ML23143A180

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Robatel, Technologies, Llc., Response to Request for Additional Information (Public Version)
ML23143A180
Person / Time
Site: 07109365
Issue date: 05/19/2023
From: Shakhatreh A
Robatel Technologies
To:
Division of Fuel Management
Shared Package
ML23143A177 List:
References
Download: ML23143A180 (1)
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Text

(Non-Proprietary Version)

U.S. NRC Request for Additional Information Docket No. 71-9365 Model No. RT-100 Package May 19, 2023 Prepared by:

Abdulsalam Shakhatreh Robatel Technologies, LLC 5115 Bernard Dr., Suite 304 Roanoke, VA 24018 For:

U.S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852

Subject:

Robatel Technologies response to address the U.S. NRC Request for Additional Information for review of the Model No. RT-100 Package, Docket No. 71-9365

References:

Request for Additional Information for Review of the Model No. RT-100 Package Letter, dated February 27, 2023 This response addresses the RAIs noted on the U.S. NRC request for additional information letter, dated February 27, 2023. The RAIs are grouped by chapter number and title from the Safety Analysis Report (SAR), along with Robatels response.

This response where applicable, references the locations in the SAR where revised information can be located.

Page 1 of 13

(Non-Proprietary Version)

STRUCTURAL RAI 2.1 Demonstrate how evaluating cold conditions of normal conditions of transport (NCT) using both a maximum internal pressure and decay heat results in the most unfavorable cask stresses.

Both section 2.2 and table 1 of Regulatory Guide 7.8, as well as section 2.4.5.2 of NUREG-2216, state that the cold conditions be evaluated with minimum internal pressure loads and without decay heat. However, safety analysis report (SAR) sections 2.6.1.1 and 2.6.2 indicate that both an increased internal pressure of 342.7 kPa (versus the calculated 182.71 kPa) and an internal heat load were considered in the cask analyses for the cold conditions.

The above information is necessary to comply with Title 10 of the Code of Federal Regulations (10 CFR) 71.71(c)(2).

Response 2.1 The cask body analysis is documented in calculation RTL-001-CALC-ST-0402. From the assessment in the calculation, Regulatory Guide 7.8 has four credible thermal conditions to be considered:

Condition 1 - Hot Case 1:

a. Ambient temperature, 38°C
b. Initial temperature, 38°C
c. Heat transfer to ambient by natural convection, still air
d. Heat transfer to ambient by radiation
e. Solar insolation as a periodic heat flux applied as 12-hr on and 12-hr off
f. Internal heat load as a uniform heat flux, 13.04 W/m² (200 watts)

Condition 2 - Hot Case 2:

a. Ambient temperature, 38°C
b. Initial temperature, 38°C
c. Heat transfer to ambient by natural convection, still air
d. Heat transfer to ambient by radiation
e. No solar insolation, in shade
f. Internal heat load as a uniform heat flux, 13.04 W/m² (200 watts)

Condition 3 - Cold Case 1:

a. Ambient temperature, -40°C
b. Initial temperature, -40°C
c. Heat transfer to ambient by natural convection, still air
d. Heat transfer to ambient by radiation Page 2 of 13

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e. No solar insolation, in shade
f. Internal heat load as a uniform heat flux, 13.04 W/m² (200 watts)

Condition 4 - Cold Case 2:

a. Ambient temperature, -29°C
b. Initial temperature, -29°C
c. Heat transfer to ambient by natural convection, still air
d. Heat transfer to ambient by radiation
e. No solar insolation
f. Internal heat load as a uniform heat flux, 13.04 W/m² (200 watts)

Boundary conditions are applied to the RT-100 ANSYS model simulating the loading conditions the cask will experience during normal and accident transport conditions. Heat Conditions 1 and 3 bound the worst-case differential thermal expansion between dissimilar materials and meet the requirements of Regulatory Guide 7.8. The ANSYS analyses determine the stresses arising from the thermal expansion of the cask, lids, and bolts maximizing the thermal stress within the components. Pressure loads are applied to the cask inner shell to simulate bounding contents loads and internal pressurization. Bolt preloads are applied to represent the bolt torque at the time the cask is prepared for shipment. The calculated stress intensities are compared to appropriate ASME allowables and the margin of safety is calculated.

The following are a summary of the pressures presented in the SAR:

  • 182.71 kPa (26.5 psig) - Actual calculated minimum normal operating pressure (MNOP)
  • 241 kPa (35 psig) - MNOP (design)
  • 342.7 kPa (49.7 psia) - MNOP (design)

Values reported in gauge pressure (psig) are used as boundary conditions in various calculations. For the normal conditions stress analyses, the design MNOP of 241 kPa was used to bound the calculated MNOP value of 182.71 kPa and is used as the internal pressure for the Regulatory Guide 7.6 load combinations.

A separate pressure stress evaluation for HAC is presented in SAR Table 2.7.4-1 that shows a large margin of safety when compared to the allowable stress. From SAR Table 6-1, the combinations of Thermal Hot/Cold + Pressure + 0.3-meter impact provide the bounding loading combinations and worst-case stress for NCT.

Impact No change to the SAR as a result of this RAI.

RAI 2.2 Identify the maximum internal cask pressure employed in the various NCT evaluations and the hypothetical accident conditions (HAC) fire accident.

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SAR sections 2.6.1.1, 3.1.4 (table 3.1.4-1) and 3.3.2.5 indicate that a conservatively increased internal cask pressure of 342.7 kPa is employed for NCT evaluations, as well as some HAC evaluations, versus a calculated value of 182.7 kPa. However, SAR sections 2.6.3, 2.6.7.2.2, 2.7.1, 2.7.3.1.1, 2.13.2.1.1, 2.13.2.1.3 and Tables 2.13.3-1 and 2.13.3-2 indicate that a value of 242 kPa is employed. For HAC fire accident conditions, SAR sections 2.7.4.3.2, 2.13.2.1.2, 2.13.2.1.4, 3.1.4 (Table 3.1.4-1) and 3.4.3.2.5 indicate that a maximum accident internal cask pressure of 689.4 kPa is employed. However, SAR sections 2.6.7.2.2 and 2.7.1 indicate that a value of 588 kPa is employed. It appears that the gauge and absolute pressure values are being used interchangeably.

This information is necessary to demonstrate compliance with 10 CFR Parts 71.71 for NCT and 71.73 for HAC.

Response 2.2 All pressure values presented in the RT-100 SAR in kPa include in parentheses the associated pressure values in psig (gauge) or psia (absolute) to prevent confusion. Both gauge and absolute pressures were presented since some engineering calculations necessitate using absolute values, such as ideal gas calculations. Values reported in gauge pressures are used as boundary conditions in various calculations.

The summary below shows all pressure values presented in the RT-100 SAR:

  • Actual calculated minimum normal operating pressure (MNOP) - 182.71 kPa (26.5 psig) o This is the calculated MNOP. However, Robatel assumed 241 kPa MNOP as the design basis for further NCT calculations.
  • NCT Design MNOP - 241 kPa (35 psig) or 342.7 kPa (49.7 psia) o This is the MNOP value that was employed in all NCT structural analyses.

o In sections 2.13.2.1.1, and 2.13.2.1.3, 250 kPa instead of 241 kPa was used for conservatism.

  • HAC Pressure - 689.4 kPa (100 psia) or 588 kPa (85.3 psig) o This is the accident internal pressure that was used for all HAC calculations.

Impact No change to the SAR as a result of this RAI.

RAI 2.3 Demonstrate how the omission of thermal expansion effects in the evaluation of HAC drop conditions with hot ambient conditions results in the most unfavorable cask stresses.

SAR section 2.7.1 states that cask stresses induced by thermal expansion are not considered for the accident drop conditions. This approach follows neither the recommendations in table 1 of Regulatory Guide 7.8 nor section 2.4.6.1 of NUREG-2216 for hot initial ambient conditions.

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This information is necessary to demonstrate compliance with 10 CFR 71.73(b).

Response 2.3 The cask body analysis is documented in calculation RTL-001-CALC-ST-0402. The logic for determining stress criteria used to qualify the RT-100 as a containment vessel is:

  • The RT-100 is limited to a maximum of 3000 A2. From NUREG/CR-6407, Table 4, the RT- 100 is transportation Category II.
  • From the ASME code definition, Service Level A is equivalent to Normal Conditions and Service Level D is equivalent to Accident Conditions. For Service Level D, Subsection ND invokes the requirements from ASME Section III, Appendix F.

o From RG 7.6, secondary stress means a stress that is self-limiting. Thermal stresses are considered to be secondary stresses since they are strain-controlled rather than load-controlled, and these stresses decrease as yielding occurs.

o From RG 7.6, C. Regulatory Position 6. Under accident conditions, the value of the stress intensity resulting from the primary membrane stresses should be less than the lesser value of 2.4Sm and 0.7Su, (ultimate strength); and the stress intensity resulting from the sum of the primary membrane stresses and the primary bending stresses should be less than the lesser value of 3.6Sm and Su. These stress allowables coincide with ASME Section III, Appendix F (F-1341.1).

  • From ASME Section III, Appendix F, Table F-1200-1, General Note - the following design rules shall be followed: (1) Level D self-relieving stresses need not be considered unless specified within a specific section of Nonmandatory Appendix F.
  • From Appendix F, F-1400 Vessels: The rules given in F-1330 and F-1340 shall be used for evaluation of vessels for loads which Service Level D are specified. The RT-100 follows the rules of F-1330 acceptance criteria using elastic system analysis.
  • From Appendix F, F-1342, (a): Neither peak stresses nor stress results from thermal expansion within the support need to be evaluated.

Therefore, the RT-100 stress analysis follows the guidance for ASME Service Level D and does not include a thermal stress evaluation for HAC.

Impact No change to the SAR as a result of this RAI.

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RAI 2.4 Demonstrate that the most unfavorable closure bolt stresses for the applicable HAC loading combinations have been determined.

It appears that the temperature values presented in table 3.1.3-2 (for HAC pin puncture at top impact limiter) were employed in calculating the bolt stresses presented in SAR section 2.13.2.2.2. However, staff believes using the temperatures provided in SAR table 3.1.3-3 result in greater bolt stresses.

This information is necessary to demonstrate compliance with 10 CFR Parts 71.43(f) and 71.51(2).

Response 2.4 Refer to the RT-100 SAR, Revision 9, Sections 2.13.2.2.2 and 2.13.2.2.4 for the updated calculations utilizing HAC temperatures from Table 3.1.3-3 which demonstrate the most unfavorable closure bolt stresses. The updated values have no impact on the closure bolt load combinations in Section 2.13.3 since the HAC free drop loads bound the HAC temperature loads for the primary and secondary lid bolts.

Impact SAR updates to Sections 2.13.2.2.2 and 2.13.2.2.4.

RAI 2.5 Revise the SAR to address vibration-induced bolt loads including prying effects.

The applicant stated in their letter dated November 22, 2022 (ADAMS Accession No. ML22335A081), that the vibration-induced loads, based on a vertical loading of two times the lid weight, were not addressed in the SAR due to their low magnitude and insignificant contribution to overall bolt stress demand. The SAR needs to be updated to address these loads. When updating the SAR, the applicant should correct unit errors in the calculation provided in ML22335A081.

This information is necessary to demonstrate compliance with 10 CFR 71.71(c)(5).

Response 2.5 Refer to the RT-100 SAR, Revision 9, Section 2.13.2.8. Vibration-induced loads based on a vertical loading of two times the lid weight were calculated per the method presented in Table 4.8 of NUREG/CR-6007 and added to the SAR. Vibration-induced loads have no impact on the closure bolt load combinations in Section 2.13.3 since the NCT impact loads bound the NCT vibration loads for the primary and secondary lid bolts. Note that vibration loads were mistakenly combined with other loads in Robatels previous response dated November 22, 2022 (ADAMS Accession No. ML22335A081).

Impact SAR updates to Section 2.13.2.8.

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RAI 2.6 Address the following items on SAR tables 2.13.3-1 and 2.13.3-2:

a. The last two columns of the tables are labeled Prying Force and Prying Moment, however, the values listed are actually fixed-edge closure-lid forces and moments (i.e., Ff and Mf in NUREG/CR-6007).
b. Identify the source of the minimum preload Non-Prying Tensile Force and Torsional Moment values provided in both tables.
c. Check the table 2.13.3-2 entry for Puncture Non-Prying Tensile Force as it does not appear to agree with the value presented in SAR section 2.13.2.5.1.2.
d. Identify the source of the puncture, free drop (NCT) and free drop (HAC) Torsional Moment values provided in both tables.
e. Include vibration-induced loading in the tables.

The cited tables require updating to correct the headings, to list all of the imposed bolt loads, and to correct values as necessary to match those presented in the SAR. In the case of the minimum preload loading values presented, staff was unable to locate a rationale or calculation for these values in the SAR.

Similarly, the source of the torsional loads presented as resulting from puncture and NCT and HAC free drop conditions could not be located in the SAR. The applicant should confirm that the most unfavorable closure bolt stresses for all loading combinations have been determined after making the changes identified above. The applicant should confirm that the most unfavorable closure bolt stresses for all loading combinations have been determined after making the changes identified above.

This information is necessary to demonstrate compliance with 10 CFR Parts 71.51(a)(1) and 71.51(a)(2).

Response 2.6

a. Refer to the RT-100 SAR, Revision 9, Section 2.13.3. The headers of Tables 2.13.3-1 and 2.13.3-2 were updated with the correct titles in accordance with NUREG/CR-6007.
b. Refer to the RT-100 SAR, Revision 9, Sections 2.13.2.3.1 and 2.13.2.3.2. Minimum preloads and torsional moments were calculated for the primary and secondary closure bolts in accordance with NUREG/CR-6007. Tables 2.13.3-1 and 2.13.3-2 were updated accordingly.
c. Refer to the RT-100 SAR, Revision 9, Table 2.13.3-2. The puncture non-prying tensile force (Fa) was updated from 237.7 kN to 73.6 kN. The updated puncture load has no impact on the bolt load combinations in Section 2.13.3 since the HAC free drop loads bound the HAC puncture loads for both the primary and secondary lid bolts.
d. Refer to the RT-100 SAR, Revision 9, Tables 2.13.3-1 and 2.13.3-2. Torsional moment (Mt) values for puncture, free drop (NCT), and free drop (HAC) were deleted. According to Table 4.9 of NUREG/CR-6007, torsional bolt moment is generated only by the preload.

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e. Refer to the RT-100 SAR, Revision 9, Tables 2.13.3-1 and 2.13.3-2. Vibration-induced loads were added to both tables for the primary and secondary lid bolts.

Impact SAR updates to Section 2.13.2.3.1, Section 2.13.2.3.2, Table 2.13.3-1, and Table 2.13.3-2.

RAI 2.7 Demonstrate that low-cycle fatigue for lid closure bolts is not an issue and revise the SAR as necessary.

NUREG-2216 section 2.4.5.5 provides guidance to employ NUREG/CR-6007 for evaluation of fatigue bolt stresses. Table 6.2 of NUREG/CR-6007 references the American Society of Mechanical Engineers Code,Section III, Appendix I bolt fatigue stress acceptance criteria. It does not appear that the combined bolt loads determined in SAR sections 2.13.3.1 and 2.13.3.2 are evaluated against the American Society of Mechanical Engineers Code criteria.

This information is necessary to demonstrate compliance with 10 CFR 71.71.

Response 2.7 Refer to the RT-100 SAR, Revision 9, Section 2.13.4 and Appendix 2.16. The fatigue analysis is conducted in accordance with the methods presented in Table 6.2 of NUREG/CR-6007 based on the procedures provided in ASME Section III NB-3222.4(e), NB-3232.3, and Appendix I. Accordingly, the fatigue analysis is completed for normal conditions of transport using a minimum fatigue strength reduction factor of 4 and ASME fatigue curves I-9.4 with elastic modulus adjustment per Table 6.2.

Impact SAR updates to Section 2.13.4 and Appendix 2.16.

RAI 2.8 Provide a means to ensure that the stated minimum horizontal gap at all lid closure bolts is achieved prior to shipment and during transport to ensure that shear load transfer to the lid closure bolts is circumvented.

SAR section 2.13.2.1.1 states that shear load effects on the primary lid bolts are prevented due to designed gaps between lid and cask wall, and subsequently lid and bolt, including fabrication tolerances shown on the design drawings. The applicant explained in their letter dated December 14, 2022 (ADAMS Accession No. ML22356A047), that for all existing fabricated RT-100 models, the actual fabricated dimensions of the lids and bolts have been calculated and provide sufficient gaps to prevent the interior of the bolt holes from contacting the lid closure bolts in the pre-shipment condition. The applicants calculations employ the exact dimensions of existing containers and assume the lids will be installed concentrically around the bolts. However, were the lid to be installed nonconcentrically such that the interior of the lid bears on the inner diameter of the cask, the gap size is reduced to nominally 0.5 mm. Consider including a post-lid-Page 8 of 13

(Non-Proprietary Version) installation inspection procedural step to verify the minimum horizontal clearance dimension is realized for every bolt prior to shipment. For example, using a template around the perimeter of each bolt head to confirm that the minimum gap exists between the exterior surface of each lid closure bolt head and the interior of the associated bolt hole has the potential to address this concern. It is quite possible for this gap to be eliminated entirely during the installation of the lids or during thermal growth or shrinkage during transport conditions, thereby imparting shear loads to one or several of the lid closure bolts. To verify that there is no contact during transport conditions, consider performing a thermal analysis to show that the lid does not bear on any bolt during expansion or contraction conditions. It is not clear in the SAR whether the bolts have the capacity to withstand the additional shear loading, during either NCT or HAC loading combinations. The addition of an inspection step after completion of lid installation for each transport use emphasizes the importance of verifying this design aspect.

This information is necessary to demonstrate compliance with 10 CFR Parts 71.43(f) and 71.51(a)(1) for NCT and 10 CFR 71.51(a)(2) for HAC.

Response 2.8 Alignment pins are used to facilitate the lid placement and alignment during installation operations to ensure that the lid and bolt holes are concentrically aligned with the cask. Further, thermal expansion/contraction study is documented below to investigate the clearance during NCT and HAC transport cases.

r = r x (1 + T)

where, r = Final radius at temperature (mm) r = Initial radius (mm)

= Coefficient of thermal expansion (1/°C)

T = Change in temperature, T - T (°C)

As documented in Table 1, the maximum initial clearance between the primary lid and cask cavity is 1.4825 mm. The final clearance during NCT and HAC expansions are 1.4837 mm and 1.4854 mm, respectively.

Additionally, the final clearance between the lid and cavity during the cold case contraction is 1.4812 mm.

As documented in Table 2, the final clearance between the bolt shank and lid hole is 2.0068 mm and 2.029 mm during NCT and HAC expansions. Additionally, the final clearance between the shank and hole during the cold case contraction is 1.9929 mm. Therefore, the clearance between the primary lid and the cask cavity is less than the clearance between the primary lid M48 bolt and bolt hole during thermal expansion and contraction cases.

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Table 1. Primary Lid Vs. Cavity Parameter Unit NCT Expansion1 HAC Expansion2 Contraction3 Initial Temperature °C 21.1 21.1 21.1 Final temperature of cavity °C 71 137 -36 Final temperature of lid °C 71 137 -36 Coefficient of thermal expansion lid 1/°C 1.62E-05 1.66E-05 1.48E-05 Coefficient of thermal expansion cavity 1/°C 1.62E-05 1.66E-05 1.48E-05 Proprietary Information Content Withheld Under 10 CFR 2.390(b)

Initial gap mm 1.4825 1.4825 1.4825 Proprietary Information Content Withheld Under 10 CFR 2.390(b)

Final gap between lid and cavity mm 1.4837 1.4854 1.4812 Table 2. Primary Lid Hole Vs. Bolt Parameter Unit NCT Expansion HAC Expansion Contraction Initial Temperature °C 21.1 21.1 21.1 Final temperature of bolt °C 70 91.9 -34.9 Final temperature of lid °C 71 137 -36 Thermal expansion coefficient lid 1/°C 1.62E-05 1.66E-05 1.48E-05 Thermal expansion coefficient bolt 1/°C 1.21E-05 1.24E-05 1.11E-05 Proprietary Information Content Withheld Under 10 CFR 2.390(b)

Initial gap mm 2 2 2 Proprietary Information Content Withheld Under 10 CFR 2.390(b)

Final Gap between bolt hole and shank mm 2.0068 2.0290 1.9929 As documented in Table 3, the maximum initial clearance between the secondary lid and primary lid interface is 1.4980 mm. The final clearance during NCT and HAC expansions are 1.4992 mm and 1.5009 mm, respectively. Additionally, the final clearance between the lid interfaces during the cold case contraction is 1.4668 mm. As documented in Table 4, the final clearance between the bolt shank and lid hole is 2.0055 mm and 2.0217 mm during NCT and HAC expansions. Additionally, the final clearance between the shank and hole during the cold case contraction is 1.9943 mm. Therefore, the clearance between the secondary and primary lid interface is less than the clearance between the secondary lid M36 bolt and bolt hole during thermal expansion and contraction cases.

1 Thermal expansion coefficients at 100 from Table 2.2.1-1 of the RT-100 SAR.

2 Thermal expansion coefficients at 150 from Table 2.2.1-1 of the RT-100 SAR.

3 Thermal expansion coefficients are interpolated at -40 from Table 2.2.1-1 of the RT-100 SAR.

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Table 3. Secondary Lid Vs. Primary Lid Interface Parameter Unit NCT Expansion HAC Expansion Contraction Initial Temperature °C 21.1 21.1 21.1 Final temperature of cavity °C 71 137 -36 Final temperature of lid °C 71 137 -36 Coefficient of thermal expansion secondary lid 1/°C 1.62E-05 1.66E-05 1.48E-05 Coefficient of thermal expansion primary lid 1/°C 1.62E-05 1.66E-05 1.48E-05 Proprietary Information Content Withheld Under 10 CFR 2.390(b)

Initial gap mm 1.4980 1.4980 1.4680 Proprietary Information Content Withheld Under 10 CFR 2.390(b)

Final Gap between lid and cavity mm 1.4992 1.5009 1.4668 Table 4. Secondary Lid Hole Vs. Bolt Parameter Unit NCT Expansion HAC Expansion Contraction Initial Temperature °C 21.1 21.1 21.1 Final temperature of bolt °C 70 91.9 -34.9 Final temperature of lid °C 71 137 -36 Thermal expansion coefficient lid 1/°C 1.62E-05 1.62E-05 1.48E-05 Thermal expansion coefficient bolt 1/°C 1.21E-05 1.24E-05 1.11E-05 Proprietary Information Content Withheld Under 10 CFR 2.390(b)

Initial gap mm 2 2 2 Proprietary Information Content Withheld Under 10 CFR 2.390(b)

Final Gap between bolt hole and shank mm 2.0055 2.0217 1.9943 Impact No change to the SAR as a result of this RAI.

MATERIALS RAI 7.1 Provide additional details on how hydrogen generation, by either galvanic or chemical reactions, was accounted for in analyzing the package contents.

The applicant stated that the contents of the package may contain a mixture of spent resins, spent filters and activated hardware which may have a potential for hydrogen generation as a result of galvanic or chemical reactions. NUREG/CR-6673 is referenced in the application for the evaluation of hydrogen generation by radiolysis and to determine shipping duration. However, NUREG/CR-6673 only considers Page 11 of 13

(Non-Proprietary Version) hydrogen formation due to radiolysis and does not address hydrogen generation from chemical reactions, thermal degradation, or biological activity. In addition, Appendix A of NUREG/CR-6673 indicates that hydrogen generation by chemical reactions can be significant. The staff is unclear how the applicant made the determination that the package contents would not cause chemical or galvanic reactions that could generate hydrogen.

This information is required to meet the requirements of 10 CFR 71.43(d).

Response 7.1 As outlined in SAR Section 1.2.2.10, the RT-100 contents include dewatered or grossly dewatered spent resins/filters, and/or activated hardware contained within a secondary container. Per Section 2.1 of NUREG/CR-6673, for waste contents that are dewatered, solidified, or concreted, the hydrogen production due to chemical reaction should be minimal as long as the content constituents and materials of packaging are chosen so that there will be no significant chemical, galvanic, or other reaction among the packaging components, among the package contents, or between the packaging components and the package contents.

Packaging Components - Chemical reactions between components of the packaging are addressed in Section 2.2.2 and its subsections (see SAR pages 2-10 to 2-13). These packaging materials include stainless steel, lead, polyurethane foam, and the EPDM O-rings gaskets. Both the lead and polyurethane foam components are encapsulated in stainless steel. The conclusion in Section 2.2.2.4 that there is no potential for chemical or galvanic reactions between the individual packaging components.

Package Contents - The materials of the contents are discussed in SAR Section 3.2.3 including:

  • Resins - e.g., polystyrene, or material such as inorganic carbon or zeolite,
  • Filters - e.g., nylon, polyester, polypropylene, or paper, which may be held within a stainless-steel cartridge,
  • Activated hardware - solid metallic components including lower density aluminum and zirconium based metals and alloys and higher density steels and Inconel,
  • Secondary containers - coated/painted carbon steel, stainless steel, or a thermoplastic such as polyethylene or polypropylene, or
  • Shoring - wood or one or several of the materials comprising the secondary container.

Per EPA-600/2-80-0764, nearly all these materials fall under one of the two established Reactivity Groups:

Group 23. Metals, Other Elemental & Alloys as Sheets, Rods, Moldings, Drops, etc., or Group 101.

Combustible and Flammable Materials, Miscellaneous (see pages 70 and 77-78 of the referenced document). Using the waste compatibility chart (Figure 6 of the referenced document), no Reactivity code 4

Hatayama, et al., A Method for Determining the Compatibility of Hazardous Waste, EPA-600/2-80-076, 1980.

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(Non-Proprietary Version) is found in the corresponding Reaction Square between these two Groups, so the two groups of waste are considered compatible.

Additionally, to ensure that there will be no flammable gas generation due to chemical reactions among the package contents, Step 2 of the RT-100 content loading procedure (see Section 7.1.2.1 on SAR page 7-7) requires that for each shipment in the RT-100 the package user: Ensure that the contents, secondary container, and packaging are chemically compatible (i.e., will not react to produce flammable gases).

Furthermore, CoC No. 9365 Condition 6.(a) requires that the package be prepared for shipment in accordance with the operating procedures of Chapter 7 of the SAR.

Packaging Components and Package Contents - The cavity of the packaging is composed exclusively of stainless steel. So, no chemical or galvanic reactions between the package contents and the stainless steel packaging components resulting in the generation of flammable gases will occur.

A combination of the assessment of the packaging and content materials and the requirement for the user to assess the contents of each package individually prior to each shipment ensures the chemical compatibility of all materials to eliminate the possibility of significant hydrogen gas generation through chemical or galvanic reactions.

Impact No change to the SAR as a result of this RAI.

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