Cask RT-100 Type B(U) Self-Certification for DOT 7A, Type A Nuclear Waste Transportation - 20098

The purpose of this Type A certification is to diversify the use of the RT-100 cask by allowing the end user to transport either Type A or Type B radioactive waste in accordance with the handling procedures for each waste category. The project's scope included the development of a matrix that contains all applicable requirements for a Type A package from the Code of Federal Regulations (CFR), Title 49 for the Department of Transportation (DOT) with a justification for each requirement. Moreover, the scope included the writing of conditions and restrictions list for the transportation of Type A nuclear waste, the writing of a compliance statement, and the design and fabrication of a Type A placard to be permanently placed on the RT-100 cask. Type A packages are self-certified by the end user using one of three methods as permitted by 49 CFR 173.461, either by performance of tests with prototypes or samples of the specimens representing the packaging, or reference to a previous satisfactory demonstration of compliance of a sufficiently similar nature, or calculations or reasoned evaluation using reliable and conservative procedures and parameters. Since the RT-100 cask was licensed by the Nuclear Regulatory Commission (NRC) as a Type B cask, Robatel relied on the method of reference to a previous satisfactory demonstration of compliance of a sufficiently similar nature for Type A certification. This method was determined to be acceptable, since Type B packages are evaluated for more demanding transport conditions than those required for Type A packages. This paper presents Robatel's process for certifying the RT-100 cask for Type A shipments, an overview of the DOT regulations related to Type A packages, and the documents that were generated for the end user. This paper is concluded with a discussion on the advantages of having the option to transport both Type A and Type B nuclear waste, and possible future projects to further improve the operation of the cask when making Type A shipments. (authors)