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DOE OSTI2025

Five Year Comparison of Mixing Height Determinations at the Savannah River Site

Air quality dispersion modeling is performed for the Savannah River Site (SRS) to demonstrate compliance with applicable regulations. The AMS/EPA Regulatory Model (AERMOD) modeling system is an EPA recommended model for air quality applications with a data preprocessor (AERMET) to incorporate meteorological data collected on site. AERMET parameterizes or calculates meteorological variables that are not directly measured onsite. One of the parameters estimated by AERMET is the atmospheric mixing height. While the mixing height is not currently a measurement input into AERMET, SRS has the capability to measure the local mixing height. The Savannah River National Laboratory (SRNL) operates a Vaisala CL31 Lidar Ceilometer which estimates mixing height from aerosol backscatter. This study compares the parameterized mixing height from AERMET to the ceilometer estimated mixing height for the current regulatory period at SRS incorporating data from 2015-2019. Results from this study showed the average daily minimum values (morning) from AERMET were an order of magnitude lower than the commonly used Holzworth (1972) method and the ceilometer estimated mixing heights. Additionally, on average, the ceilometer exhibited a daily maximum mixing height value that occurred 1-3 hours later than the AERMET estimated maximum. This difference is likely due to the nighttime atmospheric mixing height assumptions and calculations used by AERMET. The AERMET algorithm cuts off mixing height growth at sunset while the ceilometer data show ongoing evening convection typical of the southeastern United States. These results suggest that the AERMET parametrization scheme assumptions may not be representative of a forested landscape and evening convection which could account for more mixing overnight. The results obtained in this study are significant for air dispersion modeling applications for regulatory purposes and worker safety. Mixing height can impact model estimated pollutant concentrations. A greater mixing height will provide more volume for pollutant dispersion. This report documents efforts to quantify the dependence of mixing height inputs toward a conservative estimated pollutant concentration.

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NASA NTRS1979

Factors affecting the retirement of commercial transport jet aircraft

The historical background of the technology and economics of aircraft replacement and retirement in the prejet era is reviewed in order to determine whether useful insights can be obtained applicable to the jet era. Significant differences between the two periods are noted. New factors are identified and examined. Topics discussed include concern over current policies regarding deregulation, regulatory reform, and retroactive noise regulations; financing and compliance legislation; aging; economic environment and inflation; technological progress; fuel efficiency and cost; and a financial perspective of replacement decisions.

Spencer, F. A.↗

NASA NTRSDate not supplied

An MBSE Framework to Identify Regulatory Gaps for Electrified Transport Aircraft

A typical aircraft certification process consists of obtaining a type, production, airworthiness, and continued airworthiness certificates. During this process, a type certification plan is created that includes the intended regulatory operating environment, the proposed certification basis, means of compliance, and a list of documentation to show compliance. Earlier work by the authors demonstrated a model-based framework for the management of these certification artifacts for normal category airplanes. Presently, it is expanded and adapted to consider certification for transport category airplanes regulated under 14 CFR Part 25, providing clear transparency and traceability between the text of the regulations and imposed requirements, contextual information, and specified test activities. In particular, a capability to identify potential gaps in the applicability of regulations for novel architectures such as electrified aircraft is proposed. This capability, based on mismatches between the functional intent and the corresponding prescribed physical implementation, is developed. A sample implementation of the proposed capability is presented for a notional electrified powertrain aircraft architecture.

electrified transport aircraft↗

DOE OSTI2020

Sensitive Resources Assessment and Forest Analysis for the Proposed Versatile Test Reactor, Oak Ridge, Tennessee

The US Department of Energy’s (DOE’s) Oak Ridge National Laboratory (ORNL) is a leading institution in advanced materials, supercomputing, neutrons, and nuclear science. As a research laboratory managed by UT-Battelle, LLC for DOE, ORNL has national priorities in energy, security, and scientific discovery that necessitate facility improvements and expansions. DOE is also committed to environmental stewardship. The laboratory is located on the ~32,000-acre (~13,000-ha) Oak Ridge Reservation (ORR), much of which is categorized as a National Environmental Research Park (NERP) and a state Wildlife Management Area. DOE works with the Tennessee Wildlife Resources Agency (TWRA), Tennessee Department of Environment and Conservation (TDEC), US Fish and Wildlife Service (USFWS), US Department of Agriculture, and other agencies to serve as an effective steward of the ORR. Accordingly, project managers must conform to environmental regulations, agreements, and policies at the federal, state, and institutional levels. Per 40 CFR (Code of Federal Regulations) 1508.14, potential effects on research and science education also represent potential effects of federal actions on the NERP, and impacts on, e.g., deer harvest, must be considered on the Oak Ridge Wildlife Management Area when other aspects of the human environment are affected. The United States currently has no fast neutron testing capability to support advanced nuclear research and development. The proposed Versatile Test Reactor (VTR) will take advantage of current investments by the US government and private industry in nuclear reactors to expedite the design and construction process, using proven technology to create a world-class scientific infrastructure. The VTR will take advantage of fast neutrons provided by this proven technology, along with a capability to rapidly insert, conduct, and remove state-of-the-art experiments. An advantage of the VTR is that it can support future innovations in experimental capabilities without modifying the facility. The VTR will support progress in a variety of science and technology areas, including testing and qualification of advanced reactor fuels; testing and qualification of innovative structural materials; testing of innovative components and instruments; validation of advanced modeling and simulation tools; and versatility for future technical missions. Through proven technology, the VTR can take advantage of existing reactor designs and operating experience to reduce the risk, cost, and time for design and construction. The top available resources of DOE laboratories, industry, and universities will be used to expedite reactor design and construction toward developing the scientific infrastructure that affords a strong testing capability that can be sustained over many years. This report summarizes current knowledge of natural and cultural resources primarily within the VTR construction area. At the time of this report, the proposed VTR site design includes a construction area of ~150.4 acres (~69.9 ha), which contains an ~51.3-acre (~20.8-ha) operations area, located within forested natural areas of the ORR. The primary goal of the work presented here was to evaluate potential effects on sensitive resources that might result from development and construction activities associated with VTR. In addition to on-the-ground surveys during spring and summer 2020 by the ORNL Natural Resources Management Program and Aquatic Ecology Group staff, this report makes use of historical (pre-1995) and contemporary (1995 to present) data from additional confirmed sources (e.g., TDEC). Likewise, forest conditions were compiled from a 2011 forest inventory and supplemented with limited ground observations in 2020. The individuals who obtained and compiled the data presented here are familiar with and routinely assess sensitive resources on the ORR. Anyone who references this report must consider that the timing of surveys did not permit a complete delineation of the resources that will be affected. If the VTR project proceeds, additional surveys will be required to account for the seasonal patterns of various threatened and endangered species. Data deficiencies and potential resources that likely went undetected are indicated where possible. Accordingly, this report should facilitate more environmentally sound decisions during planning and 2 development of the VTR site, provide a foundation for further assessment of sensitive and cultural resources, and help project managers better address regulatory guidance and DOE policies on sustainable development in compliance with, for example, the US Endangered Species Act (ESA), Migratory Bird Treaty Act (MBTA), Tennessee Rare Plant Protection and Conservation Act of 1985, Tennessee Nongame and Endangered or Threatened Wildlife Species Conservation Act of 1974, several federal and state regulations regarding aquatic resource protection, and site-specific policies as outlined in various ORR management plans developed by ORNL and TWRA for DOE.

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DOE OSTI2021

Real-time and Autonomous Water Quality Monitoring System Based on Remotely Operated Vehicle

Existing water quality monitoring systems near hydropower facilities are limited by the lack of mobility of the sensors’ carrier platform. Most systems use a buoy, a mounting fixture attached to a solid structure, or a human worker, which significantly limits the selection of the sampling sites and poses safety risks during data collection and equipment maintenance. To improve on this technology, we developed an autonomous water quality monitoring system that can operate in dangerous water environments near hydropower facilities for water sampling at multiple locations. The goal is to enable safe, timely, and comprehensive water-quality data collection; maximize power generation revenue with improved operational control; and reduce Federal Energy Regulatory Commission and state water quality monitoring costs for compliance. The system incorporates a remotely operated vehicle as the mobile monitoring platform, a dissolved oxygen sensor for monitoring water quality, a tether management system for automatically winding the tether, a solar mobile docking platform for suppling power to the ROV, and a web-based graphical user interface for data post-processing and visualization. In addition, preliminary field research are presented to demonstrate the system capabilities.

Salalila, Aljon L.↗

DOE OSTI2020

Uranium Mill Tailings Radiation Control Act Title II DOE Due Diligence and Lessons Learned from a Previous Site Transfer - 20352

Title II of the Uranium Mill Tailings Radiation Control Act (UMTRCA) established that a government agency will provide perpetual care for closed uranium and thorium ore-processing sites that were operating under an NRC source material license in 1978 or were licensed thereafter. Commercial owners (licensees) operating under an NRC or agreement state specific license when UMTRCA was passed are responsible for conducting reclamation of any byproduct material remaining from uranium-ore processing operations in accordance with an NRC or agreement state approved reclamation plan. Reclamation includes both surface and groundwater remedies. Upon completion of reclamation and approval by NRC, the site is required to be transferred to either the host state or the DOE for long-term surveillance and maintenance. Since UMTRCA's enactment, six Title II sites have been transferred to DOE; an additional 24 Title II sites are anticipated to be transferred before 2050. DoE's role mandated under UMTRCA Title II as the long-term care custodian is to perform 'monitoring, maintenance, and emergency measures necessary to protect the public health and safety.' UMTRCA requires that the licensee pay a long-term surveillance charge 'sufficient to cover the annual costs of site surveillance.' However, at some sites such as the Bluewater, New Mexico, Disposal Site, this mandate has required additional effort and expense by DOE, beyond the originally anticipated and intended scope within UMTRCA, but within the authority of DOE under UMTRCA. In 1997, the Bluewater site became the second UMTRCA Title II site to be transferred to DOE. The site was the location of a uranium mill operated from 1953 until 1982. The specific licensee began site reclamation in 1991, and by 1995 all tailings and contaminated materials were encapsulated in two tailings disposal cells and other disposal areas. In addition to surface contamination, milling activities impacted groundwater in the two upper aquifers. In 1989, the specific licensee attempted active groundwater remediation; however, no significant reduction in contaminant concentrations was observed. As a result, the specific licensee applied to NRC for alternate concentration limits (ACLs) in 1990, which were approved in 1996 as being protective, after additional corrective actions were performed. Since transfer of the Bluewater site to DOE, unforeseen challenges have occurred, requiring additional actions. The first challenge is the occurrence of surface depressions located on the northern section of the main tailings disposal cell. The depressions were first observed during DoE's initial inspection in 1998; however, evidence of these can be observed on satellite images taken prior to transfer. Since being first observed, the depressions have continued to grow both in depth and areal extent. Due to the design of the main tailings disposal cell, the depressions impede storm water from being effectively shed off the 101- hectare (250-acre) top slope of the main tailings disposal cell. Instead, storm water accumulates in the depressions, forming a large ephemeral pond that has stored up to 16.3 x 10{sup 6} liters (4.3 million gallons) of stormwater. The ponding poses a potential risk to the integrity of the main tailings disposal cell in the case of a large storm event, with the potential to cause the pond to overtop and erode the cover material and underlying waste. DOE has taken a number of short-term actions to monitor, measure, and reduce the ponding and is currently working with the US Army Corps of Engineers to design and construct a repair. Additional challenges are associated with groundwater at the Bluewater site. Nine wells were present on the 1335-hectare (3300-acre) site upon transfer. Groundwater compliance was called into question after the State of New Mexico reduced its uranium groundwater standard from 5.0 to 0.03 milligrams per liter in 2004, and when an ACL for uranium was exceeded in a site monitoring well in 2010. Acquiring historical groundwater data and subsequent evaluations as well as additional DOE groundwater monitoring led to installing 10 new monitoring wells and performing additional site hydrogeology recharacterization. DOE continues to evaluate groundwater conditions at the site and works with the NRC to determine regulatory requirements and a path forward. As a result of lessons learned at the Bluewater site and other Title II sites, improved processes have been implemented at a programmatic level to increase due diligence before site transfer and prevent similar issues from occurring at other UMTRCA Title II sites under long-term management. DoE's due diligence process is documented in the Process for Transition of UMTRCA Title II Disposal Sites to DOE for Long-Term Surveillance and Maintenance and is designed to ensure that DOE has no technical or compliance concerns with regulatory decisions that might compromise protectiveness following site transfer to DOE. Implementation of the due diligence process has increased DoE's role prior to site transfer and has been effective in identifying potential issues. Actions by NRC and specific licensees, in response to enhanced due diligence efforts by DOE, are expected to minimize, if not totally prevent, the need for unanticipated actions by DOE pertaining to the surface and groundwater remedies after site transfer. (authors)

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DOE OSTI2025

Grid Communications: Digital Assurance and Supply Chain Challenges and Emerging Regulation Session Two

The TADA Grid Communications Workshops are designed to strengthen cybersecurity and digital assurance across the energy sector by focusing on secure deployment and management of grid communications technologies. These workshops bring together state energy offices, utilities, and technology suppliers to explore the intersection of communications infrastructure, supply chain risks, and emerging regulatory requirements. Participants will apply Cyber-Informed Engineering (CIE) principles to reduce risks in communications systems, engage with INL’s procurement guidance, and explore future tools. Through scenario-based exercises and peer exchange, attendees will develop risk-based security strategies and actionable compliance roadmaps tailored to their grid communications projects. The workshops also help participants navigate evolving regulatory frameworks such as FEOC rules in the OBBB, NERC CIP-013, and NDAA 2024, while identifying compliance gaps in mixed-technology environments. A key outcome is the formation of a practitioner network with ongoing access to INL expertise and resources, fostering long-term resilience in the digital energy ecosystem. This is Session 2 of 3 (Full Version).

29 - ENERGY PLANNING, POLICY AND ECONOMY↗

DOE OSTI2025

Grid Communications: Cybersecurity and Supply Chain Challenges and Emerging Regulation Session Three

29 - ENERGY PLANNING, POLICY AND ECONOMY↗

DOE OSTI2025

Grid Communications Supply Chain & Emerging Regulation Challenges Session 1

29 - ENERGY PLANNING, POLICY AND ECONOMY↗

DOE OSTI2020

Waste Management Project Success - Regulatory Assurance Systems - 20118

Waste management (WM) and remediation projects are essential within a restorative environmental culture. Despite years of experience, challenges and obstacles associated with efficient and effective WM project execution remain. Although some obstacles are project specific, a common challenge is navigating the regulatory landscape from planning through execution, particularly with first of a kind (FOAK) and first in a while (FIAW) projects. The absence of a comprehensive regulatory assurance strategy places significant hurdles in the path of project success. To clear a path for the successful execution of increasingly complex WM projects, this paper focuses on development of a comprehensive regulatory assurance strategy and implementation plan that effectively engages stakeholders, agencies, and performers to produce project plans that fully and cost effectively integrate applicable regulatory requirements. The most reliable way to align regulatory processes and decisions needed for mission success is through a regulatory assurance system. This system establishes a healthy interface with regulatory decision makers, to work in a collaborative manner, to create a common vision for regulatory decisions on an agreed upon schedule. A regulatory assurance system consists of several elements. Although the mission may vary from cleanup to site closure to nuclear component production, the elements of a regulatory assurance system remain essentially constant and must include: 1) identifying a common vision or end state, 2) developing a long-term, integrated strategy and schedule, 3) establishing a regulatory partnering team consisting of key decision-makers, 4) regular and frequent communication with decision-makers, 5) ensuring consistent surveillance for early identification of issues and changes that may impact the project, 6) quick resolution of emerging issues to prevent schedule impact, 7) identifying core compliance functions, 8) periodically assessing progress of the project as it relates to regulatory assurance and, 9) providing constructive feedback to improve the process. A regulatory assurance system provides a living, multi-faceted approach to planning, visioning, communicating and tracking to avoid surprises and ensure smooth and timely progress to the project. The overall success measures will be whether the system produces common sense regulatory decisions supporting the vision on time without appeal. Effective regulatory frameworks rarely happen on their own. Balanced, common-sense regulatory decisions stem from teams that are trained to work together to achieve shared goals. In this paper, particular attention is placed on the importance of starting with a shared vision for a regulatory assurance and execution strategy that leverages experience to establish optimal approaches. (authors)

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DOE OSTI2021

LANL Environmental ALARA Program Status Report for CY 2020

Los Alamos National Laboratory (LANL) ensures that radiation exposures to members of the public and the environment from LANL operations, past and present, are below regulatory thresholds and are as low as reasonably achievable (ALARA) through compliance with Department of Energy (DOE) Order 458.1 Radiation Protection for the Public and the Environment (DOE 2020), and LANL Functional Series Documents EPC-ES-FSD-004,Environmental Radiation Protection, (LANL 2020a) and EPC-ES-FSD-003, Los Alamos National Laboratory Environmental ALARA Program (LANL 2020b). These documents provide related program authorities, responsibilities, descriptions, processes, and thresholds for conducting qualitative and quantitative ALARA analyses for prospective and actual radiation exposures to the public and to the environment resulting from DOE activities conducted on the LANL site.

61 RADIATION PROTECTION AND DOSIMETRY↗

DOE OSTI2022

Using Systems Theoretic Process Analysis and Causal Analysis to Map and Manage Organizational Information to Enable Digitalization and Information Automation

The overarching goal of this Light Water Reactor Sustainability Program–supported research and development project is to provide planning tools and comprehensive guidance to utilities considering or undertaking full nuclear plant modernization. The results of this research will provide the nuclear industry with a comprehensive and usable solution, including guidance, lessons learned, methods, and planning tools. This research is currently working to provide guidance on digitalization and information automation to enable the evolution of data to information, insight, and action—thereby allowing utilities to operate safely and cost-competitively with all other electrical generation sources. Light Water Reactor Sustainability Program researchers have also recently started investigating how human and technology integration principles, information automation, and digitalization enable data evolution. These researchers are currently in the process of validating the use of System-Theoretic Process Analysis to define high-level safety constraints in the United States Nuclear Regulatory Commission’s problem identification and resolution process (i.e., a plant compliance information gathering activity). The next step in this research, which is described in the following sections of this report, is to map out data evolution in a use case to identify inefficiencies in another aspect of plant compliance information gathering and communication activities—event investigations and root cause analyses.

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DOE OSTI2024

Conversion of Site-Specific Meteorological Data for use in CAP-88 PC

CAP-88 PC is a commonly used radiological atmospheric dispersion model. This US EPA-approved model is used to demonstrate compliance with atmospheric emission regulations for radionuclides. While the model includes a large library of meteorological data for use across the United States, there are applications when users may wish to use onsite meteorological data as an input to the CAP-88 PC model. Here, in this work, we present a work-around process for preparing and converting onsite data for use in CAP-88 PC. However, the use of local data should provide a more realistic estimate of doses to members of the public in the immediate vicinity of a facility, although the regulatory agency having jurisdiction may not accept the use of local data for compliance. Additionally, the historical meteorological records from 20+ years ago (at a site many kilometers away) might not be representative of current local weather patterns, highlighting another benefit of using local meteorological data.

54 ENVIRONMENTAL SCIENCES↗

DOE OSTI2024

Requesting an Exemption from Standard Compliance: EPAct State and Alternative Fuel Provider Fleet Program Guidance Document

The U.S. Department of Energy established the Alternative Fuel Transportation Program (Program) and associated regulatory requirements pursuant to the Energy Policy Act of 1992. The Program, otherwise known as the State and Alternative Fuel Provider Fleet Program, requires covered state government and alternative fuel provider fleets operating under Standard Compliance to acquire alternative fuel vehicles (AFVs) as a specific percentage of their annual non-excluded light-duty vehicle acquisitions. The opportunity for covered fleets operating under Standard Compliance to request exemptions from their AFV-acquisition requirements serves as administrative relief in the unlikely event a fleet is unable to satisfy its requirements through the normally available compliance alternatives. These alternatives include the acquisition of light-duty AFVs, the acquisition of other, creditable vehicles (e.g., gasoline-fueled hybrid electric vehicles), making certain investments, the purchase of biodiesel for use in medium- or heavy-duty vehicles to the maximum extent allowed, and purchasing or trading for banked AFV credits. This document addresses requests for exemptions from the AFV-acquisition requirements to help covered fleets better understand: How to file a request for an exemption, information and documentation DOE needs to process an exemption request, and important policies relevant for filing exemption requests.

ADVANCED PROPULSION SYSTEMS,ENERGY PLANNING, POLIC↗

DOE OSTI2025

Ensuring electromagnetic compatibility in grid-connected power converters: Challenges, standards, and compliance strategies

In today's rapidly advancing world, electronic devices and systems are fundamental to a wide range of industries, including renewable energy and global telecommunications infrastructure. However, as these devices become more complex and widespread, the risk of electromagnetic interference (EMI) also increases, underscoring the importance of stringent Electromagnetic Compatibility (EMC) requirements for maintaining system integrity. This paper addresses the specific challenges associated with grid-connected power converters (GCPCs), which are critical in integrating renewable energy into existing power grids. It explores the complexities of EMI in the context of GCPCs, particularly given the recent emergence of tailored EMC standards for these systems. The paper also highlights the shortcomings of applying generic or unrelated standards to GCPCs, often leading to inadequate compliance and testing protocols. Through a detailed analysis of existing standards and recent advancements in product-specific EMC requirements, this paper provides a comprehensive overview of the current landscape, offering guidance to stakeholders on navigating the intricate EMC compliance landscape, with a focus on methodologies, testing procedures, and the evolving regulatory environment for GCPCs.

24 POWER TRANSMISSION AND DISTRIBUTION↗

DOE OSTI2021

Safety Analysis Report For Packaging, Y-12 National Security Complex, Model ES-3100 Package with Bulk HEU Contents

This safety analysis report for packaging (SARP) presents the results of the safety analysis prepared in support of the Consolidated Nuclear Security, LLC (CNS) request for licensing of the Model ES-3100 package with bulk highly enriched uranium (HEU) contents and issuance of a Type B(U) Fissile Material Certificate of Compliance. This SARP, published in the format specified in the U.S. Nuclear Regulatory Commission (NRC) Regulatory Guide 7.9 and using information provided in UCID-21218 and NRC Regulatory Guide 7.10, demonstrates that the Y-12 National Security Complex (Y-12) ES-3100 package with bulk HEU contents meets the established NRC regulations for packaging, preparation for shipment, and transportation of radioactive materials given in Title 10, Part 71, of the Code of Federal Regulations (CFR) [10 CFR 71] as well as U.S. Department of Transportation (DOT) regulations for packaging and shipment of hazardous materials given in Title 49 CFR.

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NASA NTRS1995

Environmentally regulated aerospace coatings

Aerospace coatings represent a complex technology which must meet stringent performance requirements in the protection of aerospace vehicles. Topcoats and primers are used, primarily, to protect the structural elements of the air vehicle from exposure to and subsequent degradation by environmental elements. There are also many coatings which perform special functions, i.e., chafing resistance, rain erosion resistance, radiation and electric effects, fuel tank coatings, maskants, wire and fastener coatings. The scheduled promulgation of federal environmental regulations for aerospace manufacture and rework materials and processes will regulate the emissions of photochemically reactive precursors to smog and air toxics. Aerospace organizations will be required to identify, qualify and implement less polluting materials. The elimination of ozone depleting chemicals (ODC's) and implementation of pollution prevention requirements are added constraints which must be addressed concurrently. The broad categories of operations affected are the manufacture, operation, maintenance, and repair of military, commercial, general aviation, and space vehicles. The federal aerospace regulations were developed around the precept that technology had to be available to support the reduction of organic and air toxic emissions, i.e., the regulations cannot be technology forcing. In many cases, the regulations which are currently in effect in the South Coast Air Quality Management District (SCAQMD), located in Southern California, were used as the baseline for the federal regulations. This paper addresses strategies used by Southern California aerospace organizations to cope with these regulatory impacts on aerospace productions programs. All of these regulatory changes are scheduled for implementation in 1993 and 1994, with varying compliance dates established.

Morris, Virginia L.↗

DOE OSTI2020

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)

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