International Isotopes Inc,

May 6, 2011

ATTN: Document-Control Desk

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

Subject: Submittal of Responses to Requests for Additional Information (RAI)

TAC L32739.

To Whom it May Concern,

The following documents are provided as a response to the US Nuclear Regulatory Commission

RAIs pertaining to the International Isotopes Fluorine Products Inc. December 30, 2009

application to license a depleted uranium hexafluoride de-conversion and fluorine extraction

process facility.

(1) Official Responses to Seismic and Structural RAIs - Public Version

(2) Official Responses to Seismic and Structural RAIs - Security Related Information

(3) Drawing Package - Security Related Information

Please contact me by phone at 208 524-5300 or email at jimillergintisoid.com if you have any

questions regarding this letter or require additional information.

Sincerely,

John J. Miller, CHP

Radiation Safety Officer

JJM-2011-32

Enclosure as Stated

cc: Dr. Matthew Bartlett

U.S. Nuclear Regulatory Commission

Mail Stop E2C40M

6003 Executive Blvd.

Rockville, MD 20852

4137 Commerce Circle, Idaho Falls, Idaho 83401

Phone: 208-524-5300, 800-699-3108 Fax: 208-424-1411

Website: www.intisoid.com
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAls

SS-1. Backzround.:

The LA and ISA Summary include several typographical errors.

Issue:

Minor typographical errors were found in various sections of the LA and ISA Summary. These

errors need to be corrected.

Request:

1. Correct the ground acceleration from 0. 03g to 0. 05g in the sentence that states, "The Peak

Horizontal Ground Acceleration for a 1,000 and 2,500 year return is 0. 03g and 0. 12g

respectively (USGS, 2002)" on Page 1-43 of the LA.

2. Correct the temperatures listed in LA Table 1-6 on Page 1-39.

3. Correct the section reference in LA Section 3.2.1 (Page 3-4) which states, "A description of

the IIFP Site is contained in ISA Summary, Section 2 and a summary description is in LA

Chapter 1. "Section 2 should be Section 1 instead.

4. Correct the section reference in LA Section 3.2.2 which states, "the ISA Summary (Section 3)

provides a description of the IIFP Facility. "Section 3 should be Section 2.

5. Correct the column labels on the total snowfall in ISA Summary Table 1-1 (Page 1-6) and

verify that the values listed in the table are correct.

6. Correct the temperatures listed in ISA Summary Table 1-2 (Page 1-7).

7. Items 1-6 are some examples. Please review the application to remove such errors.

RESPONSE:

1. The Peak Horizontal Ground Acceleration for a 1,000 return is 0.05g instead of the 0.03g

as incorrectly stated in LA Section 1.6.4.2.

License Documentation Impact: The fourth paragraph of LA former Section 1.6.4.2 - now

Section 1.7.4.2 (RAI-RP 13) and former Table 1-7 (now Table 1-8, see RAI GI-9D) will read:

Probabilistic ground motion for the sites is also shown in Table 1-78. Seismic activity is well

documented as the result of !he -NFg-LA licensing activities of an enrichment facility located near

Eunice. New Mexico and the extensive network of seismometers established for a Waste Isolation

Pilot Plant (WIPP) facility near Carlsbad, New Mexico. The Peak Horizontal Ground

Acceleration_(pea) for a 1,000 and 2,500 year return is 0.,30.05g and 0.12g respectively (USGS,

2002).

Table 148_Seismic Criteria for New Mexico Site

P=1I/T EP=I-(I-P)" n=50 years

T 500 yrs 1000 yrs 2500 yrs

P 0.002 (.2%) 0.001 (.1%) 0.0004 (.04%)

EP 0.1 (10%) 0.05 (5%) 0.02 (2%)

n 50 yrs 50 yrs 50 yrs

pga 0.03g 'i 0.05g (2) 0.12(2)

Weber, 2008; (2 USGS, 2002

Official Responses to Seismic/Structural RAls Page I
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

RESPONSE:

2. The negative sign for the Celsius temperatures listed in LA Table 1-6 on Page 1-39 was

inadvertently omitted.

License Documentation Impact: Temperatures in former Table 1-6 - now Table 1-7(see RAI

GI-9D) of Revision A of the IIFP License Application and the temperatures in Table 3-17 of

Revision A of the IIFP Environmental Report (see also RAI GI-1OA) will be revised as follows:

21.7 'C (-7 'F) will be revised to -21.7 'C (-7.1 ') for January 11, 1962.

23.9 'C (-11 F) will be revised to -23.9 'C (-11 F) for February 1, 1951.

16.1 'C (3 'F) will be revised to -16.1 'C (3 'F) for December 8, 2005.

RESPONSE:

3. The ISA Summary Section 1 provides a site description which focuses on those factors

that could impact safety (geography, meteorology, seismology, etc.) of the site and

surrounding area.

License Documentation Impact: The second sentence of the IIFP License Application Section

3.2.1 will be revised to read as follows:

The ISA Summary (IIFP, 2009) provides a description of the IIFP Facility and the surrounding

Owner Controlled Area (herein referred to as the IIFP Site). A description of the IIFP Site

focusing on those factors that could impact safety is contained in ISA Summary, Section _21 and a

summary description of those factors is in LA Chapter- * Section 1.6.

RESPONSE:

4. The ISA Summary Section 2.1, "Overview of Facility Site," provides a layout of the

facilities on the site with a summary description of the facilities and the location of those

facilities.

License Documentation Impact: License Application Section 3.2.2 will be revised as follows:

The ISA Summary (Section -.2._1) provides a description of the IIFP Facility. A summary

description of the IIFP Facility is provided in LA C hapter- 1 Section 1.1.

RESPONSE:

5. The ISA Summary Table 1-1 was inadvertently corrupted when copying and editing

Table 3-18 of the Environmental Report to the LA.

License Documentation Impact: Table 1-1 of Revision A of the IIFP Integrated Safety

Analysis Summary will be deleted and replaced with revised (see RAI GI-10A) ER Table 3-18

above and be numbered as Table 1-I in the LA. The renumbered Table 1-1 will incorporate

Official Responses to Seismic/Structural RAIs Page 2
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

changes to ER Table 3-18 (in response to RAI GI-1OA) listing the mean snowfall for 1976 as 0.25

cm instead of 0.025 cm and the annual mean snowfall will be corrected from 12.95 cm (5.1 in) to

11.93 cm (4.7 in).

RESPONSE:

6. ISA Summary Table 1-2 will be revised as stated below and as in the response to RAI

GI-10 A.

License Documentation Impact: The low extreme temperatures in Table 1-2 of Revision A of

the IIFP Integrated Safety Analysis Summary and Table 3-17 of Revision A of the IIFP

Environmental Report will be revised as follows:

21.7 'C will be revised to -21.7 'C for January 11, 1962.

23.9 'C will be revised to -23.9 'C for February 1, 1951.

16.1 'C will be revised to -16.1 'C for December 8, 2005.

RESPONSE:

7. The LA is currently under review in response to the RAIs as well as a general review for

typos or corrections need to be made.

License Documentation Impact: Once agreement has been attained on IIFP's response to the

LA RAIs, the LA will be revised and submitted to the NRC as Revision B.

Official Responses to Seismic/Structural RAIs Page 3
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

SS-2. Background.:

The regulations in 10 CFR 70.64(a) (2) require the applicant to include adequate protection

against natural phenomena in its design of the facility, and 10 CFR 70.62(c)(iv) requires the

applicant to conduct and maintain an ISA that identifies potential accident sequences caused by

credible external events. In addition,

10 CFR 70.61(b) and 70.61(c) require the applicant to demonstrate that an accident event can be

excluded from further consideration based on either its likelihood or its consequences.

Issue:

The applicant discussed the historical data of tornado, straight wind, snow, rain, and flood at the

facility site in LA Sections 1.6.3.3, Severe Weather, and 3.2.5.2, Hazard Identification; ISA

Summary Sections 1.3.2, Severe Weather, 4.4.2, Natural Phenomena Hazards, and 5.2.1 Hazard

Identification Method, and Tables 3-6, FEP/DUP Facility Hazards Identification and 5-3,

FEP/DUP Facility Hazard Identification Checklist. The applicant concluded in the ISA Summary

Table 5-3 (Items 18.4, 18.5, and 18.6) that the rain, snow, and straight wind are low-risk hazards

for the IIFP Fluorine Extraction Process & Depleted Uranium De-Conversion Plant (FEP/DUP).

The justification the applicant provided for this determination at the end of ISA Summary Section

5.2.1 is not sufficient for the NRC staff to determine whether the justification is acceptable

because the applicant did not providejustification on its low-risk determination. Nor, did the

applicant characterize these hazards at an annual probability level consistent with their risk

level. The applicant did include tornado-generated missiles as a hazard for consideration of the

process equipment located outside the buildings. However, the applicant did not indicate the type

of missiles it considered in its ISA.

Request:.

1. Characterize tornado and tornado-generated missile, straight wind, snow, rain, and flood

hazards at an annual probability level (i.e., not unlikely, unlikely, or highly unlikely)

consistent with their risk (i. e., low, intermediate, or high chemical or radiological

consequence).

2. Provide technical basis to justify the perceived risk levelfor each of the hazards identified in

Item 1.

RESPONSE:

1. Characterizations of tornadoes/winds, snow, rain and flood hazards have been performed.

The following includes a discussion of those characterizations and changes to be made to

Revision A of the IIFP Integrated Safety Analysis Summary.

Floods/Rain

It was determined that the information provided regarding "Floods" in former section 1.3.2.8

(now Section 1.3.2.6, in response to RAI GI-10D) of Revision A of the IIFP Integrated Safety

Analysis Summary was insufficient in its scope. This section was expanded to explain design

Official Responses to Seismic/Structural RAIs Page 4
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

basis flooding considerations. A preliminary flood hazard assessment for the IIFP Facility was

performed using Department of Energy (DOE) documents DOE-STD-1020-2002, DOE-STD1022-94 and DOE-STD-1023-95, and it was determined that a comprehensive flood hazard

assessment is not required. Preliminary screening indicates that flooding is not a design basis

event other than in consideration of storm water runoff which will be included in the detailed

facility design with an engineering margin for storm sewer loading.

Guidelines in the following Department of Energy (DOE) documents were used to perform a

flood hazard assessment for the IIFP Facility near Hobbs, NM: DOE-STD-1020-2002, DOESTD-1022-94 and DOE-STD-1023-95. Based on the information included herein and the

guidance provided in these documents, it was determined that a comprehensive flood hazard

assessment is not required. Preliminary screening indicates that flooding is not a design basis

event other than in consideration of storm water runoff which will be included in the detailed

facility design.

All-season precipitation estimates for the IIFP Site are provided by the National Weather Service

(NWS) and the National Oceanic and Atmospheric Administration (NOAA) in the "Point

Precipitation Frequency Atlas of the United States, NOAA Atlas 14 (Bonin, et.al., Revised 2011)

and its associated database. Using a linear least-squares regression procedure to extrapolate

NOAA's precipitation estimates to an average recurrence interval of 100,000 years, it was

determined that the 1-hour, 24-hour, and 48-hour all-season precipitation estimates for 1.0 x 10-5

annual probability are 7.2 inches, 14.4 inches, and 17.0 inches respectively.

Based upon the above precipitation estimates for the site and information presented in Table 3-24

(former 3-2 1) of the IIFP "Environmental Report", the facility will be designed to prevent

flooding from extreme precipitation of short duration. In the area north and northwest of the

developed IIFP Site, berms will be added or the terrain will be contoured to divert run-on water

around the site so that only precipitation that falls on the site itself will affect the facility design.

The site storm sewer will be designed for a 17.0 inch rainfall over a 48-hour period (1 x 10-5

annual probability). Structures containing SSCs are constructed above grade level and above the

level of plant roadways in order to physically remove (elevate) them from potential floodwater.

Structures will be provided with curbing a minimum of 12 inches in height in order to prevent

internal spills (in such an event) from leaving the structure; this curbing also serves as flood

barriers for these structures.

Tornado/Wind

The evaluation of tornadoes and straight winds was made based on NUREG/CR-4461, Revision 2

(February, 2007) including data in Appendices A, B and C of the NUREG. This NUREG guide

provides calculations based upon 46,800 tornado segments occurring from January 1, 1950

through August 2003 of which more than 39,600 had sufficient information on location, intensity,

length, and width to be used in the analysis included in this report. NUREG/CR-4461, Revision 1

had been published in April 2005. The National Weather Service changed from using the Fujita

Scale to the Enhanced Fujita Scale in February 2007. Revision 2 incorporates the Enhanced Fujita

Scale in its methodology and calculations. Specifically, Chapter 5 of the NUREG has been

revised to show lxl05 , 1x10 6 , and 1x10 7 probability design wind speeds (i.e., probability of

Official Responses to Seismic/Structural RAls Page 5
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

exceeding that wind speed in one year) for the contiguous United States estimated using the

above database and the Enhanced Fujita Scale. (NCDC, 201 Ob)

The two-degree box where the IIFP site is located is in Region 2. While the two-degree and fourdegree boxes are considered to be more reliable since they contain data for more events, the

document does allow the use of the one-degree data if the number of events is large enough to

provide accurate calculations. Instructions for using the NUREG Appendix C, Results for onedegree boxes state that the data set should contain a minimum of 10 events with 20 or more

events being desirable. There were 76 events reported for the one degree box whose SE corner is

the 320/1030 gridline. Of these, 56 were used in the calculations. The four-degree box uses data

from 364 events of the 435 events observed.

The data from the above NUREG appendices for the one-degree, two-degree, and four-degree

boxes are used. The maximum tornado wind speeds versus return period for each box are plotted

on the same chart with the straight gust wind speed data (DOE-1020-2002, Table 3-2) versus

return period for sites with basic gust wind speed of 90 mph (per USGS maps as adopted by the

model building codes). All three tornado wind speed curves intersect the straight gust wind speed

curve at approximately a 1 x 10 7 year return period or a probability of exceeding of 1 x 10-7.

DOE-STD-1022-2002, Appendix D, Paragraph D.2 states that, generally, straight and hurricane

winds control the criteria for probabilities down to about 10-4. Therefore, straight gust wind

speeds will be used as the wind design basis for building design at the IIFP Facility.

a 10000000

RETURN

PERIOD

(YRS)

1000000

100000

10000

1000

100

10

1

Stra iehtGust WindSeed=vs=o •na do=Wi nd.-Seedfor-2,&4FDereeBoxes

jTOR'NADO WI

4' BOX, 10 BOX, 20 BOX --

-I _I-.I- . - -~z If ---

~1 

.- i--l-- - i -. o- -f . I

I

4T ~ I

ju.

-I

r UT-~ 4ii IST-WINflS H- . U..- ANID.

t ~-t

_7

.. ... ... .... ....I .. .- -------- - ------- . . ..... .... ... .

0 50 100 150

WIND SPEED (MPH)

200 250 300

Legend: 40 Box - Red; 1' Box - Green; 20 Box - Blue

Official Responses to Seismic/Structural RAIs Page 6
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

Note: See the discussion of straight winds below for the derivation of basic gust wind speeds

versus probability used in the plots discussed above.

Design wind speeds for all buildings and structures that do not contain licensed material or for

buildings and structures containing chemicals or processes that do not affect licensed material

will be determined in accordance with the applicable model building codes (New Mexico

Commercial Building Code (NMCBC, 2006) and American Society of Civil Engineers (ASCE 7-

05) or latest editions adopted by the State of New Mexico at time of design). Specifically, these

buildings and structures will be designed for a minimum straight gust wind speed of 90 mph.

Design wind speeds for all buildings and structures containing licensed material or buildings and

structures containing chemicals or processes affecting licensed material are determined in

accordance with NUREG- 1520, Revision I (Appendix D and Annex to Appendix D) by reference

to DOE-STD- 1020-2002.

DOE-STD-1020-2002 Table 3-2 lists recommended peak gust wind speeds for Category C

exposure and for tornadoes at 10m (33 ft) above the ground versus "Performance Category and

Annual Probability of Exceedance" for 23 DOE sites across the United States.

By definition, DOE Performance Category 3 (PC-3) buildings and other structures are buildings

and other common structures not classified as PC-4 structures which contain sufficient quantities

of toxic or explosive substances to be dangerous to the public if released. PC-4 SSCs are

designated as "reactor like" in that the quantity of hazardous material and energy is similar to a

large Category A reactor (>200MWt). For the purposes of evaluating risks and determining

design basis criteria relative to natural phenomena events, the IIFP conservatively used the

equivalent PC-3 category for the IIFP process buildings and other structures containing licensed

material or process buildings containing processes or materials potentially affecting licensed

materials. This designation is consistent with Occupancy Category III buildings and structures as

defined in ASCE 7-05 Table 1-1(DOE G 420.1-2, 3/28/00).

DOE-STD-1020-2002, Table 3-2 lists design wind speeds and probabilities of exceeding the

speeds for straight winds and for tornadoes for several DOE sites for Performance Categories PC1 thru PC-4 structures. DOE Performance Categories are used below for illustrative purposes in

determining the design wind speed and probability of exceeding the speed for the IIFP Facility

site. The design wind speeds listed in DOE-STD-1020-2002, Table 3-2 for PC-I structures (2 x

102 probability of exceeding the speed) are consistent with the USGS wind speed maps adopted

by the International Building Code (IBC-2006) and ASCE 7-05. For all cases cited, where the

design wind speed for PC-I structures per the USGS wind speed maps is 90 mph (2 x10,2), the

design wind speed per DOE-STD-1020-2002, Table 3-2 for PC-2 structures is 96 mph (1 x 102),

for PC-3 structures is 117 mph (1 x 103) and for PC-4 structures is 135 mph (1 x 104).

Per Table D-2 in DOE-STD-1020-2002, Appendix D, the performance goal for a PC-3 facility is

to design for the facility to withstand a straight-line wind load that occurs at a frequency of 1 x

10-4. This criteria can be met in two ways: 1) design the facility to survive the force of winds with

an occurrence probability of 1xl0 4 (135 mph), or 2) design the facility to withstand a straightline wind load of 1x 103 (117 mph), but incorporate factors of safety such that the Ratio of Hazard

to Performance Probability is equal to or greater than 10 using the methodology in Appendix D of

Official Responses to Seismic/Structural RAIs Page 7
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAls

DOE-STD-1020-2002. IIFP decided to use the first approach for meeting the performance criteria

by designing PC-3 structures to withstand a 135 mph straight-line wind. At this design wind

speed and probability of exceeding the speed, no credit is taken for the Ratio of Hazard to

Performance Probability allowed in DOE-STD-1020-2002, Appendix D, Table D-2, even though

conservatism will be achieved in the design due to factors of safety inherent in the design process

and in material allowable stress specifications. From the evaluation that was performed, it was

determined that the likelihood of a tornado generating winds at 135 mph was much lower for this

area with a probability of less than 10-5. Also, according to Appendix A of NUREG/CR-4461,

Rev.2, the two-degree box which contains the IJFP Site has a tornado strike probability of 8.444 x

10-5 yr-1. Strike probabilities for the one-degree and four-degree boxes are 5.235 x 10-5 yr-1 and

3.975 x 10-5 yr"1 respectively. Therefore, facility design of PC-3 structures to a 135 mph wind

speed at the 10-4 probability level represents a conservative approach with respect to wind speed.

The IIFP facility building and structures that contain hazardous radiological and chemical (if

applicable) materials that must be controlled or mitigated to meet the performance criteria given

in 10 CFR part 70.61, "Performance Requirements," are defined as PC-3 structures per the

Natural Phenomena Hazard Evaluation methods prescribed in DOE-STD-1020-2002. As

mentioned above, those structures will meet the performance category of 1 x 104, which is

designed to withstand a 1 x 10-4 probability per year occurrence straight-line wind event. Hence,

based on the order of magnitude scale for determining event likelihood using the ISA

methodology in NUREG-1520, Rev. 1, the collapse or loss of the building integrity is considered

to be highly unlikely and meets the qualitative frequency scale of I x 10-' per year or less. Events

that occur at a highly unlikely frequency meet the performance criteria for acceptable risk without

the need to further reduce the likelihood of hazardous release or mitigate its consequences.

Therefore, designing the PC-3 facilities to withstand straight-line wind events with an occurrence

frequency of 1 x 104 per year meets ISA risk acceptance levels regardless of the hazardous

material inventories within the facilities and without consideration to mitigation of any hazardous

release.

Snow

Snow was not addressed in the IIFP Integrated Safety Analysis Summary. A section that

discusses the "snow hazard" will be added to the IIFP Integrated Safety Analysis Summary and

the new text is shown in the License Documentation Impacts below.

RESPONSE:

2. The ISA Summary Section 5.2.1 is intended to discuss PHA methodology and not the

characterization and justifications for the hazards assessment. The three paragraphs immediately

following Table 5-3 in the Section 5.2.1 of the ISA Summary Revision A are being removed

because the information in those paragraphs are not part of the description of the PHA

methodology. Instead, the natural phenomena hazard characterization and the technical basis for

justification of the perceived risk levels are provided in the above discussions and further clarified

in the ISA Revision A changes shown below.

Official Responses to Seismic/Structural RAIs Page 8
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

License Documentation Impact: Former Section 1.3.2.8 - new Section 1.3.2.6 (in response to

RAI GI-I0D) of Revision A of the IIFP Integrated Safety Analysis Summary will be deleted and

replaced with the following:

1.3.2.86 Floods

Tlhe 112P Dite does n40t f.. l within 100 year or 500 year. floodplains (11-iFP. 2009). The site is

located in a semi arid location with li:mlited bodies of water.The site is located in an area which

has a semi-arid climate with an average rainfall of 12 to slightly less than 16 inches per year as

recorded for Hobbs city (15.93 in/yr), Hobbs airport (12.35 in/yr). Pearl. NM (13.91 in/vr). and

Roswell, NM (14.66 in/vr). This information was obtained from the Western Regional Climate

Center website. The nearest river is the Pecos River to the southwest which is approximately 50

miles or greater from the site. Since there are no significant bodies of water or rivers within

several miles of the site, it is expected that any flooding would be due to extreme short-term

precipitation which could result in flash flooding. According to information obtained from

NOAA National Climate Data Center (NCDC) Storm Events, there have been 68 flood events in

Lea County, New Mexico between 1/1/1950 and 2/28/2010. an average of approximately one per

year. Of these 68 events, there were no deaths reported, and property damage was reported for

only 14 of the events, all of which occurred in the cities and towns of Lea Countv. Twenty-nine

of the 68 events were reported for Hobbs which is located at an elevation from 125 to 170 feet

lower than the site and approximately 11.4 miles to the east. The Hobbs airport is at an elevation

of about 125 feet lower and some 6.9 miles southeast of the site. and it is also in FEMA Zone D

and unmapped. The IIFP property would be expected to receive some drainage from highway 483

on the west and possibly fi'omn the north as parts of these areas are at slightly higher elevations

than the proposed facility location. However, site topography would indicate that water would

drain away from the site property toward the east and south as gradual elevation declines occur in

those directions for several miles. According to the FEMA Mapping Information Platform. the

area where the IIFP Facility is located has not been mapped, the site does not lie within areas that

have been mapped and that lie within the 100-year floodplain in and around IHobbs, New Mexico.

Guidelines in the following Department of Energy (DOE) documents were used to perform a

flood hazard assessment for the IIFP Facilitv near Hobbs, NM: DOE-STD-1020-2002, DOESTD- 1022-94 and DOE-STID- 1023-95. Based on the information included herein and the

guidance provided in these documents. it was determined that a. comprehensive flood hazard

assessment is not required. Preliminary screening, indicates that flooding is not a design basis

event other than in consideration of storm water runolf which will be included in the detailed

facility design.

All-season precipitation estimates for the IIFP Site are provided by the National Weather Service

(NWS) and the National Oceanic and Atmospheric Administration (NOAA) in the "Point

Precipitation Frequency Atlas of the United States, NOAA Atlas 14 (Bonin. et.al., Revised 2011)

and its associated database. Using a linear least-squares regression procedure to extrapolate

NOAA's precipitation estimates to an average recurrence interval of 100,000 years, it was

determined that the I-hour. 24-hour. and 48-hour all-season precipitation estimates for 1.0 x 10-

annual nrobabilitv are 7.2 inches. 14.4 inches. and 17.0 inches resnectivelv.

Based upon the above precipitation estimates for the site and information presented in Table 3-24

(former 3-21) of the I1FP "Environmental Report", the facility is designed to prevent flooding

Official Responses to Seismic/Structural RAts Page 9
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

from extreme precipitation of short duration. In the area north and northwest of the developed

plant site. berms will be added or the terrain will be contoured to divert run-on around the site so

that only the precipitation that falls on the developed portion of the site will affect plant design.

The site storm sewer system is designed fbr a 17.0 inch rainfall over a 48-hour time period.

Structures containing SSCs are constructed above grade level and above the level of plant

roadways in order to physically remove (elevate) them from potential floodwater. Structures are

provided with curbing a minimum of 12 inches in height in order to prevent internal spills (in

such an event) from leaving the structure, and this curbing also serves as flood barriers for those

structures.

License Documentation Impact: Section 1.4.5 of Revision A of the IIFP Integrated Safety

Analysis Summary will be revised as follows:

1.4.5 Design-Basis Flood Events Used for Accident Analysis

The IIFP FEP/-DUP Ssite is located outside has not been mapped but does not lie within areas that

have been mapped and that are in the 100-year flood-plain- in and around Hobbs, New Mexico according to information provided in the FEMA Mapping Information Platform. A discussion of

the IIFP flood hazard assessment is provided in Section 1.3.2.6 of the ISA. The likelihood of any

major flood at the plant site is determined to be-was-low and the consequences are Aer-e limited

(due to no fissile material existing at the site). Thus, flood type accidents are not a significant risk

for plant operations.

License Documentation Impact: Section 1.3.2.3 of Revision A of the IIFP Integrated Safety

Analysis Summary will be deleted and replaced with the following:

1.3.2.3 Extreme Winds

Wind speeds over the State of New Mexieo ar-e usuially moederate, although relatively strong,

w1in4ds often 'iccompanly occasional frontal aetivity dur-ing late winter and spr-ing months and

sometimes occur-just in advanee ofthunderstor-ms. rFrontal wyinds may. exe:eed 30 mfile/hr fori

sever-al hour-s anid r-eaeh pcak speeds of more thani 50 mile/lw.

This section describes the basis for evaluation of wvind loading on the structures at the I IFP

Facility in Lea County. New Mexico. Three sources of-wind loading are evaluated: wind loading

from a hurricane, straight wind loading and wind loading friom a tornado.

Hurricanes

The IIFP Facility site is located in the extreme southeastern portion of New Mexico and over 500

miles inland from the Gulf of Mexico. Hlurricane winds dissipate over Louisiana and Texas

enough to prevent a wind damage threat to the IIFP Facility site as evidenced by the following

information provided by NOAA. National Climatic Data Center (NCDC).

According to NOAA/ NCDC, of the 155 thunderstorm events recorded between 01/01/59 and

02/28/10, the maximum thunderstorm wind speed recorded for Lea County was 80 knots (92.1

Official Responses to Seismic/Structural RAIs Page 10
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

mph) on 07/14/89. Some of these thunderstorm events likely would have been the result of

dissipated hurricanes. (NCDC. 201Oa)

Tornadoes and Straight Winds

NOAA NCDC Storm Events includes information for 527 tornado events reported for the state of

New Mexico for the period 1950-2010 for an average of 8.78 events per year. Lea County

reported 92 tornadoes for the same period for an avera~ge of 1.53 tornadoes per year. Of these 92

tornado events for Lea County between 01/01/50 and 01/31/10, 63 - FO, 20 - Fl, 8 - F2, and oneF3 tornadoes were reported. During this same sixty-year period, no F4 or F5 tornadoes were

reported. (NCDC, 2010a)

The evaluation of tornadoes and straight winds was made based on NUREG/CR-4461. Revision 2

(February. 2007) including data in Appendices A. B and C of the NUREG, DOE-1020-2002 and

DOE-STD-l 022-2002 including Appendix D. It was detenriined from this evaluation that straight

gust wind speeds will be used as the design basis for buildings and structures at the IlFP Facility.

Design wind speeds for all buildings and structures that do not contain licensed material or for

buildings and structures containing chemicals or processes that do not affect licensed material

will be determined in accordance with the applicable model building codes (New Mexico

Commercial Building Code (NMCBC, 2006) and American Society of Civil Engineers (ASCE 7-

05) or latest editions adopted by the State of New Mexico at time of design). Specifically, these

buildings and structures will be designed for a minimum straight gust wind speed of 90 mph.

Design wind speeds for all buildings and structures containing licensed material or buildings and

structures containing chemicals or processes affecting licensed material are determined in

accordance with NUREG-1520, Revision I and by reference to DOE-STD-1020-2002 which, in

Table 3-2, lists recommended peak gust wind speeds for Category C exposure and for tornadoes

at 10m (33 ft) above the ground versus "Performance Category and Annual Probability of

Exceedance" for 23 DOE sites across the United States.

By definition, DOE Performance Categoir 3 (PC-3) buildings and other structures are buildings

and other common structures not classified as PC-4 structures which contain sufficient quantities

of toxic or explosive substances to be dangerous to the public if released. PC-4 SSCs are

designated as "reactor like" in that the quantity of hazardous material and energies similar to a

large Category A reactor (.-.>200MW ). For the purposes ofevaluating risks and determining

design basis criteria relative to natural phenromena events, the IIFP conservatively used the

equivalent PC-3 category for the IIFP process buildings and other structures containing licensed

material or process buildings containing processes or materials potentially affecting licensed

materials. This designation is consistent with Occupancy Category IlIl buildings and structures as

defined in ASCE 7-05 Table 1-1(DOE G 420.1-2, 3/28/00).

DOE-STD-1020-2002. Table 3-2 lists design wind speeds and probabilities of "exceeding" for

straight winds and for tornadoes for several DOE sites for Performance Categories PC-I thru PC4 structures. The design wind speeds listed in Table 3-2 for PC-I structures (2 x 10-2 probability

of "exceeding" in one year) are consistent with the USGS wind speed maps adopted by the

International Building Code (IBC-2006) and ASCE 7-05. For all cases cited, where the design

wind speed for PC-I structures per the USGS wind speed maps is 90 mph (2 x 10 2 ), the design

Official Responses to Seismic/Structural RAIs Page I11
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAls

wind speed per Table 3-2 for PC-2 structures is 96 mph (l xI 102), for PC-3 structures is I 17 mph

(1 xI 103 ) and for PC-4 structures is 135 mph (I x 10-4 ).

Per Table D-2 in DOE-STD- 1020-2002, Appendix D, the performance goal for a PC-3 facility is

to design for the facility to withstand a straight-line wind load that occurs at a Ixl 0-4. This I x 10.4

perfornmance goal is met at the IIFP Facility by designing applicable structures (as defined above)

using a 135 mph straight wind gust at the I x I0V probability level where no credit is taken for the

Ratio of Hazard to Performance Probability allowed per Table D-2. Therefore, the IIFP design

basis wind speed is one order of magnitude more conservative than the design basis required by

DOE for PC-3 structures where a hazard probability of I x 10'1 with a Ratio of Hazard to

Performance Probability of 10 may be used to meet the performance goal of I x 10-'.

From the evaluation that was performed, it was determined that the likelihood of a tornado

generating winds at 135 mph is at a probability level of less than 1xl0 5 . Also, according to

Appendix A. ofNUREG/CR-4461, Revision 2, strike probabilities for the one-degree, the twodegree and the fiur-degree boxes containing the IIFP site are 5.235 x I 0 5 yf1, 8.444 x 10- vrj

and 3.975 x 105 yr' respectively. Therefore. selection of a design basis wind speed for IIFP PC-3

structures of 135 mph at the lx 10-4 probability level represents a conservative approach. The IIFP

facility building and structures that contain hazardous radiological and chemical (if applicable)

materials that must be controlled or mitigated to meet the performance criteria given in 10 CFR

pairt 70.61. "Performance Requirements." are defined as PC-3 structures per the Natural

Phenomena Hazard Evaluation methods prescribed in DOE-STD-1020-2002. As mentioned

above, those structures will meet the performance categor'y of lxlOa, and be designed to

withstand a I X 10-4 probability per year occurrence straight-line wind event. Hence, based on the

order of magnitude scale for determining event likelihood using the ISA methodology in

NUREG-1520. Rev. 1. the collapse or loss of the building integrity is considered to be highly

unlikelv and meets the qualitative frequency scale of Ix 10-' per year or less. Events that occur at

a highly unlikely frequency meet the perionnance criteria for acceptable risk without the need to

further reduce the likelihood of hazardous release or mitigate its consequences. Therefore,

designing the IIFP applicable facilities to withstand straight-line wind events with an occurrence

frequency of lX1 0A per year meets ISA risk acceptance levels regardless of the hazardous

material inventories within the facilities and without consideration to mitigation of any hazardous

release.

License Documentation Impact: Additional references will be included in Section 1.8 of the

IIFP License Application (LA) for (ASCE, 2006) and (DOE, 2002). The following subheading

and text for Snow will be inserted in former LA Section 1.6.3.3 - new LA Section 1.7.3.3

(renumbered in response to RAI RP-13) after subheading Floods and text of the IIFP License

Application.

Snow

The mean annual snowfall is 5.1 inches as recorded at the Hobbs weather station with a high

annual total of 27.1 inches. The historical maximum snow depth for I lobbs, NM is 12.2 inches

and it occurred during the month of November. The 2-day 100-year snowfall is 12.1 inches which

also occurred in November.

Official Responses to Seismic/Structural RAIs Page 12
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAls

The design basis extreme environmental roof load for the process buildings (involving or

affecting licensed material) at the IIFP Site is 81.2 lb/ft2 or 396.8 kgm/r2.This design load is based

on the sum of the 100-year return period snowpack and the load corresponding to the 48-hour allseason precipitation and an annual probability of 1.0 x 10- for the facility site area. (Refer to the

I1FP Integrated Safety Analysis Summary Section 1.3.2.7 for an additional description of

determining the design basis snow load).

1.8 References

ASCE, 2006. American Society of Civil Engineers. ASCE 7-05. "Minimum Design Loads for

Buildings and Other Structures: SEl/ASCE 7-05 (ASCE Standard)." 2006.

DOE. 2002. U.S. Department of Energy, DOE STD-1020-2002, "Natural Phenomena Hazards

Design and Evaluation Criteria for Department of Energy Facilities." Washington. D.C., January

2002.

License Documentation Impact: Add additional references to Section 1.6 of the IIFP ISA

Summary for (ASCE, 2006) and (DOE, 2002). A new Section 1.3.2.7 "Snow" (below new

Section 1.3.2.6 "Floods", numbering change in response to RAI 10 GI-10D) will be added to the

IIFP ISA Summary, Revision A to read as follows:

1.3.2.7 Snow

The mean annual snowfall is 5.1 inches as recorded at the Hobbs weather station with a high

annual total of 27.1 inches. The historical maximum snow depth for Hobbs, NM is 12.2 inches,

and it occurred during the month of November. The 2-day 100-year snowfall is 12.1 inches which

also occurred in November.

The design basis extreme environmental "ground" snow load for the IIFP Site is 96.7 lb/ft2 or

472.5 kg/im2. This design basis ground snow load is calculated as the sum of the 100-year return

period snowpack and the load corresponding to the 48-hour all-season precipitation and an annual

probability of 1.0 x 10-5 for the facility site. The method of determination follows acceptable

methodology discussed in NRC NUREG-1951(NRC. 2010). The roofs of all process buildings

(involving or affecting licensed materials) at the iiFP Facility site will be sloped at a minimum of

5/12 or 22.6 degrees. Using the method described in American Society of Civil Engineers

Standard 7-05 "Minimum Design L[oads for Buildings and Other Structures" (ASCE 7-05) to

convert the ground snow load into a "roof' snow load. the design basis extreme environmental

"root' snow load for the buildings on the IIFP Facility is 81.2 lb/ft2 (396.8 kg/.1 2). This

calculation assumes no runoff of snow or rain notwithstanding that roofs of iIFP process

buildings (involving or affecting licensed materials) are sloped. This load represents the extreme

roof snow load for the purpose of building design.

IiFP used the data collected by the Western Regional Climate Center (WRCC) for the Hobbs.

New Mexico area to determine that the 100-year snowpack was 12.2 inches resulting in a normal

(severe) design basis ground snow load of 8.4 lb/ft2 (41.0 kg/r 2) (NRC. 2010). Since essentially

100 years of snowpack data was available for the area, no calculation or extrapolation of the data

was necessary.

Official Responses to Seismic/Structural RAIs Page I')
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAls

All-season precipitation estimates for the I IFP Site are provided by the National Weather Service

(NWS) and the National Oceanic and Atmospheric Administration (NOAA) in the "Point

Precipitation Frequency Atlas of the United States. NOAA Atlas 14 (Bonin, et. al., Revised 2011

and supersedes the "Two-to-Ten Day Precipitation for Return Periods of 2 to 100 Years in the

Contiguous United States", 1964) and its associated data base. Using a least-square regression

procedure to extrapolate NOAA's precipitation estimates it was determined that the 48-hour allseason precipitation frequency estimate for 1.0 x 10-5 annual probability is 17.0 inches. This 17.0

inches of precipitation (as water) corresponds to a ground snow load of 88.3 lb/ft2 or 431.5 kg/n 2.

The sum of the ground snow load from precipitation and from snowpack is 96.7 lb/ft2 or 472.5

k~,/m-from which the roof snow design load (81.2 lb/t 2 or 396.8 kg/m2) is determined as

described above.

1.6 References

ASCE, 2006. American Society of Civil Engineers. ASCE 7-05. "Minimum Design Loads for

Buildings and Other Structures: SEl/ASCE 7-05 (ASCE Standard)." 2006

DOE, 2002. U.S. Deparment of Energy, DOE STD- 1020-2002, "Natural Phenomena Hazards

Design and Evaluation Criteria for Department of Energy Facilities." Washington. D.C., January

2002.

NRC, 2010. Nuclear Regulatory Commission, NUREG-1 951 "Safety Evaluation Report for the

Eagle Rock Enrichment Facility in Bonneville County, Idaho, AREVA Enrichment Services

LLC", Pages 1-23 to 1-25.

License Documentation Impact: Paragraphs two, three and four in Section 5.2.1 (immediately

following Table 5-3) are removed.

5.2.1 Hazard Identification Method

The initial activity of the ISA was a review of the preliminary hazards, specific engineering

design files, PFDs, and P&IDs. The information obtained from this review enabled the analysts to

identify hazards associated with specific process areas. The hazards were subsequently

categorized and documented in a checklist (Table 5-3), including those hazards identified as

standard industrial hazards (SIH) covered by OSHA requirements and not considered separate

initiating events. The hazards identification information was then used to develop a more detailed

PHA.

Ther-e arc a numnber- of vehiele in metion hazar'ds that are not considered in the P11IA. An aircrfaft

crash typically consists of an initial imipact of the aircraft with the grouknd and a slide into the

ffaciliy (direct impact is possible but mnuch less likely). This event is extremnely unlikely even for

iveryý large structukr-es. For- FEP/DUP pr-ocess buildings, anid all other- facilities on the site, a larFge

limipacts -from general aviation plaiies or- he lieeptei- ae credible buat eEtremely, unlikely. Althouigh

the damage Potential to F211EP/DUP faile-ities has-46 1nOt 1 betenuatified, itisraoaltosse

that the building structuires that are designed anid built to seismic cr-iteria are suffic6ient to pr-otect

Official Responses to Seismic/Structural RAIs Page 14
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

the hazardous materials within the buildings. Therefore, radieolgical and/or hazao rd'ous material

releases are minimnal. Since small airc'aft andO'r helicopter crashes are c-nsidered low risk and

are 110t G ..~idf~ AJ~ I:t in. the-A 14ýA.

I [igh wind, snow loading. floding, and other N P••, events a,•. not considered separately. Due to

the seismic design capacity of the process- buildiings, the FE..DUI. P.lant is expected to withstand

these hazards with minimal damiage. Althoug toppling of equipmienit or lightning induced fires

May be possible, radiolegical and,/o,. h.azar.d4,ous m.aterial +il. relea.e.. Therfe.e

NPH ev'ents are considered low risk and are ot considered A.•ther.

Official Responses to Seismic/Structural RAIs Page 15
Enclosure 1 - J.IM-2011-32 

Official Responses to Seismic and Structural RAls 

SS-3. Redacted 

Redacted pages 16-23
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

SS-4. Back.zround.:

The regulations in 10 CFR 70. 64(a)(4) require the applicant to include adequate protection

against environmental conditions and dynamic effects in its design of the facility, and 10 CFR

70. 62(c) (iv) requires the applicant to conduct and maintain an ISA that identifies potential

accident sequences caused by credible external events. In addition, 10 CFR 70.61 (b) and

70.61(c) require the applicant to demonstrate that an accident event can be excluded from further

consideration based on either its likelihood or its consequences.

Issue:

In LA Section 3.2.5.2, Hazard Identification and ISA Section 5.2.1, Hazard Identification Method

and Table 3-6, FEP/DUP Facility Hazards Identification, the applicant excluded aircraft crash

as a potential external hazard from further consideration for facility design and in the ISA for the

proposed FEP/DUP. IIFPjustified this exclusion by stating that "An aircraft crash typically

consists of an initial impact of the aircraft with the ground and a slide into the facility

(direct impact is possible but much less likely). This event is extremely unlikely even for very

large structures. For FEP/DUP process buildings and all other facilities on the site, a large

aircraft crash is judged to be beyond extremely unlikely and is not considered further (Underline

added). "However, IIFP did not provide quantitative assessment of the probability of aircraft

crash hazard to the FEP/DUP to justify the exclusion.

Request:

Provide an aircraft crash hazard analysis to demonstrate that aircraft crash hazard is highly

unlikely for the IIFP FEP/DUP site.

RESPONSE: A new section will be added to the ISA Summary to address nearby air

transportation (Section 1.2.4.3) assessing the risks from aircraft hazards. This new section also

addresses military operations.

License Documentation Impact: In addition, a new Section 1.2.4.3, "Nearby Air

Transportation," will be added to the ISA Summary. This section also addresses military

operations hazards [See RAI SS-3 (i).] Section 1.2.4.3 will read as follows:

1.2.4.3 Nearby Air Transportation

An aircraft hazard risk determination (IIFP, 2011) has been conducted. This analysis follows the

methodology as described in Standard Review Plan (SRP) NUREG 0800 Section 3.5.1.6 for

aircraft hazards evaluation (NRC. 2010). SRP 3.5.1.6 methodology is accepted by the U.S.

Nuclear Regulatory Commission (USNRC) to assess the probability of hazards due to airport

operations and aircraft transits near nuclear facilities.

SRP 3.5.6.1 proximity acceptance criterion 1 A states that the probability of aircraft accidents with

potential radiological consequences is considered to be less than about I x 10' per year if the siteto-airport distance. D. is between 5 and 10 statute miles and the proiected annual number of

operations is less than 500 D2

. or D is greater than 10 statute miles and the projected annual

number of operations is less than 1000 Q2. Seventeen airports within 100 miles of the IIFP

Facility were evaluated for the number of annual operations. The distance firom the site to all the

surrounding airports is greater than 5 statute miles and the acceptable number of operations

Official Responses to Seismic/Structural RAIs Page 24
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

permitted by this acceptance criterion is greater than the number of operations conducted at each

airport multiplied by the distance factor. Based on the published number of operations and

distances to the proposed llFP site. this criterion has been met.

SRP 3.5.6.1 proximity acceptance criterion 1 B states that the probability of aircraft accidents with

potential radiological consequences is considered to be less than about I x I.O per year if the site

is at least 5 statute miles from the edge of military training routes, including low-level training

routes, except for routes used by more than 1000 flights per year or where activities (such as

practice bombing) may create an unusual stress situation. There are four military routes within a

30 nautical mile radius of the proposed site. The closest approach is approximately 15 nautical

(17 statute) miles southwest of the facility. The number of militarv operations at the Lea County

Regional Airport is 561 annually. Additionally, there is a Special Use Airspace for two Military

Operations Areas (MOAs) north of the IIFP site. The closest edge of the MOA is approximately 5

nautical (5.8 statute) miles from the facility. Thus, military operations, military training routes, or

proximity to MOAs are not expected to pose any hazard to the proposed facility since these

proximity criteria are met.

SRP 3.5.6.1 proximity acceptance criterion 1 C states that the probability of aircraft accidents with

potential radiological conseCluences is considered to be less than about 1 x 10-7 per year if the site

is at least 2 statute miles beyond the nearest edge of a Federal airway, holding pattern, or

annroach n~attern. l-oldiniŽ and annroach n~atterns were evaluated for three airnorts within 20 miles

of the IIFP site. These airports include:

* Lea County Regional Airport- 8 statute miles east southeast of the proposed facility site;

* Hobbs Industrial Airpark 8.5 statute miles east northeast of the proposed facility site;

and

" Lea County Zip Franklin Memorial Airport - 17 statute miles north northwest of the

proposed facility.

For the Lea County Regional Airport. seven Instrument Flight Rule (IFR) procedures were

evaluated for holding and approach patterns. There are no runways at the regional airport where

the IFR landing/takeoff procedures would take aircraft within 2 statute miles of the IIF.P site.

During descent into the airport. the closest approach would be 6.5 nautical (7.5 statute) miles east

southeast of the IIFP site. The Visual Flight Rule (VFR) landings/takeoffs firom two runways

would take aircraft no closer than 6.5 nautical (7.5 statute) miles from the site. The closest hold

pattern is 6.5 nautical (7.5 statute) miles from the IlFP Facility. Thus for all seven IFR procedures

for this regional airport, the IIFP site is at least 2 statute miles beyond the nearest edge of an

approach or hold pattern. Holding and approach patterns for the Lea County Regional Airport

meet SRP proximity criterion I C.

The Hobbs Industrial Airpark has no instrument procedures or specific holding patterns.

Assuming at least a 10 nautical mile visual landing approach of one runway, an aircraft could

come within 3.5 nautical (4 statute) miles from the llFP site. Using the other runway, aircraft

could come within 5.5 nautical miles during the approach landing. This airpark has no air carrier,

general aviation, or military operations. only operations from 32 airpark-based aircraft. The

threshold limit provided in NUREG-0800 for air carrier, general aviation, and military operations

is 37.400. Since no holding patterns exist for this airpark and the airpark poses no concern per

Official Responses to Seismic/Structural RAIs Page 25
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

SRP guidelines, the issue of holding patterns is not relevant for this airpark. No landing approach

patterns are within 2 statute miles of the site. Holding and approach patterns for the Hobbs

Industrial Airpark meet SRP proximity criterion IC.

For the Lea County Zip Franklin Memorial Airport (E06), two IFR procedures were evaluated for

holding and approach patterns. For the closest runway. the landing distance is 11.3 nautical miles

with a 6 nautical mile holding pattern. At the southern-most point of the holding pattern, this

would place an aircraft no closer than 16 nautical miles from the IIFP site. For VFR flights using

the runway that would take aircraft the closest to the site, this would still put aircraft no closer

than 16 nautical miles f'rom the site assuming a 10 mile final approach. Thus, no holding or

approach patterns are within 2 statute miles of the site. Holding and approach patterns for the E06

Airport meet SRP proximity criterion IC.

There are four en-route high-level airways within 35 statute miles of the IIFP Facility. The closest

airway is Q20 which passes 10.4 statute miles southwest of the IIFP Site. This Q20 airway meets

the SR.P proximity criterion 1 C. There are three en-route low-level airways passing through the

navigational aid HOB VORTAC. The closest airway (V68) passes 3.2 statute miles of the

proposed site. Another airway (V29 1) is 4.7 statute miles from the site. The closest point to the

VI 02 airway is 6.5 nautical miles from IIFP site. All three airways meet the SRP proximity

criterion IC. Even though no additional analysis is required to meet criterion I C, calculations

were performed as a further check that the annual probability of an aircraft crash into the target

area from CFR Part 121 and Part 135 operations using the airway closest to the site (V68) is less

than 10"7 per year for the SRP 3.5.1.6 acceptance criterion 1C.

Using the method provided in Section 3.5.1.6 of NUREG 0800, the probability of an aircraft on

the V68 airway crashing onto the proposed facility was estimated to be 2.7 x 10-" for CFR 121

operations. This probability makes the aircraft crash an incredible event and thus requires no

further consideration in either design or integrated safety analysis.

Department of Energy (DOE) Standard 3014-2006 (DOE. 2006) offers an alternative analytic

method to evaluate external risk from aircraft operations. To establish additional confirmation of

the results obtained by the NRC method, the DOE method was also applied. Since the DOE

method applies a different analytic approach, the results obtained via the DOE method are only

relevant in comparison to the DOE threshold risk metric, which is not the same as the NRC risk

metric. Based on the results from the DOE evaluation, the calculated probability of 3.3 x 10"7

crashes per year at the site is less than the DOE evaluation guideline of 1.0 x I0 '.Therelore, the

DOE method also demonstrates that the crash of an aircraft into the target areas is an incredible

event and thus requires no further consideration in the integrated safety analysis.

All three proximity criteria of Section 3.5.1.6 have been met. Additional calculations estimate

that the probability per year of an aircraft crashing into the plant from the closest Federal airway

(V68) is less than the NRC acceptance criteria. Calculations also estimate the annual probability

of an aircraft crashing into the plant forom the same airway is less than the DOE acceptance

criteria. This probability is well below the NRC threshold metric of I x 10(7 which means an

aircraft crash into the target area is an incredible event and thus requires no further consideration

in the integzrated safety analysis.

Official Responses to Seismic/Structural RAls Page 26
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

The aircraft hazards determination following the methodoloy,v in SRP Section 3.5.1.6 addressed

military operations. There are military operations out of the nearby regional/international airports.

including the Lea County Regional Airport and the Winkler County (WINK), Texas airport. The

number of total operations fr'om both airports, including the military operations, is far below the

SRP Section 3.5.1.6 Acceptance Limit IA. Additionally, there is a Special Use Airspace for two

Military Operations Areas (MOAs) north of the I1FP Facility. The closest edge of the MOA is

approximately 5 nautical (5.8 statute) miles from the facility. This is not expected to pose any

hazard to the proposed facility, since the MOAs are more than 5 statute miles from the site (SRP

Section 3.5.1.6 Acceptance Limit I B). Four (4) IFR Military Trainin_ Routes are within a 30

nautical mile radius of the proposed site. The closest approach is about 17 nautical miles west

from the IIFP Site. This is not expected to pose any hazard to the proposed facility, since the

routes are more than 5 statute miles from the site, per SR13 Acceptance Criterion lIB. Per SRP

3.6.1.5 Acceptance Criterion 11B. the probability of aircraft accidents is less than an order of

magnitude of I x 10` per year if the plant is at least 5 statute miles from the nearest edge of

military training routes, except for those associated with usage greater than 1000 flights per year.

The Hobbs Regional Airport has the greatest number of military operations at 561 annually.

Hence, no further analysis is required with regard to the impact of military training routes or

military operations.

License Documentation Impact: Insert a new reference for an "Aircraft Hazard Risk

Determination in Section 1.6.

1.6 References

IIFP, 2011 . International Isotopes Fluorine Products, Inc., "Aircraft 1lazard Risk Determination."

2011.

License Documentation Impact: The IIFP ISA Table 5-3 will be revised as follows for Item

17.1 (Airplanes) to identify "as applicable" to PHA because a hazard analysis has now been

performed.

Item Hazard Energy Applicable to PHA? Rationale*

Source or Material Yes No

17.1 Airplane X X Considered beyeod extremely

t4ike4wexternal initiating event.

Official Responses to Seismic/Structural RAIs Page 27
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

SS-5. Background:

The regulations in 10 CFR 70.64(a) (4) require the applicant to include adequate protection

against environmental conditions and dynamic effects in its design of the facility, and 10 CFR

70. 62(c)(iv) requires the applicant to conduct and maintain an ISA that identifies potential

accident sequences caused by credible external events.

Issue:

LA Section 1.6.4, Geology and Seismology; and ISA Summary Section 1.5, Geology and

Seismology, did not include the information needed to assess the potential effects of site soil

seismic amplification, soil settlement, allowable bearing capacity, and liquefaction potential.

Request:.

1. Provide the geotechnical and geophysical investigation plan that will be used to collect the

geotechnical properties of the site soils that will be needed for assessing seismic site

response, determining soil settlement and allowable bearing capacity for design, and

assessing liquefaction potentialfor the site.

2. Provide assessment of site soil seismic amplification, soil settlement, allowable bearing

capacity, and liquefaction potential.

RESPONSE:

1. At this time IIFP is providing information regarding the planned procedure, guidance and

standard that it will used to conduct geotechnical and geophysical investigations to

characterize the site soil and to make an assessment.

2. An assessment of site soil seismic amplification, soil settlement, allowable bearing

capacity and liquefaction potential will be available upon completion of the geotechnical

and geophysical investigation and analysis.

License Documentation Impact: A new Section 1.5.4 will be added to the IIFP ISA Summary

Section 1.5, "Geology and Seismology" to describe the plan for geotechnical and geophysical

investigation and analysis to read as follows:

1.5.4 Geotechnical and Geophysical Investigation and Analysis

A preliminary geotechnical and geophysical investigation and analysis plan has been developed

to determine the site class, seismic site response, liquefaction potential. soil settlement potential.

and allowable bearing capacity of the soil for the IIFP Facility site. Details of the analysis plan

and the codes and standards to be followed are detailed below.

The proposed scope of the flFP Facility geotechnical investigation, including the planned tests

and their use for determining soil parameters, is as follows:

* Pertform pathfinder surveys for determination of essential settlement parameters with

dilatometer soundins to 150 feet of depth or blade thrust refusal load of 25 tons;

Official Responses to Seismic/Structural RAIs Page 28
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

* Perform pathfinder surveys for determination of approximate small strain seismic data

and large strain shear strength data with Seismic Cone Penetration Test soundings to 150

feet of depth or cone thrust refusal load of 25 tons;

* Perfonn critical determination of small strain seismic shear modulus and Poisson Ratio

data with Cross-hole Seismic Tests to depths of 150 feet or so depending on tile

requirements as defined by the Engineering use of the individual buildings and geology

determined by the dilatometer and seismic cone penetration test soundings;

0 Perform drilling and borings in select locations, based on data from dilatometer and

Seismic Cone Penetration Test soundings, including Standard Penetration Test borings, to

150 fieet of depth:

* Perform soil sampling in Standard Penetration boreholes to obtain disturbed and

undisturbed soil samples: and

* Perform auger borings to 15 feet of depth and obtain bulk disturbed soil samples.

The proposed drilling and boring location guidelines are as follows:

* Structures: 1 boring for every 2500 square feet,

" Pier foundations: I boring for every pier, and

" Roads: I boring for every 500 feet.

Geotechnical Standards under which activities and tests will be performed in accordance with

American Society for Testing and Materials (ASTM) standards. See Section 2.3.3 "Geotechnical

and Geophysical Codes and Standards" for applicable ASTM Standards.

License Documentation Impact: Revised Section 1.7.4.1 (formerly 1.6.4.1) of the IIFP License

Application will be amended to refer to the geotechnical and geophysical investigation plan

provided in the IIFP ISA Summary new Section 1.5.4. Wording will be added as a last paragraph

to Section 1.7.4.1 to read as follows:

IIFP will conduct geotechnical and geophysical investigations and analyses to determine the site

class, seismic site response, liquefaction potential. soil settlement potential, and allowable bearing

capacity of the soil for the IIFP Facility site. Details of the analysis plan and the codes and

standards to be followed are provided in the IIFP ISA Summary Section 1.5.4 and Section 2.3.3.

respectively.

Official Responses to Seismic/Structural RAls Page 29
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAls

SS-6. Back2round:

The regulations in 10 CFR 70.64(a) (4) require the applicant to include environmental conditions

and dynamic effects associated with normal operations, maintenance, testing, and postulated

accidents that could lead to loss of safety functions. 10 CFR 70.62(c) (iv) requires the applicant to

conduct and maintain an ISA that identifies potential accident sequences caused by credible

external events. In addition, 10 CFR 70.61(b) and 70.61(c) require the applicant to demonstrate

that an accident event can be excluded from further consideration based on either its likelihood

or its consequences.

Issue:

In ISA Summary Section 5.2.1, Hazard Identification Method, the applicant stated that "Impacts

from general aviation planes or helicopters are credible but extremely unlikely. Although the

damage potential to FEP/DUP facilities has not been quantified, it is reasonable to assume that

the building structures that are desizned and built to seismic criteria are sufficient to protect the

hazardous materials within the buildings. Therefore, radiological and/or hazardous material

releases are minimal (Underline added). " The technical basis supporting this assumption is

needed to determine whether buildings are designed sufficiently to protect hazardous materials

from aircraft crash hazards.

Request:

Provide a technical basis for the assumption that building structures that are designed and built

to seismic criteria are sufficient to protect the hazardous materials within the buildings from

impacts of general aviation planes or helicopters.

RESPONSE: The Aircraft Hazard Risk Determination referenced in the response to RAI SS-4

was performed. All three proximity criteria of Standard Review Plan (SRP) NUREG 0800

Section 3.5.1.6 were met. Even though not required, calculations were performed as a further

check to calculate the annual probability of an aircraft crash into the target area of the IIFP

Facility from CFR Part 121 and Part 135 operations using the airway closest to the site. These

calculations estimate that the probability per year of an aircraft crashing into the plant from the

closest Federal airway is well below the NRC threshold metric of 1 x 10-7 which means an aircraft

crash into the target area is an incredible event and thus requires no further consideration in the

integrated safety analysis.

License Documentation Impact: The 2nd paragraph of ISA Summary Section 5.2.1 will be

deleted in response to RAI SS-2. The aircraft crash hazard determination has been conducted and

an explanation is provided in the IIFP ISA Summary Section 1.2.4.3 "Nearby Air Transportation"

in response to RAI SS-4.

Official Responses to Seismic/Structural RAIs Page 30
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

SS-7. Background:

The regulations in 10 CFR 70. 64(a)(2) and 70. 64(a)(4) require the applicant to include adequate

protection against natural phenomena, environmental conditions, and dynamic effects in its

design of the facility. In addition, 10 CFR 70.61 (b) and 70.61(c) require the applicant to

demonstrate that an accident event can be excluded from further consideration based on either its

likelihood or its consequences.

Issue:

In LA Section 1.1.2.1, Process Buildings and Process Areas and ISA Summary Sections 2.4,

Process Buildings and 5.2.1, Hazard Identification Method, the applicant did not provide any

load combination information for the structural design of Process Buildings. The applicant also

indicated in its ISA Summary Section 5.2.1, that due to the seismic design capacity of the process

buildings, the FEP/DUP Plant is expected to withstand hazards such as high wind, snow loading,

flooding, and other natural phenomena-related hazards with minimal damage. However, a

technical basis is not provided to support this assumption. Furthermore, the applicant did not

include civil structural design information in either LA or ISA Summary to permit assessment of

reasonableness of the IIFP proposed design.

Request:

1. Provide a facility site plan, layout of the buildings, and multiple horizontal and vertical

cross-sectional drawings of the conceptual structural design of all the Process Buildings.

2. Provide information about the structural and foundation design of Process Buildings with

emphasis on seismic design, including design bases, design criteria, design methodology, and

design codes used for reinforced concrete and steel structures.

3. Provide a description of the methods used to conduct structural analyses of Process

Buildings with an emphasis on seismic analysis, including major assumptions made such as

fixed supported structures or soil-structure interaction structures, modeling methodology

used, type of seismic analyses conducted, and computer codes used.

4 Provide a description of the methods used to conduct seismic analysis of equipment, piping,

silos, and other mechanical systems.

5. Provide load combinations to be used for structural design of Process Buildings and

demonstrate, using these load combinations, that the load combinations with seismic hazard

bound all other hazards, including the hazards in RAI 2 at the site for the design of these

Process Buildings.

6. Either determine the effects of building damage, including collapse resulting from a ground

motion corresponding to an annual probability ofl 0-5 on radiological and chemical

consequences on workers and the public; or demonstrate that the proposed seismic design of

buildings justify excluding seismically-induced building damage from the ISA.

Official Responses to Seismic/Structural RAIs Page 31
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

RESPONSE: (Requests #1 through 5):

1. An updated conceptual facility site plan drawing is being included with this Seismic

and Structural RAI response package. Also conceptual floor plans of all process

buildings showing equipment layout, and multiple horizontal and vertical crosssectional drawings of the conceptual structural design of all the Process Buildings are

being furnished as part of the engineering drawing updates being included with the

Seismic and Structural RAI response package.

2. At this time, IIFP is providing information on the codes and standards to be used for

the design of concrete and steel structures of Process Buildings (involving or affecting

licensed materials). Information concerning the structural and foundation design of

process buildings with emphasis on seismic design, including design bases, design

criteria, and design methodology-used for reinforced concrete foundations and steel

structures will be available after geotechnical and geophysical investigation and

analysis are completed and after preliminary structural analysis is completed by the

Design/Build Contractor. The design codes and standards that IIFP is committed to

following in the design of buildings and structures for the facility are provided below in

License Documentation Impact (Request #2).

3. Information concerning the description of the methods used to conduct structural

analyses of process buildings with an emphasis on seismic analysis, including major

assumptions made such as fixed supported structures or soil-structure interaction

structures, modeling methodology used, type of seismic analyses conducted, and

computer software used will be available after geotechnical and geophysical

investigation and analysis are completed and after preliminary structural analysis is

completed by the Design/Build Contractor.

4. Information concerning the description of the methods used to conduct structural

analyses of process buildings with an emphasis on seismic analysis, including major

assumptions made such as fixed supported structures or soil-structure interaction

structures, modeling methodology used, type of seismic analyses conducted, and

computer software used will be available after geotechnical and geophysical

investigation and analysis are completed and after preliminary structural analysis is

completed by the Design/Build Contractor.

5. The load combinations to be used for the design of concrete and steel structures of both

non-process buildings and process buildings at the IIFP facility are listed below. The

load combinations will be used by the Design/Build Contractor, after geotechnical and

geophysical investigation and analysis are completed, and after preliminary structural

analysis is completed, to determine the bounding hazard conditions (including the loads

from hazards discussed in SS RAI-2) for the buildings and structures at the IIFP

Facility.

NON-PROCESS BUILDINGS AND STRUCTURES - For those buildings and structures that

do not contain licensed materials or that do not affect licensed materials (i.e. those buildings and

structures that do not contain IROFS), the following load combinations will be used for structural

design in accordance with ASCE 7-05:

Official Responses to Seismic/Structural RAIs Page 32
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

Concrete Load Combinations:

1. 1.4(D + F)

2. 1.2(D+ F+ T)+ 1.6(L + H) + 0.5(Lr or S or R)

3. 1.2D + 1.6(Lr or S or R) + (L or 0.8W)

4. 1.2D + 1.6W+ L + 0.5(Lr or SorR)

5. 1.2D+ 1.OE+L+0.2S

6.0.9D + 1.6W+ 1.6H

7.0.9D + 1.OE + 1.6H

Notes.-

1. The load factor on L in combinations (3), (4), and (5) is permitted to equal 0.5for all

occupancies in which live load is less than or equal to 100 psf with the exception of

garages or areas occupied as places ofpublic assembly.

2. The load factor on H shall be zero in combinations (6) and (7) if H counteracts W or E.

Where lateral earth pressure provides resistance to other forces, it shall not be included

in H but shall be included in the design resistance.

3. In combinations (2), (4), and (5), the companion load S shall be either the flat roof snow

load (pf) or the sloped roof snow load (Ps).

Steel Load Combinations:

For steel, either the Load and Resistance Factor Design (LRFD) load combinations listed above

or the Allowable Strength Design (ASD) load combinations listed below can be used:

1.D+F

2. D+H+F+L+ T

3. D + H+ F+ (Lr orSorR)

4. D + H+ F+ 0.75(L + T) + 0.75(Lr or S or R)

5. D + H+ F+ (Wor 0.7E)

6. D + H + F + 0.75(W or 0.7E) + 0.75L+ 0.75(Lr or S or R)

7.0.6D + W+H

Official Responses to Seismic/Structural RAIs Page 33
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAls

8. 0.6D + O.7E + H

Note:

In combinations (4) and (6), the companion load S shall be either the flat roof snow load (pf) or

the sloped roof snow load (pj).

PROCESS BUILDINGS AND STRUCTURES - For process buildings and structures that

contain licensed materials or that affect licensed materials, (i.e. those buildings and structures that

contain IROFS) the following load combinations for extreme load cases will be added to the load

combinations above:

Concrete Load Combinations per A CI 349-06

D+ F+O.8L + C + H+ T+ Ro+ Es

D + F+ 0.8L +H+ T+ Ro + Wt

Notes:

1. The second load combination shall be satisfied first without the tornado missile load.

When considering tornado missile loads, local section strength and stresses may be

exceeded provided there will be no loss of intended function of any safety-related

systems.

2. The crane load C may be omitted if the simultaneous occurrence of DBE with crane

usage is not credible.

3. Es can be reduced by 10% if the exceeding probability of Es is equal to or lower than

1. OE-4 (mean).

Steel Load Combinations per AISC N690-06

If Load and Resistance Factor Design (LRFD) is used:

D O.8L +C + T+ Ro + Es

D + 0.8L + T+ Ro + Wt

Note.

The load C can be waived if the probability of Es and C occurring at the same time is less than

10E-6.

If Allowable Strength Design (ASD) is used:

D + L + C + Ro + T + Es

Official Responses to Seismic/Structural RAIs Page 3 4
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

D+ L + Ro+ T+ Wt

Notes.

1. The allowable strength can be increase by 1.5for members or fasteners in axial tension

or in shear and by 1. 6for other cases.

2. The load C can be waived if the probability ofEs and C occurring at the same time is less

than I OE-6.

Notation:

D = dead load

E = earthquake load

F = load due to fluids with well-defined pressures and maximum heights

H = load due to lateral earth pressure, ground water pressure, or pressure of bulk materials

L = live load

Lr = roof live load

R = rain load

S = snow load

T = self-straining force, including thermal effects and loads during normal operating

conditions

W= wind load

Es = Design Basis Earthquake load

Wt = tornado load

Ro = pipe reactions during normal operating conditions

C = rated capacity of crane (shall include the maximum wheel loads of the crane and the

vertical, lateral, and longitudinal forces induced by the moving crane).

For those buildings that do not contain licensed materials or that do not affect licensed materials

(i.e. those buildings and structures that do not contain IROFS), the following codes and standards

will be used for structural and foundation design where there is emphasis on seismic design:

NMCBC 2009 New Mexico Commercial Building Code,

Official Responses to Seismic/Structural RAIs Page 35
Enclosure I - JJM-2011-32

Official Responses to Seismic and Structural RAIs

IBC 2009

ASCE 7-05

ACI 318-08

ACI 530-08

ASCE 5-08

TMS 402-08

ANSI/ AISC 360-05

AISC

ANSI/ AISC 341-05

AWS D1.1-2004

International Building Code,

Minimum Design Loads for Buildings and Other Structures,

Building Code Requirements for Structural Concrete,

Building Code Requirements for Masonry Structures,

Building Code Requirements for Masonry Structures,

Building Code Requirements for Masonry Structures,

Specification for Structural Steel Buildings,

Steel Construction Manual 13 th Edition,

Seismic Provisions for Structural Steel Buildings,

Structural Welding Code - Steel, American Welding Society.

For process buildings and structures that contain licensed materials or that affect licensed

materials, (i.e. those buildings and structures that contain IROFS) the following codes and

standards will be used for structural and foundation design where there is emphasis on seismic

design:

NMCBC 2009

IBC 2009

ASCE 7-05

ANSI/AISC N690-06

ANSI/AISC 360-05

AISC

AWS D1.1-2004

ACI-349-06

ASCE 4-98

New Mexico Commercial Building Code,

International Building Code,

Minimum Design Loads for Buildings and Other Structures,

Specification for Safety-Related Steel Structures for Nuclear

Facilities,

Specification for Structural Steel Buildings,

Steel Construction Manual 13' Edition,

Structural Welding Code - Steel, American Welding Society,

Code Requirements for Nuclear Safety Related Concrete

Structures,

Seismic Analysis of Safety-Related Nuclear Structures

License Documentation Impact: (Request # 1): Add the following drawings to the "Fluorine

Extraction Process & Depleted Uranium De-conversion Plant (FEP/DUP) License Application

Engineering Drawings" package that was furnished with the IIFP License Application:

* Replace conceptual facility site plan drawing 1 00-C-000 1 Rev D with updated drawing

100-C-0001 Rev E.

* Add conceptual floor plans of process buildings showing equipment layout, and add

multiple horizontal and vertical cross-sectional drawings of the conceptual structural

design of the Process Buildings (drawings: 400-M- 1201 -D, 400-M- 1202-B, 500-1201-C

and 500-1202-C).

License Documentation Impact (Requests #2): The codes and standards will be added to IIFP

ISA Summary Section 2.3.2 in response to RAI SS-8 for structural and foundation design of IIFP

Facility buildings with emphasis on seismic design.

License Documentation Impact (Requests #3 through 5): None at this time.

RESPONSE (Request # 6): Based upon guidance provided in NUREG-1520, an assessment of

building damage and the resulting radiological and chemical consequences from a seismic event

Official Responses to Seismic/Structural RAls Page 36
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

that has a 1 x 10-5 annual probability is not required. The consequences of a I x 10-5 annual

probability (100,000 year return period) seismic event does not need to be evaluation as the

frequency is such that risk acceptability is met based on likelihood alone.

Table 5-8 of the ISA Summary (provided below) shows the scoring of initiating events based on

frequency. A 100,000 year return period results in a 10-5 annual probability and is scored a -5.

Using this value we can then determine the likelihood category for this event. (Note:

prevention/protection IROFS are typically included in the likelihood determination, but none are

assumed present for this scenario). Table 5-9 of the ISA Summary is provided below. Based on

the -5 scoring from Table 5-8, the 100,000 year return seismic event is categorized as a highly

unlikely event. Also the comments column of Table 5-8 was originally added to illustrate

examples for the failure frequency indices, but is now being deleted to avoid apparent confusion

between the "comment" and "frequency evidence" statements.

Table 5-8. Initiating Event Failure Frequency Index Values

Failure

Frequency Based on Evidence Comments

Index*

-6 External Event with frequency of<10-6/yr if i.it.iatin.g es.ent, no neede,., .ROFS 

External Event with frequency of>10-6/yr if initiating even.t,;. nROFS nieed

and <10 5/yr

-4 No occurrences in 30 years for hundreds of Rarely can bejustified by evidence.

similar systems in industry

No occurrences in 30 years for tens of Requires mu.ltiple failu.res. o. failre. 4o a

similar systems in industry ...... p v e ........ . ..... .....

-2 No occurrences of this type in this facility in Appicbl fr p ...... failur... 30 years N il for... ... ....... v fa.....

-1 A few occurrences during facility lifetime Appliable for routin mec..anical

A,6ppicIable forIopcat,-,,Freors, leSS c0 Occurs every I to 3 years r,. , tf.

1 Several occurrences per year

2 Occurs every week or more often

*Based on the example provided in NUREG-1520. Indices less than (more negative than) -I should

not be assigned unless the configuration management, auditing, and other management measures are

high quality.

Official Responses to Seismic/Structural RAls Page 37
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAls

Table 5-9. Likelihood Categories

Event Likelihood Probability of Occurrence Qualitative Description

Likelihood Category

Not Unlikely 3 Greater than 10 4 per event per year

Unlikely 2 Between I0-4 and 105 per event per Consequence Category 2

year accidents must be "unlikely."

Consequence Category 3

Highly Unlikely 1 10-5 or less per event per year accidents must be "highly

unlikely."

The consequences and likelihood categories are displayed below in Table 5-10 (from the ISA

Summary) in a 3 x 3 risk index matrix. The overall risk number of an accident is determined by

the product of the likelihood category number and the consequence category number.

Unacceptable risk levels are highlighted with shaded areas. IROFS are needed for accidents that

fall in the shaded regions so that an acceptable risk level is achieved.

Table 5-10. Risk Matrix and Risk Index Values

Likelihood of Occurrence

ikelihood Category L ikelihood Category 2 Likelihood

Severity of Consequences LCCategory 3

Highly Unlikely Unlikely Not Unlikely (1) (2) (3)

Category 3 Acceptable Risk Unacceptable Unaccepitabi

High Consequence R

(3) 3

Category 2 Acceptable Risk Acceptable Risk Unacceptable

Intermediate Consequence

(2) 2 4

Category 1 Acceptable Risk Acceptable Acceptable

Low Consequence Risk Risk

(3)

2 3

A 100,000 year return period seismic event results in a risk number of 3 and meets criteria for

acceptable risk. But as shown in Table 5-10 from the ISA Summary, events that fall into

Likelihood Category 1 meet risk acceptability regardless of the consequences. Even assuming

facility collapse and high radiological and chemical consequences occur during a 100,000 year

earthquake, we still meet the criteria for acceptable risk.

License Documentation Impact (6): None for this RAI response.

Official Responses to Seismic/Structural RAls Page 3 8
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

SS-8. Background.:

The regulations in 10 CFR 70.64(a)(2) and 70.64(a)(4) require the applicant to include adequate

protection against natural phenomena, environmental conditions, and dynamic effects in its

design of the facility.

Issue.:

In LA Section 2.2.7, DB contractor, the applicant stated that it will rely on the DB contractor to

ensure that design meets all applicable Federal, State, and local codes and standards required

for the startup stage of the project. However, the applicant did not provide this list.

Reguest:.

Provide a list of applicable Federal, State, and local codes and standards that the DB contractor

will use for the startup stage of the project.

RESPONSE: The following is a list of applicable Federal, State, and local codes and standards

that the DB contractor will use during the detailed design, construction and startup stage of the

project to insure adequate protection against natural phenomena, environmental conditions, and

dynamic effects. The DB contractor will also ensure, as part of the written contract, that design

meets these applicable federal, state and local codes and standards.

License Documentation Impact: Revise Section 2.3 "Building Codes and Standards" of the

IIFP ISA to replace existing building codes with an updated and expanded list of building codes.

After Table 2-2 following the second paragraph of 2.3, insert new Sections 2.3.1, 2.3.2, 2.3.3,

2.3.4, and 2.3.5 to read as follows:

2.3 Building Codes and Standards

The design and construction of the on-site I1FP facility buildings conform to applicable building

codes and standards. The basic-construction codes applied include:

"nteirnational Building Code (IBC) as amended b_+y, tfhe.C

SUnifer Me .. .hanical Code (UMC) as anem;lded by the Npew Mexio e i

(NNW1~Cy.

" Uniform Plumbing Code (UPC) as amenided by, the New, Mexico Plumbing Code

(N-4wC),

" Inter-A~tional Ener-gy Consevvation Code (LECC) as amended by the Nelw Mexieo Energy

" international Fire Cede (IFC).

" NFPA 104 (Life Safeýty Cede), and

* Nationial Electrical Code as amended by the New Meexico Electrical Code (NMEC).

Codes followed for eenstruction ar~e the latest editions as adopted by the State ef New Mexiico.

Table 2-2 below is a listing of code conformance for buildings located on site based on New

Mexico Commercial Building Code (NMCBC, 20062009), NFPA 13 (NFPA, 2047-a20 10), and

NFPA 101 (NFPA, 200-72009).

Official Responses to Seismic/Structural RAls Page 39
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

2.3.1 General Building Codes and Standards

2009 New Mexico Commercial Building Code (adopts by reference the 2009

International Building Code (I BC) with amendments),

2009 New Mexico Energy Conservation C ode (adopts by reference the 2009

international energy conservation code (IECC) with amendments).

2009 New Mexico Plumbing Code (adopts by reference the 2009 Uniform

Plumbing Code (UPC) with mnendments),

2009 New Mexico Mechanical Code (adopts by reference the 2009 Uniform

Mechanical Code (UMC) with amendments).

2008 New Mexico Electrical Code (adopts by reference the 2008 national

electrical code (NEC) with amendments),

2007 New Mexico Electrical Safety Code (adopts by reference the 2007

national electrical safety code (NESC) with amendments),

2009 International Fire Code,

2010 American Society for Mechanical Engineering (ASME) Section VIII.

Division I Design and Fabrication of Pressure Vessels.

2010 ASME B3 1.1 "Power Piping",

2009 ASME 1331.3 "Process Piping",

2010 ASME B31.5 "Refrigeration Piping and Heat Transfer Components."and

2008 ASME B31.9 "Building Services Piping".

2.3.2 Structural and Foundation Codes and Standards

ASCE 7-05

ACI 318-08

ACI 530-08/

ASCE 5-08/

TMS 402-08

ANSI! AISC 360-05

AI SC

ANSI!AISC 341-05

AWS D1.1-2004

ANSIiAISC N690-06

ACI-349-06

ASCE 4-98

Minimum Design Loads for Buildings aid Other Structures,

Building Code Requirements for Structural Concrete.

Building Code Requirements for Masonry Structures,

Building Code Requirements for Masonry Structures,

Building Code Requirements for Masonry Structures.

Specification for Structural Steel Buildings,

Steel Construction Manual I' t" Edition,

Seismic Provisions for Structural Steel Buildings.

Structural Welding C(ode - Steel, American Welding Society,

Specification for Safety-Related Steel Structures for Nuclear

Facilities

Code Requirements for Nuclear Safety Related Concrete

Structures, and

Seismic Analysis of Safety-Related Nuclear Structures.

2.3.3 Geotechnical and Geophysical Codes and Standards

Editions listed are shown exactly as designated by ASTM organization as being active editions. If

the standard identifier number does not have a date in parenthesis, the active date is designated by

the last two digits in the standard identifier number.

e ASTM D420-98 (2003) Standard Guide to Site Characterization for Engineering,, Design, and

Official Responses to Seismic/Structural RAIs Page 40
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

" ASTM D421-85 (2007)

" ASTM D422-63 (2007)

" ASTM D854-10

" ASTM D 1140-00 (2006)

" ASTM D 1452-09

" ASTM D[1557-09

" ASTM D1586-08a

" ASTM DI 883-07e2

" ASTM D2216-10

" ASTM D2487-10

" ASTM D2488-09a

" ASTM D2850-03a (2007)

" ASTM D4220-95 (2007)

" ASTM D4318-10

" ASTM D4428-07

* ASTM D4633-10

" ASTM D4767- I1

" ASTM D5434-09

" ASTM D5778-07

* ASTM D6635-01 (2007)

" ASTM D6429-99 (2006)

Construction Purposes.

Standard Practice for Dry Preparation of Soil Samples for Particle Size

Analysis and Determination of Soil Constants,

Standard Test Method for Particle Size Analysis of Soils.

Standard Test Method for Specific Gravity of Soils,

Standard Test Method for Amount of Material in Soils Finer than the

No. 200 Sieves,

Standard Practice for Soil Investigation and Sampling by Auger

Borings.

Test Method for Laboratory Compaction Characteristics of Soil Using

Modified Effort (56.000 ft-lb/ft3 (2,700 KN - mrmn3 )),

Standard Method for Penetration Test and Split-Barrel Sampling of

Soils,

Test Method for California Bearing Ratio (CBR) of LaboratoryCompacted Soils.

Standard Test Method for Laboratory Determination of Water

(Moisture) Content of Soil and Rock,

Standard Classification of Soils for Eng;ineering Purposes (Unified Soil

Classification System),

Standard Practice for Description and Identification of Soils (Visual

Manual Procedure).

Test Method for Unconsolidated, Un-drained Strength of Cohesive

Soils in Triaxial Compression.

Standard Practices for Preserving and Transporting Soil Samples.

Standard Test Method for Liquid Limit. Plastic Limit. and Plasticity

Index of Soils.

Standard Test Method for Cross-hole Seismic Testing,

Standard Test Method for Energy Measurement for Dynamic

Penetrometers,

Standard Test Method for Consolidated- Un-drained Triaxial

Compression Test on Cohesive Soils,

Guide for Field I.,ogging of Subsurface Explorations of Soil and Rock,

Standard Test Method for Perforning Electronic Friction Cone and

Piezocone Penetration 'Iesting of Soils.

Standard Test Method for Performing the Flat Dilatometer

(SUPPLIER shall implement method exceptions cited in Subpart 3.2.6

of this Specification because of obsolescence of major elements in

ASTM D6429). and

Standard Guide for Selecting Surface Geophysical Methods.

2.3.4 NFPA Codes and Standards

NFPA 10-2010 Portable Fire Extinguishers.

NFPA 13-2010 Installation of Sprinkler Systems,

NFPA 14-2010 Standard for the Installation of Standpipe and Hose Systems,

NFPA 15-2007 Standard for Water Spray Fixed Systems for Fire Protection,

NFPA 20-20 10 Installation of Stationary Pumrps for Fire Protection,

Official Responses to Seismic/Structural RAIs Page 41
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

NFPA 22-2008 Water Tanks for Private Fire Protection,

NFPA 24-2010 Installation of Private Fire Service Mains and Their Appurtenances.

NFPA 30-2008 Flammable and Combustible Liquids Code,

NFPA 45-2011 Fire Protection for Laboratories Using Chemicals,

NFPA 54-2011 National Fuel Gas Code,

NFPA 55-2010 Storage. Use and Handling of Compressed Gases and Cryogenic Fluids

in portable and Stationary Containers, Cylinders and Tanks,

NFPA 70-2011 National Electric Code.

NFPA 70E-2009 Standard for Electrical Safety in the Workplace®.

NFPA 72-2010 National Fire Alarm Code.

NFPA 80-2010 Standard for Fire Doors and Other Opening Protectives,

NFPA 80A-2007 Recommended Practice for Protection of Buildings from Exterior Fire

Exposures,

NFPA 85-2011 Boiler and Combustion Systems Hazards Codes,

NFPA 90A-2009 Installation of Air-conditioning and Ventilating Systems,

NFPA 90B-2009 Installation of Warm Air Heating and Air-conditioning Systems.

NFPA 91-2010 Standard for Exhaust Systems for Air Conveying of Vapors. Gases,

Mists. and Noncombustible Particulate Solids.

NFPA 101-2009 Life Safety Code.

NFPA 110-2010 Emergency and Standby Power Systems.

NFPA 220-2009 Standard on Types of Building Construction

NFPA 221-2009 Standard for High Challenge Fire Walls, Fire Walls, and Fire Barrier

Walls.

NFPA 251-2006 Standard Methods of Tests of Fire Resistance of Building Construction

and Materials,

NFPA 430-2004 Storage of l.iquid and Solid Oxidizers.

NFPA 600-2010 Standard on Industrial Fire Brigades,

NFPA 780-2011 Standard for the Installation of Lightning Protection Systems.

NFPA 801-2008 Standard flor Fire Protection for Facilities Handling Radioactive

Materials, and

NFPA 1410-2010 Standard on Training for Initial Emergency Scene Operations.

2.3.5 Instrumentation and Controls Codes and Standards

The criteria in the following regulatory guides and standards will be used to ensure that the

insirumentation and control IROFS will be desinned to monitor and control their behavior:

NRC Regulatory Guide 1.53

NRC Regulatory Guide 1 .118

NRC Regulatory Guide 1.152

NRC Regulatory Guide 1. 153

NRC Regulatory Guide 1.168

NRC RegLulatory Guide 1.169

"Criteria for Safety Systems" (Endorses IEEE Std. 279-1971).

"Periodic Testing of Protection Systems,"

Criteria for Use of Computers in Safety Systems of Nuclear Power

Plants" (Endorses IEEE Std. 603-1998),

"I & C Safety Systems" (Endorses IEEE Std. 603-1991),

"Software Verification and Validation Reviews and Audits for

Digital Computer Software Used in Safety Systems of Nuclear

Power Plants " (Endorses IEEE Std. 1012-1998).

"Configuration Management Plans for Digital Computer Software

Official Responses to Seismic/Structural RAIs Page 42
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

NRC Regulatory Guide 1.170

NRC Regyulatory Guide 1.171

NRC Regulatorv Guide 1.172

NRC Regulatorv Guide 1.173

NRC: Regulatory Guide 1.180

NRC Retulatorv Guide 1.209

ANSI/ISA-67.04.01-2000

IEEE Std. 336-1985

IEEE Std 384-1992

IEEE Std 344-1987

IEEE Std 338-1987

IEEE Std 518-1982

NUREG-0800

NUREG-0800

NR.C Regulator' Guide 1.180-

2000

NRC: Regulatory Guide 1.100-

1988, Revision 2,

Used in Safety Systems of Nuclear Power Plants" (Endorses IEEE

Std. 828-1990).

"Software Test Documentation for Digital Computer Software

Used in Safety Systems of Nuclear Power Plants" (Endorses IEEE

Std. 829-1983),

"Software Unit Testing for Digital Computer Software Used in

Safety Systems of Nuclear Power Plants" (Endorses IEEE Std.

1008-1987),

"Software Requirements Specifications for Digital Computer

Software Used in Safety Systems of Nuclear Power Plants"

(Endorses IEEE Std. 830-1993),

"Software Life Cycle Processes for Digital Computer Software

Used in Safety Systems of Nuclear Power Plants" (Endorses IEEE

Std. 1074-1995).

"Electroma~netic Compatibility" (Endorses IEEE Std. 1050-1996,

IEC Std. 61000-2005, IEEE Std. C62.41-1991, and Mil Std. 461-

1991).

"Guidelines for Environmental Qualification of Safety-Related

Computer-Based Instrumentation and Control Systems in Nuclear

Power Plants."

"Setpoints for Nuclear Safety-Related Instrumentation,"

"Standard Installation. Inspection. and Testing Requirements for

Power Instrumentation. and Control Equipment at Nuclear

Facilities,"

"Standard Criteria for Independence of Class I E Equipment and

Circuits."

"IEEE Recommended Practices for Seismic Qualification of Class

I E Equipment for Nuclear Generating Stations,"

"IEEE Standard Criteria for Periodic Testing of Nuclear Power

Generating Station Class IE Power and Protection Systems," "IEEE Guide for the Installation of Electrical Equipment to

Minimize Electrical Noise Inputs to Controllers firom External

Sources."

Standard Review Plan. Branch Technical Position ]-IICB- 11,

"Guidance on the Application and Qualification of Isolation

Devices,"

Standard Review Plan, Branch Technical Position HICB- 17.

"Guidance on Self-Test and Surveillance Test Provisions."

"Guidelines for Evaluating Electromagnetic and Radio-Frequency

Interference in Safety-Related Instrumentation and Control

Systems," and

"Seismic Qualification of Electric and Mechanical Equipmnent for

Nuclear Power Plants."

Official Responses to Seismic/Structural RAIs Page 43
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAls

License Documentation Impact: The former 6th paragraph of Section 1.1.2 of the IIFP License

Application, Revision A, will be revised to read as follows:

1.1.2 Facility Description

See ISA Summary Section 2.3 for a list of applicable Federal. State. and local codes and

standards that the DB contractor will use during the detailed design, construction and startup

stage of the project to insure adequate protection against natural phenomena, environmental

conditions, and dynamic effects. The DB contractor will also ensure, as part of the written

contract. that design meets these applicable federal, state and local codes and standards.

Buildings, lighting, fire protection, and building support systems are designed in accordance

with latest revisions, of building and construction codes including where applicable the

National Fire Protection Association (NFPA) standards, local and State codes, and related

codes and standards. A list of NFPA Standards is repeated in Chapter 7 of the IA. Table 7-1.

A listing of the major buildings and estimated sizes is provided in Table 1-2.

License Documentation Impact: The last paragraph of Section 1.1.2.1 of the IIFP License

Application, Revision A, will be revised this RAI will supersede RAI G1-6B to read as follows:

1.1.2.1 Process Buildings and Process Areas

The process buildings are classified per NFPA 13 as Ordinary Group 2 and are protected with 100

percent coverage, wet-type fire protection sprinkler systems with Class I standpipes between

floors in all exit stairways of multi-story buildings7 (NFPA, 2007).Further information is provided

for code construction conformance requirements in the IIFP Integrated Safety Analysis Summary.

Section 2.3. IIFP will contract and use a. Design and Build contractor for detail design.

engineering and construction of the IIFP Facility.

License Documentation Impact: The last paragraph of Section 4.4.2 of the IIFP ISA Summary

will to read as follows:

4.4.2 Natural Phenomena Hazards

Engineering design requirements for all active and passive IROFS will include adequate

protection from natural phenomena events. Seismic, wind, and lightning hazards will be

specifically addressed through implementation of building code design requirements as listed in

Section 2.3. suC - a: !-A.S.tIa Bufilding, Code; as amended by h..e 2006iNew-A 1(eio Go.......... e ,r- Buidin ,,ial Code)l~ (11C, 2006), , \SCF 7 05 (Minimumi Designe•,oLads forf Buildings. n k~ 1 ~ 1, 1 lD$ I f I4 ThAAl A 7Q(/X,] I f', ..- i ,/* I ,,]f

Other~o Shntmetur's (A SCE•L 2006)K. •, an NPPI-ND 7T90" (Stifar for. h i*onstalla~n 444ý ,,hn * 

PF , Ssm ,, .. ( : LA \,Table 4-4-10 and Table 4-4-0-11 document examples of how

the design incorporated natural phenomena hazards for engineered IROFS.

License Documentation Impact: Revise references in Section 2.6 to reflect the updated

versions of building codes to read as follows:

Official Responses to Seismic/Structural RAIs Page 44
Enclosure 1 - JJM-2011-32

Official Responses to Seismic and Structural RAIs

2.6 References

IIFP, 2009. International Isotopes Fluorine Products. Inc., "License Application for FEP/DUP

Facility." International Isotopes Fluorine Products,2009.

NFPA, 2007a20 10. National Fire Protection Association "NFPA 13, Installation of Sprinkler

Systems." Quincy, MA, MA : National Fire Protection Association, 2-O-20 I Oa.

NFPA, 2007-b2009. National Fire Protection Association."NFPA 101, Life Safety. Life Safety

Code." Quincy, MA,-M N4 National Fire Protection Associationi, 20072009b.

NMCBC, 20062009. New Mexico Commerical Building Code, Title 14, "Housing and

Construction," Chapter 7, Building Codes General Part 2. s.l. :

http://www.nmcpr.state.nm.us/nmac/parts/title 1 4/14.007.0002.htm, 204462009.

Official Responses to Seismic/Structural RAls Page 45