Enclosure 2 

Publically Available Summary of Closed Meeting 

Integrated Safety Analysis for International Isotopes Inc., Hobbs, NM., 

Depleted Uranium Facility 

DATE AND TIME: May 7, 2009, 11:00pm – 12:30pm 

MEETING PARTICIPANTS: NRC INIS

 Thomas Hiltz, NMSS John Miller, CHP/RSO 

 Michael Raddatz, NMSS Jim Thomas, APTS-Consultant 

 Matt Bartlett, NMSS Ron Green, ISA-Contractor 

 Yawar Faraz, NMSS 

 Dennis Damon, NMSS 

INTRODUCTION

International Isotopes Inc. (INIS) met with the Office of Nuclear Material Safety and Safeguards 

on May 7, 2009 to provide an overview of their integrated safety analysis (ISA) and seek input 

from the staff. INIS delivered a slide presentation (ML091340328), followed by a general 

discussion. Since Part 40 does not currently contain ISA requirements, and consistent with the 

Commission’s direction in SRM-SECY-07-0146, the U.S. Nuclear Regulatory Commission 

(NRC) will impose the ISA requirements through orders. The staff indicated the orders would 

require an ISA similar to Part 70, Subpart H. 

DISCUSSIONS

INIS began by providing a summary of their facility which would consist of three main buildings. 

Depleted uranium hexafluoride (DUF6) will be received from a client’s facility in 14 ton cylinders 

and processed into the system through four autoclaves. The DUF6 will be hydrolyzed into 

depleted uranium tetrafluoride (DUF4) and anhydrous hydrogen fluoride (HF). This will be 

further processed to produce high purity fluorine products. The fluorine products and HF will be 

sold commercially, and the depleted uranium oxide will be dispositioned according to 

requirements. 

After the opening summary, INIS delivered a slide presentation on the status of their ISA. After 

the slide presentation, the staff asked if a similar deconversion facility had ever been licensed 

previously. INIS stated their Idaho Falls, Idaho facility uses a similar process to produce high 

purity germanium tetrafluoride gas from DUF4 and germanium oxide which provides relevant 

experience. The former Sequoya Fuels facility employed similar steps as the DUF6 to DUF4

conversion; however, the overall process will be unique to the Hobbs, New Mexico facility. The 

contractor developing the ISA has practical experience from Babcock and Wilcox Nuclear 

Operation Group, Nuclear Fuel Services, Inc., and the Paducah Gaseous Diffusion Plant. The 

ISA contractors plan to follow guidance in Chapter 3 of NUREG-1520 as closely as possible. 

The staff agreed that following NUREG-1520 was appropriate. 

INIS emphasized that the new facility had low radiological risks. The plant will be primarily a 

chemical facility without risks of criticality due to the processing of depleted uranium. This 

reduces the number of accident sequences compared to a fuel fabrication facility and the 

primary hazard is exposure to HF. INIS indicated that for a DUF6 release accident sequence, 

exposure to HF would be the controlling factor. Therefore, ensuring protection from HF would 

ensure protection from exposure to soluble uranium. 
2

The ISA will rely on the risk assessment ideologies described in NUREG-1520, but a fault tree 

analysis is not anticipated to be necessary. Items relied on for safety (IROFS) are currently 

under development, with most accident sequences being assigned a single IROFS. The staff 

recommended consideration of the use of multiple IROFS for accident sequences. The benefits 

of this option must be weighed against the added burden of maintaining additional IROFS. 

The staff recommended careful consideration of the requirements in 10 Code of Federal 

Regulations Part 70.61. Any item that can credibly fail, including administrative measures, and 

is used to meet the performance requirements, must be identified as an IROFS. The boundary 

of each IROFS should be clearly defined. Although not required, INIS was urged to consider 

developing IROFS boundary manuals as was done for other 10 CFR Part 70 facilities recently 

licensed by the NRC. The benefit of these manuals to both the applicant and the NRC is 

especially beneficial during preoperational inspections. The configuration management 

program should ensure IROFS are not removed or modified unintentionally during maintenance. 

The applicant should be prepared to demonstrate compliance with applicable acceptance 

criterion listed in NUREG-1520. Although INIS is not expected or required to have a final design 

of the IROFS at the time of submitting the application, INIS was encouraged to provide sufficient 

information describing each IROFS, so the NRC reviewer can understand the safety function 

and design rationale for the IROFS. INIS was encouraged to avoid replacing design information 

with blanket statements, such as the “system is adequate.” The staff recommended INIS to 

maintain a list of both credible and non-credible accident sequences, which facilitates NRC’s 

review process. 

 

The staff encouraged INIS to carefully consider which information from the ISA Summary needs 

to be withheld. In general, portions of the ISA Summary such as IROFS and descriptions of 

accident sequences and other security-related information should be withheld from public 

disclosure. Generic information such as the ISA methodology, however, should be publically 

available. An affidavit is not required for withholding security related information. Business 

proprietary information must be accompanied by an affidavit, and INIS must provide a sound 

basis for withholding such proprietary information. 

PRINCIPAL CONTRIBUTORS

Matt Bartlett, Project Manager 

Yawar Faraz, ISA Reviewer