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The following information is necessary for INIS to demonstrate compliance with10 CFR 40.36(a), 

(c) (1), and (d). 

D-1. In Section 10.1.3.8 of the application, INIS states that evaluation of the final radiation survey is 

based in part on an initial radiation survey performed prior to operations. The initial survey 

determines the natural background radiation of the area; therefore, it provides a baseline datum 

for measurements which determine any increase in levels of radioactivity. This initial radiation 

survey is not described in the application. Since uranium-238 and its decay products are likely to 

be present in the background, perform a baseline environmental survey of the site that is 

adequate to stand as a valid background survey for eventual decommissioning. 

RESPONSE: IIFP will use NUREG-1575, NUREG-1505 and NUREG-1757 in developing both 

the initial survey for background determination and the final survey to be conducted after 

decommissioning in order to accomplish the free release of the site. Although the Radiological 

Environmental Monitoring Plan (REMP) which will include plans for the initial survey has not 

yet been developed, the initial sampling will be similar to the final survey sampling and 

approximate that final survey as indicated in Section 10.1.3.8. For the initial survey, the majority 

of the samples collected may be held for analysis at a later date prior to decommissioning, but 

some of these samples will be analyzed for informational purposes. Since IIFP will process only 

depleted uranium, it is anticipated that surveys will include the U-238, U-235 and U-234 isotopes 

of uranium.

Licensing Documentation Impact (1): The third paragraph in Section 10.1, Decommissioning 

Strategy, of the IIFP License Application will be revised to include the following wording: 

At the end of useful plant life, the FEP/DUP Facility will be decommissioned such that the site 

and remaining facilities may be released for unrestricted use as defined in 10 CFR 20.1402 (CFR, 

2008b). IIFP will use guidance provided in NUREG-1505, NUREG-1575 and NUREG-1757 in 

developing initial and final site survey plans sufficient to provide background and postdecontamination site condition to enable the free release of the site.

Licensing Documentation Impact (2): Section 10.1.3.8, Final Radiation Survey, of the IIFP 

License Application will be revised as follows: 

A final radiation survey must be performed to verify proper decontamination to allow the site to 

be released for unrestricted use. The evaluation of the final radiation survey is based in part on an 

initial radiation survey performed prior to initial operation. The initial survey determines the 

natural background radiation of the area; therefore it provides a datum for measurements which 

determine any increase in levels of radioactivity. Since only depleted uranium will be processed 

at the IIFP Facility, the initial and final site surveys required as part of the decommissioning 

process will include isotopic analysis for the U-238, U-235 and U-234 isotopes of uranium.

The final survey will systematically and representatively measure radioactivity for the entire site

and will be designed to detect any unreported spills and any generalized contamination that might 

accumulate over the period of operation of the facility. The intensity of the survey will vary 

depending on the location (i.e. the buildings, their immediate areas, and the remainder of the site). 

Throughout the operating life of the facility, routine surveys will be are conducted of licensed 
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material areas and records will be maintained. These survey records will be used in conjunction 

with the REMP as part of the final survey evaluation and may reduce the amount of sampling in 

some areas where the survey history indicates that no contamination has occurred. shows low 

potential for contamination. The final survey in some cases is a verification of historical surveys.

The survey procedures and results will be documented in a report which will include. The report 

will include, among other things, a map of the survey site, measurement results, and the site’s 

relationship to the surrounding area. The results will be analyzed and shown to be below 

allowable residual radioactivity limits; otherwise, further decontamination will be performed.

For decommissioning funding purposes, the final site survey will consist of samples being

samples will be taken within the 40-acre IIFP Restricted Area as well as at other locations outside 

the Restricted Area but within the 640-acre site boundary 12.1 ha (40acre) FEP/DUP Restricted 

Area (area within the security fence). Inside the Restricted Area, sSamples will be taken based on 

a sampling grid pattern of approximately 91 m by 91 m (100 yd by 100 yd). Additional samples 

will be collected within an area extending 10 feet from process building walls on the basis of one 

sample per 100 ft2 (i.e., one sample for every 10 feet of building perimeter). It is unlikely that the 

area outside the Restricted Area but within the site boundary will be contaminated. Outside of the 

Restricted Area, but within the site boundaries, the likelihood for contamination is extremely 

remote. Therefore, the grid will be expanded for this area such that samples will be taken on a 

grid pattern of approximately 610 m by 610 m (667 yards by 667 yards). The aAnalysis of the 

samples will be provided by a third party since, at the time of performance of the final radiation 

survey, no analysis facilities will be available on site. A similar collection of samples will be 

performed for the initial site survey as part of the REMP to provide a background against which 

the final site survey will be compared.

 
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D-2. In the Environmental Report, Section 6.1.2, “Radiological Environmental Monitoring Program” 

(REMP), INIS describes the REMP and proposes to initiate it at least 12 months prior to plant 

operations. However, the REMP includes only five soil samples and does not identify the 

isotopes for which the samples will be analyzed. NUREG-1757 (see reference below) includes 

guidance for determining background radiation. Consistent with the guidance in NUREG-1757, 

demonstrate a more rigorous initial survey than that described in the application and ER. 

Provide the sampling locations inside the footprint of the buildings and along the perimeter. Also 

identify the isotopes for which the soils will be analyzed. 

The following NRC references contain NRC guidance for determining background radiation and 

selecting background reference areas: 

 NUREG-1757, Consolidated Decommissioning Guidance, Volume 2 Characterization, 

Survey, and Determination of Radiological Criteria, Volume 2, Revision 1, September 2006; 

 NUREG-1505, A Nonparametric Statistical Methodology for the Design and Analysis of 

Final Status Decommissioning Surveys, Revision 1, June 1998,Section 2.2.5; and 

 NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), 

Revision 1, August 2000, Section 4.5. 

RESPONSE: The REMP has not been developed at this time. However, IIFP is committing to 

the use of guidance provided in NUREGs 1505, 1575 and 1757 in the response to 

decommissioning question D-1. The numbers of samples to be collected for the initial survey and 

their locations have not yet been determined, but IIFP is committed to perform this survey 

sampling prior to construction. More specific information can be provided after the REMP has 

been developed and written. It is anticipated that sample analysis for the U-238, U-235 and U-234 

isotopes of uranium will suffice since only depleted uranium will be processed at the facility. 

Building footprint and perimeter sampling has not been determined for initial site sampling since 

the REMP has not yet been developed. However, since the building structures are expected to be 

decontaminated and left standing, the final site survey will include sampling of the floors of those 

structures for residual contamination at a frequency of one sample per 100 ft2

. Process building 

perimeter sampling for the final site survey will involve collecting samples at 10 foot intervals 

and within a distance 10 feet from the walls of the structures resulting in one sample per 100 ft2

around the perimeter of the structures.

License Documentation Impact: Sections 10.1, Decommissioning Strategy and 10.1.3.8, Final 

Radiation Survey, of the IIFP License Application will be revised as indicated in response to 

question D-1. 

 
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D-3. Section 10.1.3.8, Final Radiation Survey, of the LA describes the initial survey and a final survey 

that will systematically measure radioactivity over the entire site. Tables 10-10, 10-11, and 10-

12 of the LA do not specifically include a final survey of site soils. Notes 1 and 2 to these tables 

state that there is a low likelihood of contaminating the facility grounds at levels that would 

require excavation or restoration, and small spills will be cleaned immediately. 

 Specify that the final status survey will be designed to detect any unreported spills and any 

generalized contamination that might accumulate over the period of operation of the facility. 

Identify the parameters or isotopes for which the grid samples will be analyzed, and describe how 

these results will be compared to the initial survey results to demonstrate that the site is suitable 

for unrestricted release. Revise the Decommissioning Cost Estimate (DCE) to include costs for 

designing and performing a final survey of the site. 

RESPONSE: Revisions are being made to Section 10.1.3.8 of the LA (See response to RAI D-1) 

to reflect the intent to detect unreported spills and generalized contamination. The isotopes for 

which grid samples will be analyzed are also being included in this revision. However, IIFP 

expects both routine and REMP monitoring to also be important in the identification of such 

occurrences. IIFP contends that the most comprehensive sampling will be performed in 

conjunction with normal facility operations over the lifetime of the facility and that this 

information will be at least as useful as samples obtained at facility closure. IIFP proposes to use 

this extensive amount of historical information in the development of its decommissioning plan 

rather than depending solely on the use of grab samples collected at the end of the facility’s 

lifetime. Once final site survey results are obtained, they will be compared to the initial survey 

results using guidance provided in NUREGs 1505, 1575 and 1757. 

Final survey labor costs are shown in the Decommissioning Funding Plan (DFP) but originally 

did not include soil sampling and analysis costs. Estimates for these costs will be made based on 

the final site survey grid provided in LA Section 10.1.3.8 and will also include process building 

perimeter sampling as specified in this revised section. The draft responses for the Financial 

Assurance RAIs have already been submitted. These soil sampling and analysis costs will be 

included in applicable Chapter 10 Tables as an update in the final Financial Assurance RAI 

responses.

License Documentation Impact (1): Section 10.1.3.8, Final Radiation Survey, of the IIFP 

License Application will be revised as indicated in response to question D-1. 

License Documentation Impact (2): The third bullet in Section 10.1.2.2, Radioactive 

Contamination Control, will be revised to include the following information: 

Routine radiological surveys will be conducted throughout the operating lifetime of the facility 

facilities’ operations life that will minimize the likelihood that radioactive contamination goes 

undetected and will provide a historical record which will simplify the site characterization 

process. The historical REMP will also be used to provide guidance for the final site survey. 

Samples will be collected to verify the historical data collected via the REMP. Additional 

samples will be collected if areas of contamination are found.