International Isotopes Fluorine Products, Inc. (IIFP) 

A Wholly Owned Subsidiary of 

International Isotopes, Inc. (INIS)

Fluorine Extraction Process & Depleted 

Uranium De-conversion 

 (FEP/DUP) Plant 

License Application 

Chapter 8 

Emergency Management 

Revision B 

December 20, 2011 

LA-IFP-001 Revision B CHAPTER 8
LA-IFP-001 Revision B CHAPTER 8 December 20, 2011 

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TABLE OF CONTENTS 

8 EMERGENCY MANAGEMENT ...................................................................................... 8-1 

8.1 LOCAL RESPONDER CORRESPONDENCE ..................................................................... 8-2 

8.1.1 Eunice, New Mexico Fire and Rescue ...................................................................... 8-2 

8.1.2 City of Eunice, New Mexico Police Department ...................................................... 8-3 

8.1.3 Lea Regional Medical Center, Lea County, New Mexico ........................................ 8-4 

8.1.4 Lea County, New Mexico Emergency Management ................................................ 8-5 

8.1.5 Hobbs, New Mexico Fire Department....................................................................... 8-6 

8.1.6 Lea County, New Mexico Sheriff’s Department ....................................................... 8-9 

8.1.7 New Mexico State Department of Homeland Security and Emergency Management .. 

 ................................................................................................................................. 8-11 

8.2 SUMMARY OF COMMENT RESOLUTION .................................................................... 8-13 

8.3 REFERENCES ..................................................................................................................... 8-15 

 
LA-IFP-001 Revision B CHAPTER 8 December 20, 2011 

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8 EMERGENCY MANAGEMENT 

Actions for response to emergencies at the International Isotopes Fluorine Product, Inc. (IIFP), Lea 

County, New Mexico facility are addressed in the separate IIFP Emergency Management Plan (EMP) 

Revision B document. 

The IIFP EMP is developed in accordance with 10 Code of Federal Regulations (CFR) 40.31(j) (CFR, 

2009) and conforms to the guidance presented in Regulatory Guide 3.67, “Standard Format and Content 

for Emergency Plans for Fuel Cycle and Materials Facilities,” U.S. Nuclear Regulatory Commission 

(NRC), 1992). This EMP also conforms with and addresses the acceptance criteria specified in Chapter 8 

of NUREG-1520, Revision 1,“Standard Review Plan for the Review of a License Application for a Fuel 

Cycle Facility,” (NRC, 2010). The IIFP EMP Revision B is submitted to the NRC under a transmittal 

separate from the License Application (LA) chapters. 

The IIFP Emergency Management Plan identifies outside response organizations that review the EMP 

pursuant to the requirement in 10 CFR 40.31(j). As part of the EMP development, the offsite response 

organizations that are expected to respond to an accident event at the IIFP Facility were provided the final 

draft of the initial IIFP Emergency Management Plan for their review and comment. The following is a 

list of those response organizations that were requested to comment on the initial Emergency Plan 

(hereafter referred to as the Emergency Management Plan) and to support IIFP Memorandums of 

Understanding (MOU) for response to accidental events at the facility. 

• Eunice, New Mexico Fire and Rescue 

• City of Eunice, New Mexico Police Department 

• Lea Regional Medical Center, Lea County, New Mexico 

• Lea County, New Mexico Emergency Management, including comments and support 

representing the Lea County Volunteer Fire Departments of Monument, Knowles and Maljamar, 

New Mexico 

• Hobbs, New Mexico Fire Department 

• Lea County, New Mexico Sheriff’s Department 

• New Mexico State Department of Homeland Security 

Comments on the final draft of the initial IIFP Emergency Plan Revision A (now referred to as EMP 

Revision B) were received from each of the above response organizations via letter and verbal 

communications. Comments received via verbal communications where documented in the Revision A 

Comment Sheet. All of the response organizations comments were incorporated into the Emergency Plan 

Revision A; some of which were redundant. Questions were resolved via verbal communications or 

through email correspondence. Copies of the correspondences are included as Section 8.1. Some 

comment providers marked key points in their correspondence with “yellow” highlight. Those highlight 

markings remain in the comment correspondence. A record of the comment resolutions is provided as 

Section 8.2, ‘Summary of Comment Resolution.” 

 
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8.1 LOCAL RESPONDER CORRESPONDENCE: 

8.1.1 Eunice, New Mexico Fire and Rescue 
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8.1.2 City of Eunice, New Mexico Police Department 

 
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8.1.3 Lea Regional Medical Center, Lea County, New Mexico 

 
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8.1.4 Lea County, New Mexico Emergency Management 
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8.1.5 Hobbs, New Mexico Fire Department 
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Redacted – Security related information 
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Redacted – Security related information 
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8.1.6 Lea County, New Mexico Sheriff ‘s Department 
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Redacted – Security related information 
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8.1.7 New Mexico State Department of Homeland Security and Emergency Management 
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8.2 SUMMARY OF COMMENT RESOLUTION 

Reviewing Organization Section Comment 

Lea County Sheriff’s Office 7.4 Redacted – Security related information Lea County Sheriff’s Office 7.4.3 Redacted – Security related information. Eunice Fire and Rescue 2.2.1 New Mexico SR209 does not run south from Hobbs to Eunice and Jal. NM SR18 does r

south from Hobbs to Eunice and Jal. 

Eunice Fire and Rescue 7.4.2 Needs to be modified in the first paragraph to include Monument, NM Fire Department

Their fire district borders the proposed site on the west and south sides. While they do nhave EMS transport capabilities, they do have EMT’s, fire and rescue capabilities. 

Eunice Fire and Rescue 7.4.2 Same as above needs to be modified to include Monument, NM Fire Department. Lea Regional Medical Center No comments at this time. City of Eunice, Police Dept. 7.4.3 Even though the Eunice Police Department is not listed as a backup agency in case of an 

emergency we would make our officers available, if requested. 

Hobbs Fire Department 7.3.1 Redacted – Security related information. Hobbs Fire Department 7.3.4 What level of training/certification does your HAZMAT team possess? Hobbs Fire Department 7.4.2 Hobbs Fire Department, in addition to fire and rescue, has a fully equipped HAZMAT 

response vehicle with 19 fully trained HAZMAT technicians, and all other personnel arOperations/OPS Decontamination certified. 

Hobbs Fire Department 7.4 Remove Hobbs Fire and Rescue and replace with Hobbs Fire Department. Hobbs Fire Department 7.4.1 Remove Hobbs Fire and Rescue and replace with Hobbs Fire Department. 
LA-IFP-001 Revision B CHAPTER 8 

SUMMARY OF COMMENT RESOLUTION (Continued) 

Reviewing Organization Section Comment 

Hobbs Fire Department 7.4.2 Remove Hobbs Fire and Rescue and replace with Hobbs Fire Department Hobbs Fire Department 7.4.2 Class rating of -4. What is this rating? Hobbs Fire Department 7.4.2 Remove Eunice Fire Department, replace with Monument Volunteer Fire. Monument is 

adjacent/adjoining response coverage area. 

NMDHSEM 6.3 Change reference to Office of Emergency Management (OEM) to NM Department of 

Homeland Security and Emergency Management 

NMDHSEM 7.3.10 Clarify level of employee first aid training. NMDHSEM 7.3.13 5th bullet – what type of respirator protection? NMDHSEM 7.4 Change agency name to reflect NM DHSEM NMDHSEM 7.4 Change agency name to reflect NM DHSEM (4th paragraph) NMDHSEM 7.4.3 Add reference to NM Hazardous Material Emergency Response Plan. NMDHSEM 8.2.2 5th bullet change agency name to reflect NMDHSEM NMDHSEM 8.4.2 3rd paragraph change agency name to reflect NMDHSEM NMDHSEM 9.2.1.3 2nd bullet change agency name to reflect NMDHSEM 
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8.3 REFERENCES 

CFR, 2009 Title 10, Code of Federal Regulations, Section 40.31(j), “Application for Specific 

 Licenses,” 2009. 

NRC, 1992 U.S. Nuclear Regulatory Commission, “Standard Format and Content of Emergency 

 Plans for Fuel Cycle and Materials Facilities,” Regulatory Guide 3.67, NRC, 1992. 

NRC, 2010 U.S. Nuclear Regulatory Commission, “Standard Review Plan for the Review of a 

 License Application for a Fuel Cycle Facility,” NUREG-1520, Revision 1, NRC, 2010.