss package design applications Date: Tuesday, February 14, 2023 3:50:38 PM Attachments: image002.png No.02 Affidavit on the proprietary document(JRF)_R1 - EIC Comments.pdf

Dear Rick:

Following our TEAMS call we explained to our Japanese client the need for a Roadmap showing sections in the SAR for the JRF-90Y-950K that are unchanged and those that are changed, with easy-to-read descriptions of the changes. We expect to receive the Roadmap this week. They have already provided the revised Affidavit on Proprietary Documents (attached).

In the meantime, we have had discussions with NNSA (SRS) and Y12 and wish to clarify the Need Dates discussed on our call.

At the time of our call, I was not aware that both SRS and Y12 have to qualify each cask in order to allow the casks to be delivered to each facility and the fuel processed. This means that each facility needs sufficient time after US DOT issues the CAC for each cask in order to qualify each cask prior to shipment from Japan to the US. Without this Receipt Authorization, the casks with fuel cannot be shipped to the US. Therefore, the corrected Need Dates based on input from SRS and Y12 are as follows:

1. JRF-90Y-950K (application submitted to USDOT; clarifications in process; Need Date March 31, 2023)

2. JRC-80Y-20T (yet to be submitted to USDOT, estimated mid-February; Need Date July 10, 2023)

3. JMS-87Y-18.5T (yet to be submitted USDOT, estimated early-March; Need Date July 10, 2023)

(Regarding the NT-IV package, the Need Date remains as stated in the TEAMS call, March 2024.)

We are available for further discussion as needed and are pressing our client to provide the outstanding documents asap.

Thank you for your understanding and assistance.

Best regards, Russell Russell Neely Chief Operating Officer Edlow International Company Tel: +1 202 483 4959 From: Boyle, Rick (PHMSA) <rick.boyle@dot.gov>

Sent: Monday, January 30, 2023 8:23 AM To: Adrian Rony <arony@edlow.com>

Cc: Garcia Santos, Norma <Norma.GarciaSantos@nrc.gov>; White, Bernard

<Bernard.White@nrc.gov>; (Pierre.Saverot@nrc.gov) <Pierre.Saverot@nrc.gov>; Franchone Oshinowo <foshinowo@edlow.com>; Russell Neely <rneely@edlow.com>

Subject:

RE: Teleconference to discuss package design applications 11:00 on Wednesday works for everyone. I sent out a TEAMS meeting notice. Let me know if Edlow has issues using TEAMS.

Look forward to talking with you and Russell Rick Boyle Chief, Radioactive Materials Transport USDOT, PHMSA 1200 New Jersey Avenue SE, Washington, DC, 20590 Office: 202.366.2993 Mobile: 202.697.1301 From: Adrian Rony <arony@edlow.com>

Sent: Friday, January 27, 2023 2:31 PM To: Boyle, Rick (PHMSA) <rick.boyle@dot.gov>

Cc: Sumrall, Matthew (PHMSA) <matthew.sumrall@dot.gov>; Garcia Santos, Norma

<Norma.GarciaSantos@nrc.gov>; White, Bernard <Bernard.White@nrc.gov>;

(Pierre.Saverot@nrc.gov) <Pierre.Saverot@nrc.gov>; Franchone Oshinowo

<foshinowo@edlow.com>; Russell Neely <rneely@edlow.com>

Subject:

RE: Teleconference to discuss package design applications 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.

Hello Rick, Regarding a teleconference, Edlow would like to suggest Wednesday, February 1st at 11am or 2pm. If an alternative time is required, please let us know. Russell Neely will also join the call as he is managing the shipments from Japan with SRS (Kiran).

For your reference, we have the following packages for discussion:

1. JRF-90Y-950K (application submitted to USDOT)

2. NT-IV (application submitted to USDOT)

3. JRC-80Y-20T (yet to be submitted to USDOT, estimated mid-February)

4. JMS-87Y-18.5T (yet to be submitted USDOT, estimated early-March)

The JRF, JRC, and JMS are the packages related to the shipments with SRS.

Concerning your questions below regarding the JRF, we had previously submitted on January 14th

the majority of these issues to our Japanese customer and awaiting their responses. We will advise them again of our impending teleconference so we can have their answers by the time of the teleconference.

Concerning your questions below regarding the NT-IV, we have just received additional information on this package this week from our Japanese customer. We can share on the teleconference.

Thank you.

Regards, Adrian Rony Edlow International Co.

O: 202-483-4959 x 19 M: 301-651-7262 arony@edlow.com From: Boyle, Rick (PHMSA) <rick.boyle@dot.gov>

Sent: Friday, January 27, 2023 11:24 AM To: Adrian Rony <arony@edlow.com>

Cc: Sumrall, Matthew (PHMSA) <matthew.sumrall@dot.gov>; Garcia Santos, Norma

<Norma.GarciaSantos@nrc.gov>; White, Bernard <Bernard.White@nrc.gov>;

(Pierre.Saverot@nrc.gov) <Pierre.Saverot@nrc.gov>

Subject:

Teleconference to discuss package design applications Good morning Adrian, I was planning to set up a conference call with you this week to discuss your applications for the JRF and NT-IV package designs but time got away from me.

Below is a list of questions that would serve as the agenda for the meeting. As NRC would like to participate, is it possible for you to suggest available times for a teleconference to be held early next week? Thank you for your time and attention.

For the JRF Package:

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

2) Provide an affidavit listing the documents and enclosures that are considered proprietary by the applicant.

The affidavit only mentions one document considered as proprietary (i.e.,

Enclosure 1, North American Version of the Safety Analysis for JRF), which does not seem to be accurate, since the submittal to DOT includes 7

documents in English (without counting DOTs cover letter) and more than one document may be considered proprietary by the applicant.

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

If document No. 6 is considered proprietary by the applicant, provide an affidavit including the document and send a public version of the document.

Document No. 6 is not included in the affidavit provided with the application for the JFR90Y-950K package. It is not clear if the entire document or portions of it may be considered proprietary by the applicant.

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

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

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

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

5) Clarify the following:

a) Since the application provides a comparison of the 2017 and 2022 versions of the SAR with the 2022, does this application include any of the changes in the revalidation recommendation issued in April 2022 for this package b) Do the text highlighted in gray and the text in blue boxes in different documents correspond to the changes to the SAR from the 2017 version?

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

For the NT-IV Package:

1. What is different since 2010 (contents, design, operation/maintenance)?

2. What prompted change?

3. What contents do you plan to transport?

4. When do you plan to begin making shipments?

Rick Boyle Chief, Radioactive Materials Transport US Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue SE, Washington, DC, 20590 Office: 202.366.2993 Mobile: 202.697.1301 PHMSA Home l LinkedIn l Twitter l HAZMAT l OPS