Summary of February 24, 2011 Management Meeting with International Isotopes Inc. 

Regarding Application 

Review for Proposed Deconversion Facility 

DATE: February 24, 2011 

PLACE: U.S. Nuclear Regulatory Commission (NRC) 

 Rockville, Maryland 

ATTENDEES: See Enclosure 2 

PURPOSE: 

The purpose of this meeting was to discuss management issues and project status related to 

the International Isotopes Fluorine Products Inc. (IIFP) license application for the Fluorine 

Products and Depleted Uranium Deconversion Facility. 

DISCUSSION: 

The status of the application review was discussed. IIFP received formal Requests for 

Additional Information (RAIs) beginning in September 2010 and the final RAIs were provided 

December 21, 2010. The formal Environmental Impact Statement (EIS) RAI responses were 

due by January 21, 2011, and the formal Safety Evaluation Report (SER) RAI responses were 

due by February 4, 2011. The review milestones and potential impacts on the schedule were 

discussed. IIFP continues to develop the RAI responses and anticipates completing the formal 

submittals by March 2011. Extension of the formal RAI response dates beyond the January 

21/February 4, 2011, is expected to have a day for day impact on the completion date of the EIS 

and SER. The U.S. Nuclear Regulatory Commission (NRC) staff indicated that these projected 

dates will continue to be revised until receipt of the formal RAI responses. The dates may also 

be impacted by other safety issues, the Commissions directions, or scheduling factors beyond 

the staff’s control. 

The NRC staff notified IIFP that a sub-committee of the Advisory Committee on Reactor 

Safeguards (ACRS) has expressed an interest in receiving an information briefing on the IIFP 

project. Both IIFP and the NRC staff will need to provide briefings to the sub-committee on the 

project and the review, respectively. The briefing is not anticipated to impact the overall review 

schedule for the SER. The NRC staff does not believe a formal letter from the ACRS is needed 

to support the review. 

IIFP is evaluating a number of bids for the design/build contract. Previously, IIFP indicated RAI 

responses for seismic/structural and human factors were awaiting development support from 

the design/build contractor. However, IIFP now plans to use bounding calculations and 

commitments to industry standards to address the remaining RAIs. The applicant is also 

evaluating whether to submit a pre-construction exemption request. Such a request will require 

at least six months to process. The exemption review generally requires an environmental 

assessment. 

IIFP’s application requests a 40 year license term. Historically, Part 40 fuel cycle facilities were 

granted a maximum of 10 year license terms. However, the requirement to conduct an 

Integrated Safety Analysis (ISA) has previously been used for certain Part 70 facilities as a 

basis to allow up to 40 year licenses. IIFP is subject to the same ISA Part 70 requirements. 
Therefore the applicant intends to submit a letter summarizing their basis for requesting a 40 

years license. 

IIFP inquired if the government’s continuing resolution would impact the NRC’s review. The 

NRC staff has budgeted sufficient resources to complete the INIS SER in 2011 and the EIS in 

the Spring of 2012. Based on the proposed schedule, the bulk of the budgeted resources in 

2012 will be shifted to construction inspections. IIFP and the NRC staff should work to complete 

the application within the projected schedule. 

After the business portion of the meeting, members of the public were given an opportunity to 

ask questions or make comments. No additional questions were provided