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General Information 

GI-1 Comparison between the topographical features in License Application (LA) Figures 1-3 and 1-4 

gives the impression that the 640-acre plot would extend beyond the county sections represented 

in Figure 1-4.Consistent with NUREG-1520, Section 1.1.4.3(2), trace out the 640-acre property 

on LA Figure 1-4, similar to LA Figure 1-3, to clarify how county Sections 26, 27, 34 and 35 

overlap with the 640-acre property. 

RESPONSE: The site proposed by the Lea County Economic Development Council consisted of 

four (4) 640-acre Sections from which INIS would select one section on which to build the 

proposed IIFP Facility. The intent of the original Figure 1-3 in Chapter 1 of the IIFP License 

Application was to show the general area in relation to Highways 62 and 483. At the time that 

Figure 1-3 was developed, the exact boundaries had not been clearly defined. The Figure 1-3 

outline boundaries shown on the map should have been updated to be correct and consistent with 

the later information used in the updated correct Figure 1-4. 

License Documentation Impact: Figure 1-3 in the License Application Revision A, Chapter 1, 

Section 1.1.1 will be replaced with the revised Figure 1-3 below. Also, paragraph three of the 

Section 1.1.1 will be revised to read as follows: 

The area surrounding the site consists of vacant land and industrial properties. The general area 

consisting of four (4) approximate 640-acre Sections is delineated in Figure 1-3, IIFP Site Map 

with Surrounding Industrial Properties. of the site location consisting of four (4) approximate 

640-acre Sections is shown in Figure 1-3 in relation to New Mexico (NM) Highways 483 and 

U.S. Highway 62.

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 Source: Natural Resources Conservation Service, U.S. Department of Agriculture 

Figure 1-3 IIFP Site Map with Surrounding Industrial Properties.

Figure 1-3 IIFP General Site Location in Relation to NM Highway 483 and U.S. Highway 62 

 

 

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GI-2 Consistent with the acceptance requirements presented in NUREG 1.2.4.3(4), provide a specific 

request for a license period such as 10 to 40 years. 

RESPONSE: A specific request for a license period of 40 years is being made in the IIFP 

License Application and described by the revisions below. 

License Documentation Impact: In response to RAI GI-2, new wording will be added to the 2nd

sentence of paragraph six of the IIFP License Application, Revision A, Chapter 1, “General 

Information”. Note: Further modification of the final sentence of the paragraph will be made in 

response to RAI GI-7A. Section 1 paragraph six will be revised to read as follows: 

IIFP is requesting a license authorizing up to 750,000 kilograms of depleted uranium (kgU) to be 

maintained at any one time in the facility inventory. IIFP is requesting the license authorization 

for up to 40 years and is plansning to operate the facility indefinitely and continue to renew the 

licenses as needed. IIFP also has a written agreement with the State of New Mexico on the 

maximum inventories of major chemicalsdepleted uranium oxides and total depleted uranium that 

can be maintained on site. 

License Documentation Impact: Section 1.4 of the IIFP License Application, Chapter 1, will be 

revised to read as follows: 

1.4 Requested Licenses and Authorized Uses 

The Source Material license for the material described in Table 1-4 of Section 1.3 above is 

requested to be authorized for up to 40 years. IIFP plans to operate the facility indefinitely and 

continue to renew the license as needed.

IIFP will not store or process Special Nuclear Material (SNM) at the FEP/DUP Facility. 

Therefore, no licenses and authorized uses for SNM are requested. SNM is defined in 10 CFR 

70.4, “Definitions,” (2008d). 

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General Information 

GI-3 Ensure that the page numbering in the electronic version of the Environmental Report (ER) 

matches the hard copy submitted to the U.S. Nuclear Regulatory Commission (NRC). 

RESPONSE: It is unclear why there would be differences in the page numbering with the 

electronic version of the submitted Environmental Report with the hard copy submitted to the 

NRC. The electronic copy submitted matches the paging of the Environmental Report in the NRC 

Agency Document Access and Management System (ADAMS) Web database. In any new 

revisions, the page numbering of the electronic submittals will be reviewed to ensure that those 

match hard copy submittals. 

License Documentation Impact: None. 

 

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GI-4 Integrated Safety Analysis (ISA) Summary Table 4-3 references release scenario evaluation 

number DUF-00. This term does not appear to be defined in the ISA Summary. Provide a 

definition for DUF-00 in ISA Summary Table 4-2 or some other appropriate location. 

RESPONSE: DUF-00 is not an IROFS. It is defined as “No IROFS Required.” This identifier 

was used as a placeholder in our Excel spreadsheet. A unique identifier and value was needed in 

this location to avoid an error in the spreadsheet calculations. 

License Documentation Impact: The term DUF-00 is being defined and added in the IIFP 

Integrated Safety Analysis Summary, Section 4.1 to read as follows: 

Table 4-1 indicates the definitions for the contents of each column in the accident summary 

tabulations. Table 4-2 is a reference list of identified IROFS that includes a brief functional 

description of each item. The term DUF-00 is used as a special identifier in the ISA Summary 

tables and is defined as “No IROFS required”. More detailed descriptions of IROFS are provided 

in Section 6. It should be noted that these items are shown in numerical order with the exception 

of numbered items that were originally identified as potential IROFS but were not required after 

the final risk analysis was completed, Table 4-3, Table 4-4 and Table 4-5 list the potential 

accident sequences that were identified that could have consequences that are Category 2 or 3 

based on the performance criteria of 10 CFR 70.61 (CFR, 2009a). The likelihood, consequence, 

and risk ratings are also provided. Environmental levels are all determined to be Category 1. The 

measures to reduce the risk to acceptable levels (IROFS) by either reducing the frequency of 

occurrence of the events or mitigating the consequences of the events are also identified. 

Descriptions of the accident sequences are shown in Section 3. 

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GI-5 Verify that the LA section break 1.6.3.4 is placed in the proper location or whether it should be 

moved up one paragraph, next to Hydrology. 

RESPONSE: Hydrology was incorrectly identified as a subheading under Section 1.6.3.3, 

“Severe Weather.” Hydrology should have been labeled as Section 1.6.3.4 with the incorrectly 

labeled Section 1.6.3.4, “Characteristics of Nearby Rivers, Streams, and Other Bodies of Water,” 

as a subheading to Hydrology. The License Application will be revised to correctly label the 

Sections. 

License Documentation Impact: The License Application former Section 1.6.3.3 (now Section 

1.7.3.3 in response to RAI RP-13), subsection “Hydrology” will be revised as follows (No change 

has occurred in the text for the section.): 

Hydrology

1.7.3.4 Hydrology 

License Documentation Impact: The License Application, Revision A, Sections 1.6.3.4-1.6.3.8 

will be revised as a subheading to new 1.7.3.4 “Hydrology”. Subsequent Sections and subsections 

of the Chapter 1 of the License Application will be renumbered accordingly. (No changes will 

occur in the text for these sections.): 

1.6.3.4 Characteristics of Nearby Rivers, Streams, and Other Bodies of Water

Characteristics of Nearby Rivers, Streams, and Other Bodies of Water

1.6.3.5 Depth to the Groundwater Table

Depth to the Groundwater Table

1.6.3.6 Groundwater Hydrology

Groundwater Hydrology

1.6.3.7 Characteristics of the Uppermost Aquifer 

Characteristics of the Uppermost Aquifer

1.6.3.8 Design Basis Flood Events Used for Accident Analysis

Design Basis Flood Events Used for Accident Analysis

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General Information

GI-6 The application should provide a clear understanding of the site operations. Consistent with 

NUREG-1520, Section 1.1.4.3, provide the following information: 

A. The application refers to Phase 1 and 2 of the facility in LA Section 1.2.2, LA Table 7-3, LA 

Chapter 9, LA Chapter 10, and multiple locations in the ER and other documents. The words 

“Phase 1” and “Phase 2” gives the impression that the license application covers both 

Phases. From a licensing review perspective, the only operation under consideration is 

“Phase 1.” “Phase 2” will be evaluated under a completely separate licensing action. This 

is further obscured by the use of the terms “design/build phase” and “operations phase,” 

both of which are included in the review of the current application. Consistent with NUREG1520 , Section 1.1.4.3(1), provide the following information: Consider modifying the phrases 

“Phase 1” and “Phase 2” to refer to separate licensing actions. Make a clear distinction 

between current application activities and future application activities. Provide an 

explanation early in Chapter 1 which clearly explains the difference between the current 

application activities and future application activities. Ensure that this explanation clearly 

distinguishes between current requested activities and future, non-requested activities. 

RESPONSE: In the license application that was submitted in December 2009, the term Phase 1 

Facility is used to identify the near-term construction of the initial IIFP Facility and the associated 

licensing action.

The current license application is only for the near term facility (referred to as Phase 1 Facility) 

and requested activities within the current license applications is only for Phase 1. 

A future expansion is planned (referred to as Phase 2 Facility) that includes additional capacity 

and a process for direct de-conversion of depleted uranium hexafluoride to depleted uranium 

oxide. Phase 2 construction and operation will require a separate and future licensing action. 

The only part of the current IIFP License Application (LA) where there is a need to identify the 

separate Phase 2 future licensing action and construction is the Chapter 9, “Environmental 

Protection.” All other references to Phase 2 will be removed from the License Application other 

than where it is being defined and explained in LA Chapter 1, “General Information.” 

The referral to a future Phase 2 expansion is briefly discussed in the LA Chapter 9 owing to links 

and references in the LA Chapter 9 to the IIFP “Environmental Report” (ER). IIFP decided to 

prepare and submit the ER for the IIFP Site for both the initial facility being covered under the 

current license application and for the planned expansion later. The future Phase 2 Facility is 

evaluated in the current ER submittal owing to the plans to add a Phase 2 expansion within 

approximately 3-4 years of the initial facility operation. However, that Phase 2 expansion would 

require a separate and future licensing action. 

Additionally, the word “Phase” in relation to design/build, construction and operation of the 

facility will be removed during the next License Application revision. 

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License Documentation Impact: An explanation beginning with a new third paragraph will be 

added to the IIFP License Application Chapter 1, “General Information” introductory section, 

former paragraph three will also be revised. The information in the new paragraphs clarifies the 

differences between the Phase 1 and Phase 2 Facilities relative to their different construction time 

periods and separate licensing actions. The introductory section will be revised to read (changes 

in red text) to read as: 

International Isotopes Fluorine Products (IIFP), Inc., a wholly owned subsidiary of International 

Isotopes Inc. (INIS), intends to build and operate a new uranium processing facility (plant) near 

Hobbs in Lea County, New Mexico (referred to as the Hobbs site). IIFP will provide services to 

the uranium enrichment industry for converting (de-conversion) depleted uranium hexafluoride 

(DUF6) into uranium oxide for long-term stable disposal. The company will also include a 

commercial plant to produce specialty fluoride gas products for sale. High-purity silicon 

tetrafluoride (SiF4) and boron trifluoride (BF3) will be manufactured in the IIFP facility by 

utilizing the fluorine derived from the de-conversion of DUF6. The fluoride gas products are 

highly valuable for applications in the electronic, solar, and semi-conductor markets. In addition, 

anhydrous hydrogen fluoride (AHF) is a product of the de-conversion and is sold as a chemical in 

high demand for various industrial applications. 

Depleted uranium hexafluoride referred to as “tails” is the by-product of uranium enrichment. 

Enrichment is required as a vital step in the nuclear fuel cycle to produce fuel for nuclear reactors. 

All of the existing and planned commercial uranium enrichment processes use uranium 

hexafluoride (UF6) as the process gas to produce isotopic enriched UF6. Upon further processing, 

the enriched uranium material results in the desired nuclear fuel product. The depleted tails may 

have some residual value but will ultimately require disposal. A commercial service is needed in 

the U.S. to convert the DUF6 into the more stable uranium oxide for long term disposal. This 

process is generally referred to as “de-conversion”. IIFP is proposing to design, engineer and 

license the nation’s first privately-owned commercial facility for de-conversion of DUF6. 

IIFP is applying for a license to construct and operate a facility for commercial de-conversion 

services and production of high-purity products as discussed above. This current license 

application and requested licensing activities considers only the near term initial facility 

construction and operation and is referred to as the Phase 1 Facility and licensing action. 

A future expansion is planned (referred to as Phase 2) but it is not part of the current licensing 

activity or application. Any such new expansions (or facility phases) would be licensed and 

constructed in different time periods under separate licensed actions. 

The only part of the current license application where there is a need to identify the future and 

separate Phase 2 licensing action and construction is the Chapter 9, “Environmental Protection.” 

The referral to a future Phase 2 expansion is briefly discussed in the LA Chapter 9 owing to links 

and references in the LA Chapter 9 to the IIFP “Environmental Report” (ER). IIFP decided to 

prepare and submit the ER for the IIFP Site for both the initial facility being covered under the 

current license application and for the planned later expansion. The future Phase 2 Facility is 

evaluated in the current ER submittal because of plans to add a Phase 2 expansion within 

approximately 3-4 years of the initial facility operation. However, that Phase 2 expansion would 

require a separate and future licensing action. 

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This Chapter provides an overview of the initial IIFP Facility; specifically named the Fluorine 

Extraction Process/Depleted Uranium De-Conversion Plant (FEP/DUP) commercial facility along 

with a description of the facility and various processes and a description of the FEP/DUP site. 

Institutional information is provided to identify the applicant, describe the applicant’s financial 

qualifications, and describe the proposed license activities. 

License Documentation Impact: Section 1.2.2 of the IIFP License Application will be revised 

to read as follows: 

1.2.2 Financial Qualifications 

IIFP estimates the total initial capital and startup cost of the initial IIFP Facility FEP/DUP 

commercial facility to be approximately $75-90 million dollars (estimated in 2009 US dollars), 

excluding escalation, interest, waste disposition, decommissioning, and any replacement 

equipment required during the life of the facility.Plans are to finance the facility mostly through 

capital funding investors.

IIFP presently intends to utilize a surety bond and Standby Trust Fund method to provide 

reasonable financial assurance of that decommissioning funding will be available at the time of 

decommissioning the facility. At least six months prior to startup of the Phase 1IIFP Ffacility

described in the current license application, IIFP will provide NRC the financial assurance 

instrument that IIFP intends to execute. Upon finalization of the specific funding instrument to be 

used and at least 21 days prior to the commencement of operations, IIFP will supplement its 

application to include the signed, executed documentation. The surety bond and fund will provide 

assurance that decommissioning costs will be paid in the unexpected event IIFP is unable to meet 

its decommissioning obligations at the time of decommissioning. In this case, funds drawn from 

the surety bond will be placed directly into a standby trust fund naming the U.S. Nuclear 

Regulatory Commission as the beneficiary. 

A Decommission Funding Plan (DFP) for the facility is developed and provided as Chapter 10 of 

the IIFP NRC Licensing Application. 

License Documentation Impact: The third paragraph of the IIFP License Application, Chapter 9 

introductory section will be revised to read as follows: 

It also should be noted, that in In addition to the proposed facility requested in the current 

licensing activity and License Applicationof this submitted LA, the ER evaluates the 

environmental effects of an a future add-on DUF6 process for direct de-conversion to depleted 

uranium oxide, referred to as Phase 2. The DUF6-to-oxide de-conversion future expansion is not 

part of the current License Application or requested activities. The future Phase 2 process was 

evaluated in the current ER submittal owing to the plans to begin adding this process to the 

original facility within approximately 3-4 years of the first facility operation. The DUF6-to-oxide 

de-conversion plant is not part of this initial LA. The Phase 2 expansion would require a separate 

and future licensing activity at the appropriate time to its construction. Plans are to amend the LA 

for the future Phase 2 process at the appropriate time.

License Documentation Impact: The first paragraph (split to create a new second paragraph) of 

Section 9.1 of the IIFP License Application will be revised to read as follows: 

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9.1 Environmental Report 

The ER (IIFP, 2009) constitutes one portion of an application to be submitted by IIFP to construct 

and operate a facility that offers de-conversion services of DUF6 and extracts the fluoride from 

the DUF 6 to produce high-purity fluoride gas products and anhydrous hydrofluoric acid (AHF). 

During this Phase 1 process the DUF6 uranium will be de-converted into depleted uranium (DU) 

tetrafluoride (DUF4) and then into DU oxide in the fluorine extraction process. In the future Phase 

2 Ffacility, that will be licensed and constructed as a separate activity, an additional process will 

be used for direct de-conversion of DUF6 to AHF and depleted uranium oxide. In both processes, 

the fluorine products and AHF are sold, and the depleted uranium oxide is sent for off-site 

disposal to a licensed low-level radioactive waste disposal facility. 

The proposed IIFP Ffacility, and planned phase 2 expansion, will be located near Hobbs, New 

Mexico (Figure 9-1). The ER for the proposed facility serves two primary purposes. First, it 

provides information that is specifically required by the Nuclear Regulatory Commission (NRC) 

to assist it in meeting its obligations under the National Environmental Policy Act (NEPA) of 

1969 (NEPA, 1969) and the Environmental Protection Agency’s (EPA) NEPA-implementing 

regulations. Second, it demonstrates that the environmental protection measures proposed by IIFP 

are adequate to protect both the environment and the health and safety of the public. 

License Documentation Impact: The introductory section of IIFP Chapter 10, 

“Decommissioning” will be revised to eliminate references to a Phase 2 facility and will read 

(changes in red text) as follows:

10 Decommissioning 

This chapter presents the International Isotopes Fluorine Products, Inc. (IIFP) Plant initial 

Decommissioning Funding Plan for its Fluorine Extraction Process and Uranium De-conversion 

Plant (FEP/DUP). This Decommissioning Funding Plan (DFP) has been developed following the 

guidance provided in NUREG-1757 (NRC, 2006). The DFP is for only the current IIFP License 

Application and licensing activities. Any future facility expansions of licensing actions would 

require an amended or separate DFP. 

The IIFP facility will be constructed in two phases, with Phase 1 completing the DUF6 to DUF4

process and the DUF4 to fluorine products processes and the supporting infrastructure of the plant. 

IIFP plans to expand the facility de-conversion capacity by constructing a Phase 2 plant 

approximately 4 years later. The current licensing application, Integrated Safety Analysis (ISA) 

and Decommission Funding Plan submittal are for Phase 1 construction and operation only. 

Separate or amended licensing and a revised DFP will be developed and submitted at an 

appropriate time during the licensing process of the Phase 2 project. The Phase 2 will consist of 

the additional processing equipment to convert DUF6 directly into uranium oxide.

IIFP, Inc., as a wholly owned subsidiary of International Isotopes, Inc. (INIS), commits to 

decontaminate and decommission the facility at the end of its operation so that the facility and 

grounds can be released for unrestricted use. The Decommissioning Funding Plan will be 

reviewed and updated as necessary at least once every three years starting from the time of the 

start of operations. Prior to facility decommissioning, a Decommissioning Plan will be prepared 

in accordance with 10 CFR 40.42 (CFR, 2008a) and submitted to the NRC for approval.

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This chapter fulfills the applicable provisions of NUREG-1757 (NRC, 2006) through submittal of 

information in tabular form (Tables 10-1 through 10-18) as suggested by the NUREG. 

License Documentation Impact: The first paragraph of the IIFP License Application Section 

10.1 will be deleted and the revised Section will read as follows. Also, the wording “Phase 1” will 

be deleted from the title of Section 10.1.1 as shown below. 

10.1 Decommissioning Strategy 

The Decommissioning Funding Plan addresses the overall strategy for decommissioning the 

entire Phase 2 facility. However, because of the two-phase construction approach to this facility, 

the DFP only provides a detailed cost estimate, schedule and the financial assurance plan for the 

Phase 1 equipment and the infrastructure equipment that will be common to both phases. This 

initial DFP, including cost estimates, schedule and financial assurance, assumes that only a Phase 

1 facility would exist at the time that decommission is required. This strategy of preparing and 

submitting an initial DFP for Phase 1 facilities only, in this license application, conservatively 

considers that IIFP would cease business before Phase 2 is constructed or that Phase 2 would not 

materialize. This contingency strategy does provide for the financial assurance of the Phase 1 

facility in any case. Expansion of the plant to Phase 2 will require amendments to the IIFP 

license, and the DFP will be updated and re-submitted to the NRC for approval prior to the 

introduction of nuclear materials into the Phase 2 portion of the facility. 

The overall strategy for decommissioning is to decontaminate or remove all materials from the 

site in order to release the facility and the site for unrestricted use. This approach avoids longterm storage and monitoring of wastes on site. The type and volume of wastes produced at the 

FEP/DUP facility do not warrant delays in waste removal normally associated with a deferred 

dismantlement option.

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

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

2008b). 

All remaining facilities will be decontaminated where needed to acceptable levels for unrestricted 

use. Hazardous wastes will be treated or disposed of in licensed hazardous waste facilities. 

Disposal of radioactive or hazardous material will not occur at the plant site, but at licensed 

facilities located elsewhere. Following decommissioning, the facilities and site will be available 

for reuse.

Financial arrangements are made to cover costs required for returning the Phase 1 portions of the 

site initial IIFP Facility to unrestricted use. Updates on cost and funding will be provided as 

described above. A detailed updated Decommissioning Plan will be submitted at a date near end 

of plant life, in accordance with 10 CFR 40.42 (CFR, 2008a).

The following describes decommissioning plans and funding arrangements. This information was 

developed in support of the decommissioning cost estimate. Specific elements of the planning 

may change with the submittal of the decommissioning plan required at the time of license 

termination.

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10.1.1 IIFP Phase 1 Facility Description

License Documentation Impact: Paragraph two in LA Section 10.1.3.1 and the first paragraph 

in Section 10.3.2 will be revised to eliminate references to a Phase 2 facility and will read 

(changes in red text) as follows:

Actual decontamination and decommissioning would follow shortly upon approval of the plan 

and the award of any subcontracts. The decommissioning plan schedule for the Phase 1IIFP

Ffacility is shown as Figure 10-1. At the time of required decommissioning, if only a Phase 1 

plant exists, then upon decommissioning and final survey and confirmation by the NRC, the 

license would be terminated and the site/facility could be released for reuse. If a Phase 2 also 

exists at the time of required decommissioning, the updated future DCF Plan for Phase 2 will 

have indentified the costs, schedule and any decontamination and decommission requirements for 

the DUF6 to oxide process beyond those already identified in the Phase 1 Plan. 

In accordance with 10 CFR 40.36(d) (CFR, 2008h), IIFP will update the decommissioning cost 

estimate for the FEP/DUP, and the associated funding levels, over the life of the facility. Updates 

will take into account changes resulting from inflation or site-specific factors, such as changes in 

facility conditions or expected decommissioning procedures. Funding level updates will also 

address anticipated operation of Phase 2 portions of the facility prior to introducing nuclear 

materials into that equipment.

License Documentation Impact: Table 7-3 of the IIFP License Application will be revised to 

delete the subtitle “Phase 1” from the second row of the Table. The remaining Table data are for 

the IIFP Facility that is described in the current licensing activities and License Application. 

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General Information 

GI-6 

B. LA Sections 1.1.2.1 and 1.1.2.2 and Table 1-2 provide a description of each of the major 

buildings at the facility. However, buildings which process uranium (listed in Table 1-2 in 

bold text) are grouped and described in general terms, while other major buildings, e.g., 

decontamination building, fire pump house, etc. are described individually, building by 

building. Consistent with the requirements in NUREG-1520, Section 1.1.4.3 (2), provide a 

description of the processes conducted in the processing of uranium, building by building, 

similar to the other major buildings listed in Section 1.1.2.2. Ensure that the description is 

presented in a manner that facilitates an understanding of the flow of material through the 

process. 

RESPONSE: The process buildings and their type of construction were described in LA Section 

1.1.2.1 mainly as a group as we viewed the LA Chapter 1, “General Information” as more 

introductory to the License Application. We described the “Other Major Buildings” in more detail 

in Section 1.1.2.2 originally in order to differentiate their type of construction and individual 

functions in support of the process building group. The Section 1.1.2.1 is being revised, as shown 

below, to include individual process building descriptions and in a manner that will describe the 

basics of flow of material through the processes that are later described in the Section 1.1.3 of the 

LA Chapter 1, “General Information”. 

License Documentation Impact: Starting at Paragraph four of Section 1.1.2 the Section is being 

revised to move and update the Table 1-2. Additional wording and a list have been added to the 

end of paragraph seven in response to RAI EP-2(black text is original and red text is change) to 

read as follows: 

The process equipment is located within building structures, where feasible. Process buildings 

that function as product and waste material storage have separate areas for each purpose. Those 

areas have loading/unloading docks to facilitate shipping. 

Process buildings have aprons, curbing and dikes and external pads have curbing and dikes where 

chemicals are stored or handled. Pumps are provided on pads and in building selected areas to 

transfer chemicals to containers or to the Environmental Protection Process (EPP) in event of a 

spill or leak. 

Auxiliary buildings generally house: 

• Materials; 

• Maintenance shop; 

• Laboratory equipment; 

• Steam boilers and supporting utilities; 

• Electrical utility equipment; 

• Sanitary water treatment, certain equipment for process water treatment and recycle, and 

• Accommodation for personnel work, break-rooms, change-rooms, and toilets. 

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 

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Protection Association (NFPA) standards, local and State codes, and related codes and standards.

NFPA Standards are listed in Table 7-1. The primary applicable codes and standards (editions 

applicable at time of design) for the design and building requirements of the IIFP Facility include 

the following: 

• Uniform Plumbing Code (UPC) as amended by the New Mexico Plumbing Code 

(NMPC). 

• International Energy Conservation Code (IECC) as amended by the New Mexico Energy 

Conservation Code (NMECC). 

• Uniform Mechanical Code (UMC) as amended by the New Mexico Mechanical Code 

(NMMC). 

• International Building Code (IBC) as amended by the New Mexico Commercial Building 

Code (NMCBC). 

• National Electrical Code (NEC) as amended by the New Mexico Electrical Code 

(NMEC). 

• International Fire Code (IFC). 

• ASME/ANSI B16 Standard for Pipe and Fittings. 

• ASME/ANSI B31 Pressure Piping (includes, power piping, process piping, gas piping, 

etc.). 

• ASME Section VIII, Div 1 Design and Fabrication of Pressure Vessels. Latest Edition. 

• API 620 Design and Fabrication of Atmospheric Storage Tanks. 

• AISC Standards for Steel Construction. 

• ASTM Standards for Steel Building Construction. 

• ACI for Concrete Construction. 

A listing of the major buildings and estimated sizes is provided in Table 1-2. 

 

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Table 1-2 IIFP FEP/DUP Plant Building Sizes

BUILDING 

(Areas where uranium is processed or 

stored are marked in “bold” print”) 

DIMENSIONS (feet) APPROXIMATE 

AREA 

(square feet) 

APPROXIMATE 

VOLUME 

(cubic feet) 

 LENGTH WIDTH 

EAVE 

HEIGHT 

DUF6 Autoclave Building 90 60 40 5,400 216,000 

DUF4 Process Building 50 50 70 2,500 175,000 

DUF4 Container Storage Building 4050 40 18 1,6002,000 28,80036,000

DUF4 Container Staging Building 25 25 18 625 11,250 

Decontamination (Decon) Building 50 30 30 1,500 45,000 

FEP Process Building (SiF4 and BF3) 60 4050 6070 24003,000 144210,000 

FEP Oxide Staging Building 4050 20 30 8001,000 2430,000 

FEP Product Storage & Packaging Building 50 35 18 1,750 31,500 

AHF Staging Containment Building 40 30 30 1,200 36,000 

Fluoride Products Trailer Loading Building 90 20 20 1,800 36,000 

Maintenance & Stores Building 60 50 15 3,000 45,000 

EPP Building 40 30 18 1,200 21,600 

Lime Silo Storage Shed 20 20 8 400 3,200

Utilities Building 50 50 18 2,500 45,000 

Material Warehouse 100 50 18 5,000 90,000 

Main Switchgear Building 50 40 18 2,000 36,000 

Fire Pump House 1020 1020 15 100400 1,5006,000

Water Treatment Building 30 15 15 450 6750 

Process Offices 50 30 15 1,500 22,500 

Laboratory (Small uranium samples 

handled) 30 30 15 900 13,500 

Administrative Building 80 50 15 4,000 60,000 

Guard House 25 20 10 500 5,000 

License Documentation Impact: LA, Section 1.1.2.1 is being revised (black text is original and 

red text is change) to read as follows: 

1.1.2.1 Process Buildings and Process Areas 

General Description

The DUF6 Autoclave Building, DUF4 Process Building, DUF4 Container Storage Building, DUF4

Container Staging Building, Decontamination (Decon) Building, FEP Process Building (SiF4 and 

BF3), FEP Oxide Staging Building, FEP Product Storage & Packaging Building and the EPP 

Building are of structural steel beam and column construction with metal wall panels and with 

Class 1 metal roofs. The first floor of each building is constructed of reinforced concrete with 

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curbing to function as a containment-type barrier. Located in the northeast corner of the access 

pad and adjacent to the DUF4 Process Building, is the DUF4 Container Staging Building. This 

building is used for removing DUF4 from DUF4 shipping containers that may be received from 

suppliers and for transferring into the DUF4 hoppers located in the DUF4 Process Building. 

The AHF Staging Containment Building and the Fluoride Products Trailer Loading Building are 

constructed of reinforced concrete floor slabs with a containment-type barrier design around the 

inside perimeter. The upper sections of these buildings are of concrete or concrete block 

construction with Class 1 metal roofs. 

Radiological boundary control hand-foot monitors are strategically located at building walkway 

exits of areas where determined to be needed. Fluoride and radiological detection systems, local 

alarms and alarm notification to Controls Rooms are also strategically located in those building 

areas, where applicable. 

The process buildingsDUF4 Process Building and the FEP Process Building are multi-story 

buildings where necessary to provide requirements for equipment space and to provide elevations 

for permitting gravity flow of particulate solids through equipment and piping, where applicable.

The upper floors are configured such as to provide adequate room for equipment function and 

maintenance. The upper floor areas below the equipment and piping containing powdered 

materials are constructed of reinforced concrete with curbing and seal coatings on floor and wall 

surfaces. Other upper floor areas of the buildings are constructed of metal grating or metal 

flooring. 

Process Control Rooms are provided in the major processes, including appropriate monitoring, 

recording, alarm notification and control instrumentation. A Control Room is located in the DUF4

Process Building. The DUF6 Autoclave Building is controlled from the DUF4 Process Building. 

The FEP Process Building plant has its own process Control Room for the SiF4 and BF3

processes. The AHF Staging Containment Building and Fluoride Products Trailer Loading 

Facility Building share a Control Room. Likewise, one control area is located in the Utilities 

Building for monitoring and controlling the steam boiler system, air compressors and other utility 

supply equipment. Control room areas and electrical and instrument rooms are typically of 

concrete block construction with concrete or metal roofs. Ceiling assemblies and fire walls 

separate these areas from production areas of the facilities. Process area Control Rooms, where 

routinely occupied by workers, have environments maintained for comfort and safety. Control 

Rooms located in process areas, where uranium or hazardous chemicals are processed, stored or 

handled, have separate heating, ventilation and air conditioning (HVAC) systems. The Control 

Rooms in these areas are designed to maintain a positive pressure environment with highefficiency filtration of intake air and are provided with low pressure alarms to notify occupants 

should a loss of pressure inside a Control Room occur. 

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 1 standpipes between 

floors in all exit stairways of multi-story buildings. (NFPA, 2007). Codes followed for 

construction are the latest editions as adopted by the State of New Mexico. 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. A final Record of Codes for construction will 

be established at the time the Design and Build contractor starts the detail design. 

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Each process building/area and its relationship to respective process flows are further described 

below. 

Full DUF6 Cylinder Storage Pad

Cylinders containing solid DUF6 are received by truck from customers/suppliers in accordance 

with approved Department of Transportation shipping requirements. After following preunloading procedures for material accountability, cylinder inspection, shipping document 

verifications, and IROFS requirements related to assay and weight verification, the cylinder is 

unloaded for temporary storage at the Full DUF6 Cylinder Storage Pad. This pad is used to stage 

full DUF6 cylinders for processing. Cylinders are moved by a special cylinder hauler to the DUF6

Autoclave Building as needed for feeding of contents to the DUF6-to-DUF4 process. Protective 

anchored concrete-filled pipe bollards are installed around the perimeter of the cylinder pad in 

locations where a potential exposure to uncontrolled vehicle traffic exists. The pad is constructed 

of reinforced concrete and is approximately 175 feet wide by 200 feet long and is sized to store 

up to 60 full cylinders. The entire storage pad is curbed for storm water collection and is provided 

with underground drains connecting to the Cylinder Pad Stormwater Retention Basin located 

south of the cylinder pad. The surface and slope of the cylinder pad is designed to prevent any 

significant pooling of liquids. The pad is provided with saddles to space and support the 

cylinders. A full cylinder is placed in a saddle and never stacked. 

DUF6 Autoclave Building

The DUF6 Autoclave Building is one level and includes a large overhead area to accommodate a 

bridge crane. The building contains two containment-type autoclaves that use controlled steam to 

safely vaporize the solid DUF6 for feeding to the DUF4 process. The vaporized DUF6 flow is 

from the feed cylinder located in the autoclave through a feed header and piping to the DUF6-toDUF4 reaction vessel that is located in the DUF4 Process Building. Typically, the content of one 

DUF6 cylinder is being fed to the reaction vessel from one autoclave. The other autoclave is going 

through a cycle of unloading an emptied cylinder, reloading of a full solid-contents cylinder and 

heating the cylinder contents in preparing it to be fed to the reaction vessel. 

Also included in the DUF6 Autoclave Building are two cold boxes cooled by refrigeration 

systems and sized to contain one 48Y-type cylinder each. One cold box is used to collect DUF6

cylinder heels after cylinders have been fed out to the DUF4 process. The other cold box is the 

receiving vessel for the purge and evacuation system that serves the DUF4 process. 

Two rail mounted cylinder carts and weigh scales are provided in the autoclave area. One cart and 

scale are located between the two autoclaves, and the other cart and scale are located between the 

cold boxes. An overhead bridge crane is installed to hoist the DUF6 cylinders into and out of the 

autoclaves and cold boxes. The crane path is designed to permit lateral movement without 

traveling above an autoclave or cold box containing a DUF6 cylinder. 

Motor Control Center (MCC) and instrumentation equipment rooms are located in the east end of 

the DUF6 Autoclave Building on the first floor. 

Just west of the DUF6 Autoclave Building, a reinforced concrete pad is installed as a staging area 

for DUF6 cylinders. This pad is located at the entrance doors to the DUF6 Autoclave Building to 

provide for staging of both empty and full cylinders by the cylinder hauler to and from the 

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outdoor cylinder storage pads. Protective anchored concrete filled pipe bollards are installed 

around the staging area for protection of DUF6 cylinders from vehicular traffic. 

Empty DUF6 Cylinder Storage Pad

Approximately 150 ft east of the intersection of the East and South Roads is the Empty DUF6 

Cylinder Storage Pad. This pad is used to stage empty DUF6 cylinders in preparation for shipment 

from the facility. A security fence is installed around the entire perimeter of the cylinder pad with 

one entrance opening with clearance for the cylinder hauler to maneuver. The pad is constructed 

of reinforced concrete and is approximately 105 ft wide x 185 ft long and sized to contain up to 

40 empty cylinders. The pad is provided with saddles to space and support the cylinders. Empty 

cylinders may be double stacked if necessary.

DUF4 Process Building

The DUF4 Process Building is a five level building adjacent to the DUF6 Autoclave Building with 

a fire barrier between the two buildings. It is within this building that DUF6 is converted to DUF4

and AHF. 

The DUF6 from the DUF6 Autoclave Building flows to the DUF6 surge tank where it enters the 

top of the DUF6 to DUF4 reaction vessel. Also hydrogen gas from the hydrogen gas generator 

system, that is located outside and remote of the DUF4 Process Building, flows through control 

systems into the top of the reaction vessel. The DUF6 reacts with the hydrogen gas to form DUF4

solid particles and AHF gas. The DUF4 powder is removed from the reaction vessel by a cooling 

screw where it is transported to hoppers for temporary storage. The AHF exits the bottom of the 

reaction vessel through the cooling screw as an off-gas; passes through two sets of filters in series 

configuration; through a series of carbon-bed traps to remove any residual un-reacted DUF6 then 

through two in-series condensers where the AHF liquefies and drains into temporary storage 

tanks that are located in the AHF Staging Containment Building. The residual off-gas that passes 

through the second condenser flows through a hydrogen burner and the Plant KOH Scrubbing 

System and vent stack, all of which are located external to the DUF4 Process Building. 

The top level of the DUF4 Process Building contains the top portion of the reaction vessel and the 

DUF6 surge tank. Also on this level are the primary and secondary dust collectors and dust 

collector blower. The fourth level houses six carbon-bed traps (configured as two banks of three 

traps in series), the off-gas primary filter, and the off-gas secondary filter. The partial AHF 

condenser, total AHF condenser and the cooling screw conveyor are located on the third level. 

The second level contains the product transfer screw, vibrating screen and the top heads of the 

three DUF4 storage hoppers. The bottom outlets of the three DUF4 storage hoppers and the 

product vacuum transfer system are located on the first level. One bay is clear on all floors to be 

used to facilitate maintenance of equipment, instrumentation and piping. Just west of the DUF4

Process Building, a reinforced concrete equipment access pad is installed to provide access to 

equipment for removal from the DUF4 Building if removal of such equipment is required for 

maintenance.

DUF4 Container Staging Building

Located in the northeast corner of the access pad and adjacent to the DUF4 Process Building, is 

the DUF4 Container Staging Building. The purpose of this building is to provide equipment and 

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space for unloading, staging and emptying DUF4 containers that may have been used to 

temporarily store additional inventory of DUF4. The building may also be used to handle DUF4

that may be received from other suppliers for conversion of DUF4 to fluoride gas products. This 

building is used for removing DUF4 from storage or shipping containers and for transferring into 

the DUF4 hoppers located in the DUF4 Process Building. 

Decontamination (Decon) Building

The Decontamination Building serves as a facility with equipment to manage Low-Level 

Contaminated Waste (LLW) other than the depleted uranium oxide waste. A more detail 

explanation in the use of the Decontamination Building to manage LLW is provided in Section 

9.2.2.1, “Waste Management Procedures;” Chapter 9 of the IIFP License Application. 

The Decontamination (Decon) Building is located adjacent to, and on the north side of the DUF4

Process Building. The construction provides for a fire barrier between the Decontamination 

Building and the DUF4 Process Building. This Decon Building and its equipment is used for 

decontamination of process equipment for maintenance and removal of depleted uranium from 

decontamination wash waters or from small volumes of contaminated liquors. The Decon 

Building contains an equipment cleaning booth and hood system, primary and secondary dust 

collector system in series, holding tanks, precipitation tanks, primary and polishing filters, 

associated pumps, piping, field equipment instrumentation panels, ion exchange columns and 

associated controls and backwash systems. 

FEP Process Building

The FEP Process Building is a four level building located just east of the DUF4 Process Building. 

The SiF4 and BF3 processes that involve licensed material are housed in this building. The flow of 

process materials for both of these processes begins with DUF4 being transported from the DUF4 

Process Building to the respective DUF4 feed hoppers (bin) in the FEP Process Building. 

In the SiF4 process, the DUF4 is mixed with SiO2 and fed to the rotary calciner equipment. In the 

rotary calciner the mixture reacts to form SiF4 gas and solid particle uranium oxide. The depleted 

uranium (DU) oxide discharges the end of the rotary calciner and is temporarily stored in hoppers 

until packaged for shipment to an off-site licensed disposal facility. The SiF4 product exits the 

rotary calciner as an off-gas, flows through a set of filters configured in series flow and through 

pre-condensers for removing hydrogen fluoride (HF) impurities. The product gas then flows to 

primary and secondary cold traps where the product is collected. The residual off-gas from the 

secondary cold trap flows to the Plant KOH Scrubbing System to receive three-stage treatment 

prior to discharging to the atmosphere through the vent stack. 

In the BF3 process, the DUF4 is mixed with B2O3, fed into a pre-heater where moisture is 

removed by forming HF that leaves the pre-heater as a vapor and flows to the Plant KOH 

Scrubbing System. The mixed solids discharge the pre-heater into a rotary calciner where the BF3

product gas and uranium oxide are produced. The depleted uranium oxide discharges the rotary 

calciner to temporary storage hoppers until packaged for shipment to an off-site licensed disposal 

facility. The BF3 product gas flows from the rotary calciner through two in-series filters, through 

pre-condensers for HF impurity removal, and then is collected in primary and secondary cold 

traps. The off-gas that exits the secondary cold trap flows to the Plant KOH Scrubbing System for 

three-stage treatment prior to discharging to the atmosphere through the vent stack. 

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The top level of the FEP Building supports the product cold traps, the pre-condensers, secondary 

filters, primary and secondary dust collectors, and dust collector blower. The third level houses 

the primary filters, the SiO2 and B2O3 feed hoppers, DUF4 feed hopper, the dust collector fines 

hopper, the ribbon blender, the feed conveyors, and the pre-heater (for the BF3 process only). The 

second level contains the rotary calciners for the SiF4 and BF3 processes. The cooling screws 

associated with the rotating calciner discharges are also on the second level. The oxide hoppers 

and the drum-off stations are located on the first level. Also located on the first level are the FEP 

Control Room, as described above, and the electrical equipment room. 

The largest amount of solid waste generated at the IIFP Facility is the depleted uranium oxide that 

is a byproduct of the FEP process. This waste is managed using the equipment and facilities of 

the FEP Process Building and the FEP Oxide Staging Building. The use of these buildings and 

associated equipment in managing this oxide waste is described in Section 9.2.2.1, “Waste 

Management Procedures;” Chapter 9 of the IIFP License Application. 

FEP Oxide Staging Building

The FEP Oxide Staging Building is adjacent to, and on the east side of the FEP Process Building. 

The wall between the FEP Oxide Staging Building and the FEP Process Building is a fire barrier. 

This building is a two level building with a reinforced concrete floor on the first level with 

containment-type curbing. It is used for staging of oxide waste containers for loading into truck 

trailers and transporting to an off-site licensed waste disposal facility. Equipment in the building 

consists of enclosed container-loading stations, weighing equipment, electrical and 

instrumentation monitoring and alarm panels and controls, exhaust hood systems, piping and 

ductwork connections to the primary dust collector system. 

DUF4 Container Storage Building 

Just east of, and adjacent to, the FEP Oxide Staging Building is the DUF4 Container Storage 

Building. This building is used to store additional inventory of DUF4 or shipping containers of 

DUF4 that may be received from suppliers. This source of DUF4 can be used in production of 

FEP products and/or de-converted to depleted uranium oxide. 

FEP Product Storage and Packaging Building

The FEP Product Storage and Packaging Building is separated from, and located at the south side 

of the FEP Process Building. In this building, the purified SiF4 and BF3 products, which are 

chemically and physically separated from licensed material, are received for temporary storage 

and packaging. When a product cold trap in the FEP Process Building is ready to be unloaded, the 

respective product compressor and evaporator in the FEP Product Storage and Packaging 

Building is used to transfer the product to storage tubes in this building. The building contains 

two levels and has a reinforced concrete floor on the first level with containment-type curbing. 

The equipment in this building is used transfer product from temporary storage tubes to truck 

tube-trailers located in the Fluoride Products Trailer Loading Building or to package and store 

SiF4 and BF3 product gas in cylinders for shipment to customers. This building houses the FEP 

compressors and associated coolers, product evaporator vessels, storage systems, containmenttype enclosures containing the packaging manifolds, and the exhaust hoods and ductwork that 

connect to an emergency scrubber. The FEP product gas storage system consists of 12-in. 

diameter by 30 ft long, high pressure, ASME coded and stamped storage tubes inside a common 

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cooling area. Approximately 30 FEP product storage tubes that are configured in banks of five are 

provided, including the spare tubes. 

FEP Building Dock 

An elevated dock on the southeast side of the FEP Process Building provides access for truck 

loading for transporting oxide containers to licensed waste disposal facilities and for truck 

loading for shipping SiF4 and BF3 cylinders to customers. 

Plant Potassium Hydroxide (KOH) Scrubbing System

A KOH liquid scrubbing system is used to remove residual fluorides from each process off-gas 

prior to venting the off-gas flows to the atmosphere. This Plant KOH Scrubbing System vents 

treated gases through a single stack. The system is utilized to treat final off-gas streams from the 

DUF4 production process (DUF6 to DUF4) and the SiF4 and BF3 processes. The off-gas streams 

flow first through a concurrent-venturi where the gas contacts aqueous KOH solution and then 

flow is through a counter-current flow pack tower where further scrubbing with aqueous KOH 

solution occurs. Final scrubbing of the gas is achieved by flow through a bed of sized coke in 

contact with a counter-current flow of aqueous KOH solution, where the treated gas is then 

discharged through a vent stack to the atmosphere. The Plant KOH Scrubbing System stack is 

monitored to measure for traces of fluorides or uranium in the vent gas. 

The spent liquors resulting from scrubbing the fluorides contain mainly potassium fluoride, water 

and some un-reacted KOH. The spent liquors are sent to the Environmental Protection Process 

(EPP) Building to regenerate the KOH liquid for recycle back to the scrubbing system. 

The KOH venturi-type (primary), packed tower (secondary), and coke box (tertiary) scrubbers 

and pumps; KOH tanks and associated equipment; and dike pad that serve the DUF4 process are 

located outside and adjacent to the east side of the DUF4 Process Building. The system consists of 

two similar lines of three-stage in-series scrubbers. 

The primary scrubber equipment (venturi-type) for the FEP process is located outside and on the 

west side of the FEP Process Building, with the venturi off-gas vents connected by piping to the 

packed towers of the scrubber system that serves the DUF4 process. This configuration provides 

secondary and tertiary treatment of the final effluents from the FEP processes prior to venting to 

the atmosphere. 

Environmental Protection Process Building

The Environmental Protection Process (EPP) Building is located east of the DUF4 Container 

Storage Building and inside the EPP process dike area. The building equipment is used to treat 

fluoride bearing liquors for recycle and reuse in the plant processes. In this process, lime is 

reacted with spent KOH solution that is received from the Plant KOH Scrubbing System. The 

reaction results in regeneration of KOH and formation of calcium fluoride. The solid particle 

calcium fluoride (CaF2) is filtered and dried for shipment to customers or disposal at an off-site 

licensed disposal facility. The regenerated KOH is pumped back to the Plant KOH Scrubbing 

System for reuse. 

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The building houses the EPP control systems, rotary vacuum filter, dryer feed screw, dryer, and 

discharge screw. Equipment for reacting lime with the fluoride bearing liquors includes the 

reaction tank, clarifier, pumps, regenerated KOH recycle tank, holding/feed tanks, and associated 

equipment. This equipment is located outside the EPP Building and within the process dike area. 

AHF Staging Containment and Fluoride Products Trailer Loading Buildings

The AHF Staging Containment Building and the Fluoride Products Trailer Loading Building are 

located east of the DUF4 Autoclave Building and south of the FEP Product Storage and 

Packaging Building. A fire barrier is located between the AHF Staging Containment Building and 

the Fluoride Products Trailer Loading Building, and between the FEP Product Storage and 

Packaging Building and the Fluoride Products Trailer Loading Building. A minimum number of 

sealed pipes and conduits penetrate the walls separating these buildings. Each building is 

constructed as a separate enclosed area. The buildings are not totally leak tight, but provide a 

level of secondary containment to suppress or inhibit an AHF, SiF4 or BF3 release in the event of 

a spill or leak. 

The AHF Staging Containment Building houses four (4) 8,000 pound AHF storage tanks, piping 

and controls. The Fluoride Products Trailer Loading Building is used as an enclosed area for 

loading AHF trailers and for loading SiF4 and BF3 tube trailers for shipment to customers. Vent 

lines and relief valve lines on the storage tanks and from the trailer during loading are connected 

to the Plant KOH Scrubbing System described above. 

The products are loaded from the storage tanks into approved Department of Transportation 

(DOT) tank trailers when inventories reach a level for shipment. A minimum number of product 

transfer lines from each process enter the Fluoride Products Trailer Loading Building. 

The Fluoride Products Trailer Loading Building contains a truck entrance door on one side that 

remains sealed, closed and controlled except for short periods when the trailer is moved in and 

out. Safety precautions are taken to prevent the trailer from contacting the fill line by the 

installation of physical barriers, and to prevent inadvertent movement of the trailer during loadout. 

Two positive-air-lock doors are located in each building. One air-lock in each building is an 

emergency exit to the outside. The other air-lock in each building is an exit and also an entrance 

to a separate control room, under positive pressure, where surveillance and operational controls 

for the two containment areas are managed. 

In these buildings, the SiF4, BF3and AHF products have been chemically separated from licensed 

materials. These products in these buildings are also physically separated from licensed materials, 

such as not to affect licensed materials. 

 

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License Documentation Impact: LA, Section 1.1.2.2 is being revised to remove duplicated 

descriptions that will be revised and moved to Section 1.2.2.1 above. Also, “Material Warehouse” 

description is being revised in Section 1.1.2.2 to identify its function as part of managing nonradioactive waste. The remaining text in the section will remain unchanged. 

Decontamination Building

The Decontamination Building is located adjacent to, and on the north side of the DUF4Process 

Building. The construction provides for a fire barrier between the Decontamination Building and 

the DUF4 Process Building. This building is used for decontamination of equipment for 

maintenance and removal of uranium from decontamination wash waters or from small volumes 

of contaminated liquors. The Decontamination Building contains an equipment cleaning booth 

and hood system, primary and secondary dust collector system in series, contaminated-water 

holding tanks, primary and polishing filters, associated pumps, piping, field equipment 

instrumentation panels, ion exchange columns and associated controls and backwash systems. 

DUF4 Container Storage Building

Just east of, and adjacent to, the FEP Oxide Staging Building is the DUF4 Container Storage 

Building. This building is used to store shipping containers of DUF4 that may be received from 

suppliers. This source of DUF4 can be used in production of FEP products and/or de-converted to 

depleted uranium oxide.

Material Warehouse

The Material Warehouse is located just northeast of the Process Offices/Laboratory Building. 

This warehouse is used to receive and store such items as piping components, electrical conduit, 

wiring, equipment for capital construction projects and spare parts. Small quantities of chemicals 

such as paints, oils, and cleaning agents are stored in the warehouse, but the quantities are limited 

to meet New Mexico Commercial Building Code (NMCBC) and NFPA requirements. No 

licensed, raw, or in-process materials or finished products are stored in this building. 

Part of the Material Warehouse is used for managing non-radioactive waste. This function is 

described in Section 9.2.2.1, “Waste Management Procedures;” Chapter 9 of the IIFP License 

Application. 

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General Information 

GI-6 

C. LA Section 1.1.3.2, Page 1-13, third full paragraph contains a description of the exothermic 

reaction of Depleted Uranium Hexafluoride (DUF6) to Depleted Uranium Tetrafluoride 

(DUF4) and Anhydrous Hydrogen Fluoride (AHF). Consistent with NUREG-1520, Section 

1.1.4.3 (3), specify what reacts exothermically with the DUF6. Specify where this reaction 

takes place, e.g., in the DUF4 building, and specify which building listed in LA Table 1-2 

contains the reaction vessel for this process. 

RESPONSE: The standard heat of formation (enthalpy) for hydrogen and uranium hexafluoride 

reaction to form DUF4 and AHF is considerably exothermic; approximately – 285 kilojoules/mol. 

In the DUF6 to DUF4 process, in order to ensure an efficient reaction, the reaction is initiated at 

about 300 o

F, or above, at which the reaction is exothermic and sustains an efficient reaction 

temperature. Air cooling around the reaction vessel is employed to control the reaction at set 

temperature, while insulation around the reaction vessel and electrical heating around part of the 

reaction vessel are utilized for fine control of the reaction temperature. In the DUF6 reaction 

vessel, hydrogen gas reacts with DUF6 as an exothermic reaction to produce DUF4. The DUF6

reaction vessel is located in the DUF4 Process Building. 

License Documentation Impact: Section 1.1.3.2, paragraph 6 of the IIFP License Application 

will be revised to read: 

The DUF6 cylinder is placed in a containment-type autoclave; where the contents are vaporized. 

The DUF6 vapor is then fed to a the DUF6 reaction vessel, located in the DUF4 Process Building,

where it undergoes exothermic reactsion with hydrogen gas to produce DUF4 and AHF. The 

reaction is exothermic which sustains an efficient reaction temperature. Air cooling around the 

reaction vessel is employed to control the reaction at set operating temperatures. Insulation 

around the reaction vessel and electrical heating around part of the reaction vessel are utilized for 

fine control of the reaction temperature. The DUF4 solid powder is continuously withdrawn from 

the reaction vessel bottom through a cooling screw mechanism and transferred to storage hoppers. 

A two2-stage dust collector system is provided to control and recycle DUF4 dusts dust that is 

generated by gas flows are internal to the solids handling equipment. and generated by air or gas 

flows associated with the handling equipment. The DUF4 in the storage hoppers is transferred to 

the FEP plant for use as raw material feed in producing SiF4 and BF3. 

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General Information 

GI-7 LA Pages 1-1 and 1-2 list the estimated average inventories for the major chemicals onsite and 

the limits for the agreement with the state of New Mexico. In addition, LA Section 1.3 contains 

Table 1-4 which indicates the maximum quantity of licensed material requested in the 

application. However, additional information is needed regarding the quantity of materials and 

their chemical and physical forms. Consistent with the acceptance requirements presented in 

NUREG 1.2.4.3(3), provide the following information: 

A. LA Table 1-1 lists the projected average for various chemicals used in the process. Each 

chemical is represented by a range of values. Clarify if the range of values is the minimum 

and maximum quantity. If not, describe how these ranges of values are calculated and how 

they represent an average. Add a description of the physical form (gas, powder, liquid) of 

licensed material listed in Table 1-1. 

RESPONSE: The original Table 1-1, Revision A of the IIFP License Application, “General 

Information” Section, was prepared to show the typical range of inventories used in the IIFP 

Facility processes based on the estimated variable rates of production and the facility projected 

production capacity. The word “average” is a misnomer because the typical range is not 

necessarily derived from a calculated average of material inventory. The range of inventory 

amounts does not necessarily represent the minimum/maximum values. The range is derived from 

estimates of production through-put rates, plant process capacities and additional contingencies 

relative to inventory management. 

The contingencies included in the estimate are operational and material delivery situations that 

may cause variations in the facility raw material, work-in-process and product inventories but 

would be controlled such as to not cause licensed materials possession limits to be exceeded. For 

example, the upper range of the DUF4 inventory considers that production rates for DUF4 would 

be a scenario where, the reaction vessel is operated at its optimum throughput for several 

consecutive days thereby accumulating a full inventory in the DUF4 storage hoppers. Then, it 

considers the DUF4 reaction vessel may be shutdown, perhaps for scheduling reasons or 

preventive maintenance, thus resulting in the inventory drawdown as that inventory is being fed 

as the raw material to the FEP process. This mode of operation would contribute to the DUF4

inventory being at the upper amount then decreasing to the lower amount; typical in inventory 

management for industrial manufacturing facilities, particularly chemical plants. The normal 

variability in production scheduling caused by the operational inter-dependency of the facility 

various processes makes it necessary to estimate inventories as a projected range of values. 

Some of the contingencies considered in estimating the subject range of inventories include 

unexpected changes and variations in market demand, uncertainties in shipping and transportation 

schedules, delivery lead-time variability, and abnormal outages on processes and utilities. 

In the case of “total depleted uranium”, the upper range value is the licensed possession limit. It is 

should be noted that State of New Mexico limits are agreed to at higher levels than the requested 

license possession limits for kilograms (kg) of total depleted uranium (as “U”). This difference is 

a result of the State considering that facility expansions and requests for higher possession limits 

that may occur under future and separate license requests and actions. The requested licensed 

materials possession limit for the current IIFP License Application is 750,000 kg uranium. 

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The other chemicals, that are not part of the licensed possession limit, do not have inventory 

limits, but are shown in Table 1-1 for reference to other aspects of the IIFP Facility operation. 

We are revising Table 1-1 from a projected average to a table of estimated typical range of 

inventories for the facility projected (design) production capacity. An additional table column 

(number three) will be added to provide a description of the physical form of the materials listed 

in Table 1-1. 

License Documentation Impact: The original Table 1-1 in Section 1, “General Information”, 

Revision A of the IIFP License Application is being deleted in total and a new Table 1-1 is being 

added as shown below. The original paragraphs six (also modified in response to RAI GI-2) and 

seven along with Table 1-1 will read as follows (black text is original and red text is change or 

new): 

IIFP is requesting a license authorizing up to 750,000 kilograms of depleted uranium (kg U) to be 

maintained at any one time in the facility inventory. IIFP is requesting the license authorization 

for up to 40 years and is plannings to operate the facility indefinitely and continue to renew the 

licenses as needed. IIFP also has a written agreement with the State of New Mexico on the 

maximum inventories of major chemicalsdepleted uranium oxide and total depleted uranium that 

can be maintained on site. 

Table 1-1 provides the estimated average typical range of inventories of major chemical materials 

used at the IIFP Facility and the physical forms for each material. Also shown is and the 

maximum limit on the major chemical inventories as per the IIFP agreement with the State of 

New Mexico. 

 

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Table 1-1 IIFP Facility Inventories

Material Maximum Limit Agreement 

with New Mexico1

Projected Average

 

Total Depleted Uranium 

(DUF6, DUO2 and DUF4)

2

4,851,000 lbs

(2,200,000 Kg) See Note 2

DUF6 Not Applicable 15-20 full cylinders

DUF6 in Process Not Applicable 43,000-66,000 lbs

(19,500-30,000 Kg)

DUF4 Not Applicable 140,000-300,000 lbs

(63,600-136,400 Kg)

Uranium Oxides as DUO2

2,205,000 lbs

(1,000,000 Kg)

340,000-470,000 lbs

(154,500-213,600 Kg)

HF (aqueous) Not Applicable 10,000-15,000 lbs

(4,500-6,800 Kg)

AHF Not Applicable 31,000-35,000 lbs

(14,000-15,900 Kg)

SiF4 (Packaged +

in process) Not Applicable 48,000-70,000 lbs(21,800-31,800 Kg)

BF3 (Packaged + 

in process) Not Applicable 17,000-33,000 lbs(7,800-15,000 Kg)

KOH Not Applicable 15,000-17,000 lbs

(6,800-7,700 Kg)

CaF2 Not Applicable 45,000-50,000 lbs

(20,400-22,700 Kg) 1 Memorandum of Agreement Between International Isotopes, Inc. and the New Mexico Environment Department, October 22, 

2009. 

2 Projected Averages: see individual breakdowns for DUF6 in cylinders and in process; DUF4 and DUO2. Maximum limits of 

Total Depleted Uranium include limits for DUF6 in cylinders and in process; DUF4 and DUO2.

 

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Table 1-1 IIFP Facility Inventories of Major Chemicals

Material

Maximum Limit 

Agreement with New 

Mexico1

Physical Form: Liquid(l), 

Solid or Powder(s), Vapor 

or Gas(g)

Typical Range of 

Inventory Based on 

Projected Production 

Capacity and 

Requirements 

(kg)

Total Depleted 

Uranium as “U” 

4,851,000 lbs 

(2,200,000 Kg) l, s, g 678,200-1,653,750 (307,575-750,000) 

DUF6 Not Applicable (NA) l, s, g 275,600-1,105,000 

(125,000-501,200) 

DUF4 NA s 363,500-515,000 

(164,900-233,600) 

Uranium Oxides as 

DUO2

2,205,000 lbs 

(1,000,000 Kg) s 350,000-525,000 (158,700-238,100) 

Hydrofluoric Acid 

(Hydrogen Fluoride) NA l, g 31,000-80,000 (14,100-36,300) 

SiF4 (Packaged + in 

process) NA s, g 8,000-14,400 (3,600-6,500) 

BF3 (Packaged +in 

process) NA s, g 7,200-54,800 (3,300-24,900) 

KOH NA l 14,000-54,000 

(6,300-24,600 Kg) 

CaF2 NA s 2,400-80,500 lbs 

(1,100-36,500 Kg) 

Ca(OH)2 NA s 25,000-100,000 

(11,300-45,300) 1 Memorandum of Agreement of International Isotopes, Inc. and the New Mexico Environment Department, October 22, 2009. 

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General Information 

GI-7 

B. Section 2.4.1 of the ISA, first paragraph, indicates that the DUF6 is vaporized via steam. State 

whether the DUF6 will be sublimed or passed through a liquid phase, and indicate the location 

and maximum quantity of liquid DUF6 that will be produced throughout the facility. 

RESPONSE: Liquid DUF6 is formed only at temperatures and pressures greater than the triple 

point as shown below in the UF6 Phase Diagram. Below the triple point, solid DUF6 will change 

phase directly to DUF6 gas (vapor) by sublimation when the temperature is raised and/or the 

pressure is lowered at continuous points along the solid/gas interface line. In the IIFP DUF6 feed 

process at the process operating conditions, the DUF6 passes through a liquid phase because the 

operating pressure required to feed the DUF4 reaction vessel is greater than the triple point 

pressure of 22 pound per square inch absolute (psia). 

Pure UF6 follows its phase diagram (shown below) consistently regardless of isotopic content. 

The liquid DUF6 phase and gas (vapor) phase are in equilibrium at autoclave operating 

temperatures. The gas (vapor) phase is transferred from the cylinder to the process through a 

pigtail attached to the autoclave feed manifold with the DUF6 cylinder valve at the 12:00 o’clock 

position. 

UF6 Phase Diagram 

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The IIFP Facility maximum quantity of liquid DUF6 will be found in autoclaves at operating 

temperature. The maximum amount of liquid DUF6 expected to be in components during 

operations is approximately 56,000 pounds or about two full DUF6 cylinders at operating 

temperatures and is contained within the autoclaves. All autoclaves are housed in the DUF6

Autoclave Building. 

License Documentation Impact: Paragraph one (paragraph one becomes paragraphs one, two 

and three, following paragraphs will shift down accordingly) and former paragraph two of 

Section 2.4.1 of the IIFP Integrated Safety Analysis Summary will be revised to read as follows: 

2.4.1 DUF6 Autoclave Building 

The DUF6 Autoclave Building is one level and includes a large overhead area to accommodate a 

bridge crane. The building contains two containment-type autoclaves that use controlled steam to 

safely vaporize the solid depleted UF6 for feeding to the DUF4 Pprocess Building. As steam is 

admitted to the autoclave containing a cylinder with solid contents, the cylinder temperature rises. 

DUF6 solid begins to vaporize and the vapor pressure in the cylinder increases until the solidliquid-vapor triple point is reached at about 22 pound per square inch absolute (psia). At the triple 

point the solid begins to melt forming liquid in addition to the solid and vapor physical states. 

There is essentially no further increase in pressure or temperature of the DUF6 in the cylinder 

until the solid DUF6 is melted to liquid, i.e., virtually all of the heat absorbed by the cylinder 

contents is used to melt the DUF6 solid. After the solid is melted, the continuation of heating 

evaporates liquid DUF6 and increases both the temperature and pressure in the cylinder along the 

UF6 vapor pressure curve. When the DUF6 in the cylinder reaches the temperature of the steam in 

the autoclave, there is no further increase in either temperature or pressure. When the cylinder 

reaches the desired operating (feed) pressure, the cylinder and feed header piping valves are 

opened to provide feed to the DUF4 reaction vessel. The liquid DUF6 phase and vapor phase are 

in equilibrium at autoclave operating temperature (approximately 220 oF-235 oF). The vapor is 

transferred to the process through a pigtail attached to the autoclave feed manifold with the DUF6

cylinder valve at the 12:00 o’clock position. Further discussion of vaporizing and feeding DUF6 is 

provided in Section 3.1.2.3 of the IIFP ISA Summary. Safety controls relative to steam, pressure, 

and temperature for the autoclave system that are Items Relied on For Safety (IROFS) are 

identified in Table 6-1 of the ISA Summary. 

The IIFP Facility maximum quantity of liquid DUF6 will be found in the cylinders inside the 

containment-type autoclaves at operating temperature. The maximum liquid DUF6 in inventory 

for the IIFP at any one time for the IIFP Facility being licensed is approximately 56,000 pounds 

or about two full DUF6 cylinders at operating temperatures. 

Also included are two cold boxes cooled by refrigeration systems and sized to contain one 48Ytype cylinder each. One cold box is used to collect DUF6 cylinder heels after cylinders have been 

fed out to the DUF4 process. The other cold box is the receiving vessel for the purge and 

evacuation system that serves the DUF4 process. 

Two rail mounted cylinder carts and weigh scales are provided in the autoclave area. One cart and 

scale are located between the two autoclaves, and the other cart and scale are located between the 

cold boxes. An overhead bridge crane is installed to hoist the DUF6 cylinders into and out of the 

autoclaves and hot cold boxes. The crane path is defined to permit lateral movement without 

traveling above an autoclave or cold box containing a DUF6 cylinder. 

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General Information 

GI-7 

C. Each 48Y cylinder can contain as much as 22 kg (IAEA-TECDOC-750 “Interim guidance for 

the safe transport of reprocessed uranium,” pg 55) of heal. Address whether Technetium-99 

and transuranics will be present in the cylinder tails from previous operations. 

RESPONSE: The IIFP facility in Hobbs, New Mexico receives depleted uranium hexafluoride 

(DUF6) in a solid physical state contained in 14-ton type 48-Y (or 48-G) cylinders typically 

owned by the supplier (IIFP toll de-conversion customer). IIFP will contract with commercial 

enrichment plant suppliers (customers) who have requirements and licenses for their facilities to 

receive and process UF6 that has resulted from natural uranium feed that at a minimum, meets or 

exceeds the definition of commercial natural UF6 for enrichment with the requirements of 

American Society of Testing and Materials (ASTM) C787-03, "Standard Specification for 

Uranium Hexafluoride for Enrichment" (ASTM, 2003). 

Under the current IIFP License Application and commitments, it is highly unlikely that IIFP 

would receive DUF6 cylinders that contain technetium (Tc) or transuranics (TRU). IIFP is not 

requesting a possession license to receive DUF6 tails from facilities that enrich reprocessed 

uranium. Also with the current license request and the technology described in the current 

License Application, IIFP will not receive DUF6 tails from the Department of Energy (DOE) 

stockpile; for the reasons discussed below. IIFP will assure these requirements are met through 

contractual arrangement, technical specifications, terms and conditions of the contract and 

auditing of the enrichment facility license. If IIFP in the future has the opportunity for receiving 

and processing (de-conversion) of DOE stockpiled DUF6 and determines it to be feasible, then 

IIFP will prepare and submit a separate licensing amendment and action. 

It is important to understand, under the current licensing request, why receipt of Tc or TRU in 

DUF6 by IIFP for de-conversion would be highly unlikely. The following summary of the 

credible technical studies by government national laboratories and the DOE helps explain the 

basis for this determination. 

Studies conducted at Oak Ridge National Laboratory and results of a peer review by Lawrence 

Livermore National Laboratory state that “the only plausible pathway for TRU and technetium to 

end up in the depleted UF6 cylinders is by way of heels from prior use of the cylinders to store 

reactor return feed.” (“Strategy for Characterizing Transuranics and Technetium Contamination 

in Depleted UF6 Cylinders”, Oak Ridge National Laboratory, J.R. Hightower, et al, October 2000 

and “A Peer Review of the Strategy for Characterizing Transuranics and Technetium 

Contamination in Depleted Uranium Hexafluoride Tails Cylinder”, Lawrence Livermore National 

Laboratory, G.P. Brumbaurgh, et al, September 1, 2000). 

The Department of Energy (DOE) in preparing their Environmental Impact Statement for the 

DOE De-conversion facilities built at their Paducah, Kentucky and Portsmouth, Ohio sites, 

commissioned the Oak Ridge National Laboratory and Lawrence Livermore Laboratory to 

conduct the studies referenced above. DOE knew that because reprocessed uranium was enriched 

in the early years of the government owned gaseous diffusion plants that some of the DOE 

stockpile of depleted UF6 (DUF6) was possibly contaminated with small amounts of technetium 

(Tc) and transuranic (TRU) elements plutonium (Pu), neptunium (Np) and americium (Am). 

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Appendix B of the Portsmouth DUF6 Conversion Final EIS (can be found on the DOE website) 

thoroughly addresses and explains the basis for the Oak Ridge National Laboratory study and 

conclusions and the extent of Tc and TRU contamination in DOE DUF6 cylinders. 

The following excerpt is from the referenced DOE Portsmouth EIS: 

“B.1.3 Extent of Transuranic and Technetium Contamination in the DUF6 (referring to DOE) 

Cylinders” 

“Both the ORNL team and the peer review team reviewed the previous characterization 

studies conducted on the tails cylinders. The ORNL team also interviewed some staff members 

who worked at the Portsmouth and Paducah Gaseous Diffusion Plant sites when the recycled 

uranium was being fed to the cascades. On the basis of those reviews and the characterization 

performed in the period December 1999 to August 2000, it was concluded that the level of 

contamination in the tails cylinders is very limited. The peer review team stated that the only 

plausible pathway for the TRU and Tc to get into the DUF6 cylinders was by way of the heels from 

prior use of the cylinders to store reactor return feed. It was discovered during the investigations 

that some cylinders that were used to store reprocessed UF6 were emptied into the cascades for 

reenriching the UF6. The same cylinders were later filled with DUF6 without first being cleaned. 

The TRU contamination in the feed cylinders consisted mainly of nonvolatile fluorides. Therefore, 

they were concentrated in the heels of the feed cylinders. Any TRU isotopes that were carried into 

the cascades were thought to have plated out and been captured in 

the cascades; thus, they never made it into the tails cylinders. Similarly, nonvolatile compounds of 

Tc stayed in the heels, while the volatile components, because of their low molecular weight 

compared with UF6, moved up the cascades and either were released in the purge stream or 

stayed with the enriched product. 

The number of reprocessed uranium feed cylinders that were later used to store DUF6 

was not known, but it was estimated to be in the hundreds (Hightower et al. 2000). This number 

represents only a portion of the total of approximately 60,000 DUF6 cylinders that are used to 

store DOE’s inventory of DUF6 at the three storage sites — Portsmouth, Paducah, and East 

Tennessee Technology Park. 

It is believed that when the cylinders with contaminated heels were filled with DUF6, the 

liquid DUF6 entering the cylinder stirred the heels and caused some fraction of the contamination 

to be mixed with the DUF6. It is also possible that a small fraction of the TRU that had been 

captured in the cascades may have re-volatized during the cascade improvement projects and was 

carried into some DUF6 cylinders. Therefore, TRU and Tc could be found both in the heels and in 

the bulk of a small, but unknown, number of DUF6 cylinders in the DOE inventory.” 

Therefore, IIFP will require suppliers of cylinders that are used for depleted tails and received by 

IIFP to preclude use of cylinders that in the past have contained reprocessed UF6, unless those 

cylinders have been decontaminated and verification is made that such cylinders do not contain 

Tc and TRU contaminants. Suppliers of DUF6 to IIFP will be required to provide written 

evidence as to the origin of the cylinders that are filled with DUF6 and shipped to the IIFP 

Facility. Also, periodic audits of suppliers will be performed to provide assurance that these 

requirements are satisfied. 

License Documentation Impact: Additional paragraphs will be added to Section 1.4 (also 

revised in response to RAI GI-2) of the IIFP License Application (LA) to address the Tc and 

TRU question. Also, Section 1.3 and Table 1-4(see also RAI GI 7-D for further revisions) of the 

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License Application will be revised to add a small amount of natural uranium for use in 

laboratory standards and methods. Additionally, in the next LA revision, the new references 

shown in the text will be added to the respective LA chapter reference page. The following 

revisions (changes in red text) will be made to Sections 1.3 and 1.4 of the LA. 

1.3 Type, Quantity, and Form of Licensed Material 

IIFP proposes to acquire, deliver, receive, possess, produce, use, transfer, and/or store source 

material meeting the criteria of Source Material as described in 10 CFR 40.4, “Definitions”

(CFR, 2008a). Details of the source material are provided in Table 1-4, “Type, Quantity, and 

Form of Licensed Source Material.” Also It it is anticipated that some license materials may be 

used for instrument calibrations. As those needs are identified during the detailed design phase, 

IIFP will prepare a license amendment as needed. A small amount of natural uranium for use in 

laboratory standards and methods is included in the licensed material request. 

Table 1-4 Type, Quantity, and Form of Licensed Source Material 

Source Material Physical and Chemical Form Maximum Amount by this 

Licensed Material to be 

Possessed at any One Time 

Depleted uUranium 

(depleted) and daughters

products

Physical: solid, liquid, and gas 

Chemical: UF6, UF4, UO2F2, 

uranium oxides, and other trace 

compounds 

750,000 Kilograms as uranium 

Natural uranium and 

daughters 

Physical: solid, liquid, and gas 

Chemical: UF6, UF4, , uranium 

oxides, and other trace compounds 

50 Kilograms as uranium 

Any byproduct material with 

atomic numbers 1 through 83 

and any source material 

Sealed Source *Not to exceed 10.0 mCi per 

source, and 1.0 Ci total 

*millicuries (mCi) and curie (Ci) 

1.4 Requested Licenses and Authorized Uses 

The Source Material license for the material described in Table 1-4 of Section 1.3 above is 

requested to be authorized for up to 40 years. IIFP plans to operate the facility indefinitely and 

continue to renew the license as needed. 

IIFP will not store or process Special Nuclear Material (SNM) at the FEP/DUP facility. 

Therefore, no licenses and authorized uses for SNM are requested. SNM is defined in 10 CFR 

70.4, “Definitions,” (2008d). 

IIFP will contract with commercial enrichment plant suppliers (customers) who have 

requirements and licenses for their facilities to receive and process UF6 that has resulted from 

natural uranium feed. Under the current IIFP License Application and commitments, it is highly 

unlikely that IIFP would receive DUF6 cylinders that contain technetium (Tc) or transuranics 

(TRU). IIFP is not requesting a possession license to receive DUF6 tails from facilities that enrich 

reprocessed uranium. Also with the current license request and the technology described in the 

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current License Application, IIFP will not receive DUF6 cylinders from the Department of Energy 

(DOE) stockpile for reasons discussed in the DOE “Portsmouth DUF6 Conversion Final EIS, 

Appendix B” (DOE, 2000). IIFP will assure these requirements are met through contractual 

arrangement, technical specifications, terms and conditions of the contract and auditing of the 

commercial enrichment facility license. If IIFP in the future has the opportunity for receiving and 

processing (de-conversion) cylinders from the DOE DUF6 stockpile and determines it to be 

feasible, then IIFP will prepare and submit a separate licensing amendment and action. 

Studies conducted at Oak Ridge National Laboratory and results of a peer review by Lawrence 

Livermore National Laboratory state that “the only plausible pathway for TRU and technetium to 

end up in the depleted UF6 cylinders is by way of heels from prior use of the cylinders to store 

reactor return feed.” (“Strategy for Characterizing Transuranics and Technetium Contamination 

in Depleted UF6 Cylinders”, Oak Ridge National Laboratory, J.R. Hightower, et al, October 2000 

and “A Peer Review of the Strategy for Characterizing Transuranics and Technetium 

Contamination in Depleted Uranium Hexafluoride Tails Cylinder”, Lawrence Livermore National 

Laboratory, G.P. Brumbaurgh, et al, September 1, 2000). 

Therefore, IIFP will require suppliers of cylinders that are used for depleted tails and received by 

IIFP to preclude use of cylinders that in the past have contained reprocessed UF6, unless those 

cylinders have been decontaminated and verification is made that such cylinders do not contain 

Tc and TRU contaminants. Suppliers of DUF6 to IIFP will be required to provide written 

evidence as to the origin of the cylinders that are filled with DUF6 and shipped to the IIFP 

Facility. Also, periodic audits of suppliers will be performed to provide assurance that these 

requirements are satisfied. 

License Documentation Impact: The following revisions (changes in red text) will be made in 

Section 3.1.2.2 of the IIFP Integrated Safety Analysis (ISA) Summary. 

3.1.2.2 Receipt of Depleted Uranium Hexafluoride (DUF6) 

The IIFP Ffacility in Hobbs, New Mexico receives DUF6 materials in a solid physical state, 

typically contained in 14-ton type 48-Y cylinders owned by the supplier (the IIFP de-conversion 

customer). These cylinders are built to American National Standards Institute (ANSI) standards 

(ANSI, 2001) and are transported by truck trailers that are Department of Transportation (DOT) 

approved. The type 48-Y cylinders are approved for multi-shipments, provided the ANSI 

standards, which include a 5-year hydrostatic test requirement, are met. Empty cylinders are 

returned to the supplier/customer following de-conversion. 

The type 48-G cylinders are typically used for on-site storage of DUF6 but have been utilized for 

in the past by the U.S. government for transport. by the Department of Energy. Under the current 

IIFP license request, cylinders of DUF6 from the U.S. Department of Energy stockpile will not be 

received. 

Shipment of the type 48-G cylinders to the IIFP Ffacility may require the supplier/customer to 

obtain a DOT Special Permit. The type 48-G cylinders are a one-time use cylinder. Disposition of 

the empty cylinder would require the complete removal of DUF6. One option under 

consideration would be to qualify the empty 48-Y G cylinders as Industrial Packages (IP) and 

utilize them as a DU oxide transport and disposal container. 

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Upon receipt, full cylinders of DUF6 are visually inspected for damage and surveyed for radiation 

and removable contamination. Documents that contain information regarding cylinder 

identification, weight, and uranium assay that accompany the shipment are reviewed and verified 

for accuracy. Uranium assay is qualitatively verified by performing a non-destructive gamma 

survey measurement. Once accepted for receipt, the cylinders are unloaded using the facility 

cylinder hauler vehicle and placed in on a temporarythe Full DUF6 Cylinder Sstorage Padyard

until it is scheduled for feed to the de-conversion process. 

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General Information 

GI-7 

D. Table 1-4 lists uranyl fluoride (UO2F2) as a chemical form for the process. In response to the 

RAI provide a description of where this chemical form occurs in the process and whether or 

not it is described in Chapter 1. Provide a description in the LA of the quantity and conditions 

which result in production of UO2F2 in the licensed operation. (Note: UO2F2 is mentioned 

as occurring in air effluents, but not as a part of the process.) Clarify whether UO2F2 is 

actually part of the process or incidental due to reaction with moisture in the air. Since 

UO2F2 is soluble, indicate the quantity of UO2F2 produced, the possible exposure to staff, and 

precautions implemented to prevent inadvertent exposure. 

RESPONSE: DUO2F2 is formed by the reaction of DUF6 and moisture. Small amounts of 

DUO2F2 that are formed in the process would only be incidental to the process. Equipment and 

piping that contain DUF6 are evacuated and purged using the DUF4 Process Building Purge and 

Evacuation System prior to opening for maintenance to minimize the potential for DUO2F2

formation. Workers wear protective respiratory equipment and clothing per Radiological 

Procedures and Permits to prevent exposure to any trace or small amounts of residual DUO2F2. 

License Documentation Impact: In the IIFP LA, Section 1.3, remove UO2F2 from Table 1-4 

(modifications were made in response to RAI GI-7C) owing to it being incidental to the process 

only. 

Table 1-4 Type, Quantity, and Form of Licensed Source Material 

Source Material Physical and Chemical Form Maximum Amount by this 

Licensed Material to be 

Possessed at any One Time

Depleted uUranium

(depleted) and daughters 

products

Physical: solid, liquid, and gas 

Chemical: UF6, UF4,UO2F2,

uranium oxides, and other trace 

compounds

750,000 Kilograms as uranium

Natural uranium and 

daughters 

Physical: solid, liquid, and gas 

Chemical: UF6, UF4, , uranium 

oxides, and other trace compounds 

50 Kilograms as uranium 

Any byproduct material with 

atomic numbers 1 through 83 

and any source material

Sealed Source *Not to exceed 10.0 mCi per 

source, and 1.0 Ci total

*millicuries (mCi) and curie (Ci)

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General Information 

GI-8 Sections 1.1.1 and 1.1.2 contain site maps and a description of the site layout. The application 

distinguishes between a 40-acre plot and a 640-acre plot, but does not make a clear distinction 

between the site boundary, controlled area, and restricted area. Consistent with the requirements 

in 20.1003, 70.61(f) and the acceptance criterion in NUREG-1520, Section 1.3.4.3(1), provide the 

following information: 

In the LA and other licensing documents, define what part of the International Isotopes Fluorine 

Products (IIFP) will be the controlled area, e.g., 40-acre plot, in accordance with the definitions 

in 20.1003 “Controlled area.” Clarify in the application whether the 640-acres, excluding the 

40-acre plot, represent a buffer zone between the site boundary and the controlled area. Add a 

paragraph to the LA and other licensing documents, as appropriate, describing in general terms 

the controlled area and access controls. The ISA Summary in particular should contain 

information on the controlled area and boundary definitions [70.61(f)], including information on 

whether the 640-acres will be fenced and marked and information on whether the controlled area 

entrance will have access controls such as gates or security checkpoints. 

RESPONSE: The IIFP Facility property boundary is the 640- acres. The property boundary will 

not be fenced. The facility site “Controlled Area” will be within the approximately 40-acre 

perimeter fence but consists of areas that are not within Restricted Areas. The “Controlled Area” 

will be marked at the perimeter fence and will have access controls, gates and security 

checkpoints. Restricted Areas will be within the perimeter fence and will be further limited from 

access for the purpose of protecting individuals against undue risks from exposure to radiation 

and radioactive materials. 

The same added definitions and descriptive information being placed in the LA (as below), will 

also be incorporated into Section 2 of the ISA “Facility Description” in the next revision of the 

license application documents. 

License Documentation Impact: New paragraphs will be inserted between exiting paragraphs 1 

and 2 in Section 1.1.2 of the IIFP License Application, “General Information” and will read (new 

text is red) as follows: 

1.1.2 Facility Description 

The facility and infrastructure are typical of specialty chemical and industrial facilities. Buildings, 

in addition to the process buildings, are included for administration, laboratory, maintenance 

shop, stores inventories, security checkpoints, utilities and powerhouse, and warehousing. Figure 

1-5 shows the facility site plan and layout of the buildings, roads and major infrastructure. 

The Site Boundary and Unrestricted Area are defined below: 

• The IIFP Lea County, New Mexico property boundary is approximately 640- acres. The 

facility site is approximately 40-acres that are fenced within the 640-acre property 

boundary. The remainder of the property boundary is not fenced, but is a buffer zone 

around the 40-acre facility site. The property ownership of the buffer zone prevents other 

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industries or the public from establishing extended or permanent occupancy close to the 

40-acre facility site. 

• NRC regulation 10 CFR 20.1003 defines an unrestricted area as an area, access to which 

is neither limited nor controlled by the licensee. The area adjacent to the 40-acre facility 

site and outside the fenced area where the IIFP does not normally exercise access control 

is an Unrestricted Area. This area can be accessed by members of the public, indigenous 

wildlife, or by facility personnel. The Unrestricted Area is governed by the limits in 10 

CFR 20.1301. The total effective dose equivalent to individual members of the public 

from the licensed operation may not exceed 1 milli-Sievert (mSv) or 100 millirem 

(mrem) in a year (exclusive of background radiation). The dose in any Unrestricted Area 

from external sources may not exceed 0.02 mSv (2 mrem) in any one hour. In addition to 

the NRC limit, the Environmental Protection Agency, in 40 CFR 190, imposes annual 

dose equivalent limits of 0.25 mSv (25 mrem) to the whole body, 0.75 mSv (75 mrem) to 

the thyroid, and 0.25 mSv (25 mrem) to any other organ of any member of the public as 

the result of exposures to planned discharges of radioactive materials to the general 

environment from uranium fuel cycle operations and to radiation from these operations. 

The Controlled and Restricted Areas are defined as below: 

• In 10 CFR 20.1003, the NRC defines a “Controlled Area” as an area, outside of a 

Restricted Area but inside the site boundary, access to which can be limited by the 

licensee for any reason. The NRC defines a restricted area as an area, access to which is 

limited by the licensee for the purpose of protecting individuals against undue risks from 

exposure to radiation and radioactive materials. 

• The IIFP Facility site Controlled Area is within the approximately 40-acre perimeter 

fence but consists of area that is not within Restricted Areas. The Controlled Area is 

marked at the perimeter fence and has access controls, gates and security checkpoints. 

The area of the plant within the perimeter fence but outside any Restricted Area is part of 

the Controlled Area. Facility employees and contractors have authorized access to the 

Controlled Area based on specific applicable pre-authorization procedures and training. 

• Due to the presence of the owner controlled area fence, members of the public and site 

visitors do not have direct access to this Controlled Area of the site and must be 

processed by security and authorized to enter the site. Training for access to a Controlled 

Area is provided commensurate with the radiological hazard. Site visitors may include 

delivery people, tour guests and service personnel who are temporary, transient occupants 

of the Controlled Area. Area monitoring demonstrates compliance with public exposure 

limits for such visitors. 

• Examples of Restricted Areas include staging/storage areas for DUF6, DUF4 and depleted 

uranium oxide, and the DUF4 Process Building. Personnel who have not been trained in 

radiation protection procedures are not allowed to access a Restricted Area without escort 

by trained personnel. 

• All personnel are required to monitor themselves prior to exiting Restricted Areas that 

have the potential for contamination, using monitoring instruments that detect 

contamination. 

• Access control to Restricted Areas and some of the type of areas that may exist within 

Restricted Areas are discussed in the IIFP License Application Section 4.7.15, “Access 

Control.” These areas may be temporary or permanent. The areas are posted to inform 

workers of the potential hazard in the area and to help prevent the spread of 

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contamination. These areas are conspicuously posted in accordance with the requirements 

of 10 CFR 20.1902. 

The 40-acre facility site is surrounded by security fence with a surveillance road just inside the 

fence. Pole mounted security lighting is installed around the perimeter of the security fence. 

The entrance to the facility is from the west via a paved road (approximately 3/4 mile) that 

intersects with NM 483. The road connects with the plant road system at the main gate and guard 

station. 

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General Information 

GI-9 Sections 1.6.2.1-1.6.2.3 provide information on the local demographics. Consistent with the 

acceptance criteria in NUREG 1.3.4.3 (2), provide the following information: 

A. LA Section 1.6.2.1 provides the population of Gaines and Andrews Counties. However, the 

population of Lea County is not provided. Provide the latest census numbers for the 

population of Lea County. 

Response: The License Application Section, former 1.6.2.1 - new Section 1.7.2.1 (in response to 

RAI RP-13) will be revised to include the population of Lea County along with the latest 

population estimates for the three counties. 

License Documentation Impact: The License Application former Section 1.6.2.1 - new Section 

1.7.2.1 will be revised as follows: 

1.6.2.1 Latest Census Results1.7.2.1 Latest Census Results 

According to the U. S. Census Bureau, the population of Lea County was 55,511 in 2000 with a 

population density of 4.9 people per square kilometer. the The population of Andrews County 

was 13,004 in 2000 with a population density of 3.3 people per square kilometer (see IIFP ER). 

Its population experienced a similar growth/decline pattern as that of Lea County. The population 

of Gaines County in 2000 was 14,467 with a population density of 3.7 people per square 

kilometer. Unlike in Andrews County, the population of Gaines County was relatively stable 

during the 1990’s. The total population of the three principal counties in the region of influence 

was nearly 83,000 in 2000. The area did not experience the population increase that occurred in 

other areas of New Mexico and Texas. The latest U.S. Census Bureau estimates for 2008 as 

reported in the ER (IIFP, 2009b) were 59,155 for Lea County, 13,645 for Andrews County, and 

15,081 for Gaines County.

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General Information 

GI-9 

B. Section 1.6.2.1 provides the population density per kilometer for Andrews County. For 

consistency, provide the population density for Gaines and Lea Counties also. 

RESPONSE: Former Section 1.6.2.1 - new 1.7.2.1 (in response to RAI RP-13) will be revised to 

include the population density for Gaines and Lea Counties. 

License Documentation Impact: Former Section 1.6.2.1 – new Section 1.7.2.1 of the License 

Application will be revised as shown in the License Documentation Impact for RAI GI-9A. 

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General Information 

GI-9 

C. LA Section 1.6.2.3 contains information on schools. This information appears to have 

discrepancies with the data in the ER in the first full paragraph above Table 3-52. Correct 

any discrepancies and provide the location and capacity of the nearest hospitals. Provide a 

sentence indicating where the nearest pre-schools, day cares, and nursing homes are located. 

(Note: Some of this information exists in the ER. This information may be referenced rather 

than repeated in the LA, if desired.) 

Response: License Application former Section 1.6.2.3 – new Section 1.7.23 (in response to RAI 

RP-13) will be revised to reflect the correct number of educational institutions in Hobbs, NM. 

The section will also be revised to address nearest pre-schools, daycares, and nursing homes. 

License Documentation Impact: License Application, Revision A, Chapter 1, former Section 

1.6.2.3 –new Section 1.7.2.3, paragraph one will be revised as follows and a new paragraph two 

will be inserted and the former paragraph two will shift accordingly. 

Urban development is relatively sparse in the vicinity of the proposed IIFP site. The nearest city, 

Hobbs, New Mexico, is approximately 22.5 m (14 mi) to the east. Within Hobbs, New Mexico, 

several educational institutions are available for the education of personnel in the local 

community. There are three colleges including a community vocational junior college, a high 

school and an alternative high school, three junior high middle schools, and eleventwelve

elementary schools as well as two private schools. 

There are fourteen nursing homes or senior living facilities in Hobbs. There are 21 daycare 

providers and preschool centers in Hobbs. 

As mentioned above, there are no state or federal parks are located within five (5) miles of the 

IIFP site. 

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General Information 

GI-9 

D. Emergency Plan, Section 3.0 lists four facilities within a five-mile radius. The LA 

Section 1.6.2.4 only lists one of these facilities. Add the other three facilities listed in 

Emergency Plan to the LA. In the LA, provide the average number of employees who work at 

these facilities (for separate facilities and combined), and indicate how this number changes 

with each shift. 

Response: Former Section 1.6.2.4 – new Section 1.7.2.4 (in response to RAI RP-13) of the 

License Application will be revised to correct the name of the Xcel Energy Cunningham Station 

and to add the three other facilities listed in the Emergency Plan. The average number of 

employees who work at the facilities will be added as Table 1-5 to this section. 

License Documentation Impact: Section 1.6.2.4, “Near-by Industrial Facilities,” of the License 

Application will be revised as follows: 

Land around the proposed site has been mostly developed by the oil and gas industry. The lone 

nearby industrial facility is the New Mexico Power and Light Company plant on the west 

boundary (New Mexico Highway 483) of the IIFP proposed property line. Nearby industrial 

facilities are the Xcel Energy Cunningham Station plant on the west boundary (New Mexico 

Highway 483), approximately 1.6 km (1.0 mi) fromof the IIFP Site, the Xcel Energy Maddox 

Station 3.7 km (2.3 mi) to the east, the Colorado Energy Station approximately 2.4 km (1.5 mi) 

northeast of the site, and the DCP Midstream Plant 5 km (3.1 mi) southeast of the site. The 

average number of employees who work at these facilities are shown in Table 1.5. 

Table 1.5 Nearby Industrial Facilities 

Company Employees on Days Employees on Shift 

DCP Midstream Linam Ranch Plant 67 2 

Colorado Energy Station 14 3 

Xcel Energy Maddox Station 12 2 

Xcel Energy Cunningham Station 25 3 

License Documentation Impact: Former Section 1.6.2.5 – new Section 1.7.2.5, “Land Use 

within a Five Mile Radius,” will be revised as follows: 

As mentioned above, the site is undeveloped and utilized for oil and gas wells. Several power 

lines and underground power lines run generally east to west and several gas pipelines run north 

and west as well as east to west. 

Surrounding property consists of vacant land, and the New Mexico Power and Light Company 

power plant on the west boundary of the IIFP proposed property line. three power companies and 

the gas processing plant mentioned above. Cattle grazing on nearby sites occur throughout the 

year. Land around the proposed site has been mostly developed by the oil and gas industry. The 

nearest residence is situated west northwesteast of the site 8.52.6 km (5.31.6 mi) from the north 

boundary. 

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General Information 

GI-10 LA Section 1.6.3, ER Section 3.6, and ISA Summary Section 1.3 contain information on the 

meteorology for the site. Some of this information contains minor typos or requires clarification. 

Consistent with the requirements in NUREG-1520, Section 1.3.4.3(3), provide the following 

information: 

A. Some of the temperatures in Table 1-6 of the LA, Table 3-17 of ER, and Table 1-2 of ISA 

Summary are reported as positive when they should be negative. In addition, some of the 

temperatures in Table 3-14 of the ER should have negatives. Review all the temperatures in 

all the tables throughout the submittals and verify that they have the correct sign. 

RESPONSE: IIFP concurs that some of the temperatures are incorrect as shown. The tables 

listed will be corrected and other tables will be reviewed for similar errors. 

License Documentation Impact: Temperatures in Table 3-14 of Revision A of the IIFP 

Environmental Report will be revised as follows: 

21.7 0

C will be revised to -21.7 0C for January 

18.9 0C will be revised to -18.9 0C for February 

-17.2 0C will be revised to -18.3 0C for December 

License Documentation Impact: Temperatures in Table 3-17 of Revision A of the IIFP 

Environmental Report will be revised as follows: 

21.7 0

C will be revised to -21.7 0C for January 

23.9 0C will be revised to -23.9 0C for February 

16.1 0C will be revised to –16.1 0C for December 

License Documentation Impact: Measurements in Table 3-18 of Revision A of the IIFP 

Environmental Report will be revised as follows: 

.025 will be changed to 0.25 for mean snowfall for October 

12.95 cm (5.1 in) will be changed to 11.93 cm (4.7 in) for the Annual mean snowfall. 

License Documentation Impact: Former Table 1-5 – new Table 1-6 (in response to RAI GI9D) of Revision A of the IIFP License Application will be deleted and replaced with revised ER 

Table 3-18 above and be numbered as Table 1-6. 

Temperatures in former Table 1-6 – new Table 1-7 (in response to RAI GI-9D) of Revision A of 

the IIFP License Application will be revised as follows: 

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21.7 0

C will be revised to -21.7 0C for January 

23.9 0C will be revised to -23.9 0C for February 

16.1 0C will be revised to –16.1 0C for December

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

Analysis Summary will be deleted and replaced with revised ER Table 3-18 above and be 

numbered as Table 1-1. 

Temperatures in Table 1-2 of Revision A of the IIFP Integrated Safety Analysis Summary will be 

revised as follows: 

21.7 0

C will be revised to -21.7 0C for January 

23.9 0C will be revised to -23.9 0C for February 

16.1 0C will be revised to –16.1 0C for December 

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General Information 

GI-10 

B. The design basis precipitation is stated at 3.5-4 inches for the 100-year timeframe in LA 

Section 1.1.5.3 and ISA Summary Section 1.3.2.8. The design basis precipitation appears to 

be based on the data in ER Table 3-21. Incorporate or reference this table in the LA and ISA 

Summary. In addition, ER Sections 3.4.11.3 and 3.4.11.4, and LA Section 1.6.3.3, and ISA 

Summary Section 1.3.2.8 indicate that the IIFP is not within the 500-year flood plain. In 

response to this RAI, provide the basis for this determination. Also, if possible, consistent 

with the 100-year data in ER Table 3-21, provide similar precipitation data for the 500-year 

flood. 

RESPONSE: Table 3-21 in the ER shows 100-year return period one-hour point precipitation 

information from NOAA Precipitation Frequency Data Server for three weather stations in the 

general vicinity of the proposed IIFP. Also, the coordinates for the IIFP site were entered into the 

NOAA Precipitation Frequency Data Server and corresponding estimates for that specific 

location were obtained. Based on this information, a 100-year one-hour precipitation event of 4.0 

inches was selected for stormwater sewer design. The selected precipitation event is greater than 

the 90% confidence upper limit values for any of these four locations. Table 3-21 will also be 

revised to include one-hour precipitation information for a 500 year return period. 

It was also 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 

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

facility was performed using Department of Energy (DOE) documents DOE-STD-1020-2002, 

DOE-STD-1022-94 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 stormwater runoff which is included in the detailed 

facility design. 

Sections 3.4.11.3 and 3.4.11.4 of the ER and section 1.6.3.3, subheading “Floods” of the LA will 

be addressed under License Documentation Impact in response to question GI-10 C below. 

License Documentation Impact: Section 1.1.5.3, subheading “Storm Sewers” of Revision A of 

the IIFP License Application will be revised as follows: 

1.1.5.3 Sewer Systems and Collection Basins 

Storm Sewers 

The IIFP Ffacility storm sewer systems design assumes a 100-year return period storm of 8.9 to 

10.2 cm (3.5 to 4-in) rain of 1-hour duration for the Hobbs, New Mexico area one-hour 

precipitation event of 4.0 inches. Information obtained from the NOAA Precipitation Frequency 

Data Server is provided in Table 3-21 of the Environmental Report for three weather stations in 

the Hobbs, NM area. These data show mean 100-year one-hour rainfalls of 3.33 to 3.40 inches 

with a maximum 90% upper confidence limit of 3.77 inches. Preliminary engineering of the 

drainage system size and layout was done to estimate costs and determine requirements and 

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information for additional detailed design later. The early design encompasses an area of the 

facility that includes the process buildings, auxiliary buildings, pads, roads, parking lot and the 

water treatment and electrical substation areas in the back acreage of the facility. All the storm 

sewer systems are inside the inner fenced area and collect rainwater runoff from an estimated 20-

25 acres including roadways, building roofs and pads. 

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

RAI GI-10D) of Revision A of the IIFP Integrated Safety Analysis Summary will be deleted and 

replaced with the following: 

1.3.2.81.3.2.6 Floods 

The IIFP site does not fall within 100-year or 500-year floodplains (IIFP, 2009). The site is 

located in a semi-arid location with limited 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/yr), and 

Roswell, NM (14.66 in/yr). 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. Point precipitation information for coordinates of the site location 

(32.716 degrees latitude, -103.33 degrees longitude) as presented in the NOAA Precipitation 

Frequency Data Server are 3.40 in. (with 90% CLs of 2.98 and 3.77) for a one-hour rain with an 

Average Recurrence Interval (ARI) of 100 yr. For a 500 yr ARI, the values are 4.33 in. (with 90% 

CLs of 3.74and 4.82). The same type of data for three weather stations in and around Hobbs, NM 

is very similar and is displayed in Table 3-21 of the ER. According to the Federal Emergency 

Management Agency (FEMA) Mapping Information Platform, the site lies in a FEMA Flood 

Zone D which means that floodplain mapping has not been performed for this area. 

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 Date 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 County. 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 site would be 

expected to receive some drainage from highway 483 on the west and possibly from 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 toward the east and 

south as gradual elevation declines occur in those directions for several miles. While the area 

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

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

according to information provided in the FEMA Mapping Information Platform. 

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

preliminary flood hazard assessment for the proposed IIFP facility near Hobbs, NM: DOE-STD1020-2002, DOE-STD-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 

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flood hazard assessment is not required. Preliminary screening indicates that flooding is not a 

design basis event other than in consideration of stormwater runoff which is included in the 

detailed facility design for storm sewer loading. 

Based upon the above precipitation data for the site and information presented in Table 3-21 of 

the IIFP “Environmental Report” an estimate of a 4.0 inch one-hour rainfall was used for storm 

sewer design. The facility is designed to prevent flooding from extreme precipitation of short 

duration. Structures containing SSCs are constructed above grade level and above the level of 

plant roadways. They are curbed to prevent internal spills from leaving the structure, and this 

curbing also serves as flood barriers for those structures. The terrain is contoured around the site 

to improve drainage away from or diversion around the facility. In this way, the structures are 

physically removed from potential sources of flooding. 

License Documentation Impact: Table 3-21in Section 3.6.1.3 of the IIFP Environmental 

Report, Revision A will be revised to include 500 year return period data with current updates for 

the 100-year data. 

Table 3- 21 Estimates of the 24-Hour 100-Year and 500-Year Rain Event in Hobbs, New Mexico 

Station Rainfall Frequency Estimates 

1-Hour Event (24-Hour Event) In Inches1

Mean 

(90% Confidence 

Interval) 

Lower Limit

 (90% Confidence 

Interval) 

Upper Limit

 (90% Confidence 

Interval) 

100-year 

information

Hobbs 3.35 (7.07)3.33 (7.03) 2.93 (6.21)2.91 (6.17) 3.74 (7.81)3.73 (7.76)

Hobbs FAA Airport 3.40 (6.47)3.38 (6.95) 2.99 (5.75)2.95 (6.11) 3.78 (7.10)3.76 (7.67)

Hobbs 13 W 3.41 (6.60)3.40 (6.43) 3.00 (5.82)2.98 (5.73) 3.77 (8.36)3.77 (7.04)

500-year 

information 

Hobbs 4.25 (9.27) 3.66 (7.98) 4.76 (10.26) 

Hobbs FAA Airport 4.31 (9.17) 3.71 (7.90) 4.80 (10.15) 

Hobbs 13 W 4.33 (8.47) 3.74 (7.38) 4.82 (9.31) 

Source: WRCC, 2006NOAA Precipitation Frequency Data Server 1 1 inch = 2.54 centimeters

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

Analysis Summary will be revised as follows: 

The IIFP FEP/DUP Ssite is located outside the 100-year flood-plain.; has not been mapped but 

does not lie within areas which have been mapped and are in the 100-year floodplain in and 

around Hobbs, New Mexico according to information provided in the FEMA Mapping 

Information Platform. Hhowever, a flood of any magnitude was considered credible during the 

accident analysis performed in the ISA. The likelihood of any major flood at the plant site was 

low and the consequences were limited (due to no fissile material existing at the site). Thus, flood 

type accidents are not a significant risk for plant operations. 

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General Information 

GI-10 

C. The basis quoted in ER Figure 3-27 for IIFP being outside the 100-year flood plain is based 

on data provided by the Economic Development Corporation (EDC) of Lea County, NM. In 

response to this RAI, provide a basis for the credibility of the information. Indicate if the 

EDC is qualified to develop these reports, or specify that the EDC compiled the information 

from nationally recognized sources. In addition, in the LA, ISA Summary, and ER, provide a 

basis for the statement that the IIFP is outside the 500-year flood plain. 

RESPONSE: The FEMA Mapping Information Platform was used to determine that the area 

where the IIFP site is located is in Zone D and has not been mapped. Mapping is performed on a 

priority basis. Certain areas in general vicinity of the IIFP site have been mapped and those maps 

may be seen at this same site. Areas of potential flooding are shown in and around Hobbs, NM. A 

topographic view of the area indicates that the IIFP site is 125 to 170 feet above these locations. 

The site is also approximately 125 feet higher than the Lea County Airport which is also in Zone 

D and has not been mapped. Based on this information, it is safe to say that the site is not in areas 

which have been mapped and lie within the 100-year floodplain (Zone A) in and around Hobbs, 

New Mexico and is at a higher elevation than areas which have been mapped. FEMA is the 

source of the EDC floodplain information as documented on the map provided to IIFP. The 500-

year information is not shown either in the information provided by the EDC or on maps located 

using the FEMA Mapping Information Platform. References to the 500-year floodplain have been 

removed as appropriate. 

License Documentation Impact: The source reference for the floodplain information shown in 

Section 3.4.1.1, Figure 3-27 of Revision A of the IIFP Environmental Report will be changed 

from the EDC to include provider to EDC, FEMA and USGS. 

Source: EDCLC, 2008, Drawing provided by Gordon Environmental Inc. to EDC of Lea County, Floodplain information 

 FEMA and Topographical Information: U. S. Geological Survey. 

License Documentation Impact: Section 3.4.11.3 of Revision A of the IIFP Environmental 

Report will be deleted and replaced with the following: 

3.4.11.3 Floodplain Description/Flood Control Measures 

Site grade is above the elevation of the 100-year and the 500-year flood elevations. See Figure 3-

27, “Watercourses, Floodplains, and Playas Map” for location of FEMA Zone A (areas inundated 

during 100-year flood event) northeast of the site or northwest of Hobbs, New Mexico around the 

Hobbs Industrial Air Park. The IIFP site storm system is designed to accommodate a 100-year 

return period precipitation event. No additional flood control measures are proposed for the IIFP 

facility.

Site grade is significantly above areas which have been mapped and are in the 100-year 

floodplain in and around Hobbs, New Mexico according to information provided in the FEMA 

Mapping Information Platform. These mapped areas and topographical data are displayed in 

Section 3.4.1.1, Figure 3-27, “Watercourses, Floodplains, and Playas Map” for location of FEMA 

Zone A (areas inundated during 100-year flood event). This map was provided to the Economic 

Development Council of Lea County by Gordon Environmental Inc. who references FEMA as the 

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source for floodplain information and the U. S. Geological Survey (USGS) as the source for 

topographical information. 

The IIFP site stormwater system is designed to accommodate a 100-year return period 

precipitation event. An estimate of a 4.0 inch one-hour rainfall was used for storm sewer design. 

See Section 1.3.2.6 “Floods” of the ISA. The facility is designed to prevent flooding from 

extreme precipitation of short duration. Structures containing SSCs are constructed above grade 

level and above the level of plant roadways. They are curbed to prevent internal spills from 

leaving the structure, and this curbing also serves as flood barriers for those structures. The site 

terrain is contoured to improve drainage away from or diversion around the facility. In this way, 

the structures are physically removed from potential sources of flooding. 

License Documentation Impact: Section 3.4.11.4 of Revision A of the IIFP Environmental 

Report will be deleted and replaced with the following: 

3.4.11.4 Design-Basis Flood Elevation 

Site grade is above the 500-year flood elevations. 

The IIFP site has not been mapped but does not lie within areas which have been mapped and are 

in the 100-year floodplain in and around Hobbs, New Mexico according to information provided 

in the FEMA Mapping Information Platform. Preliminary screening indicates that flooding is not 

a design basis event other than in consideration of stormwater runoff which is included in the 

detailed facility design. See section 1.3.2.6, “Floods” of the ISA. 

License Documentation Impact: Former Section 1.6.3.3 – new Section 1.7.3.3, subheading 

“Floods” (in response to RAI RP-13) of Revision A of the IIFP License Application Section will 

be deleted and replaced with the following: 

Floods

The IIFP site does not fall within 100-year or 500-year floodplains (see IIFP ER). The site is 

located in a semi-arid location with limited bodies of water.

The IIFP Site has not been mapped but does not lie within areas which have been mapped and are 

in the 100-year floodplain in and around Hobbs, New Mexico according to information provided 

in the FEMA Mapping Information Platform. Preliminary screening indicates that flooding is not 

a design basis event other than in consideration of stormwater runoff which is included in the 

detailed facility design. See section 1.3.2.6 “Floods” of the ISA. 

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General Information 

GI-10 

D. For the design basis wind strength in the ISA Summary, provide a return year period and 

maximum wind speed for both intermediated term (100-500 years) and long term (>1000 

years). Specify the basis for both the maximum wind speed and return year period for the 

information, e.g., a site-specific study, national weather service, etc. In addition, Table 3-22 

in the ER has a very limited timeframe (82-97). Justify that this limited timeframe is 

adequate for the design basis wind. Demonstrate that the wind assessments were from a 

recognized source and the method used for analyzing high-wind hazard is a commonly used 

and accepted method. 

RESPONSE: The determination of design basis wind speed has been reevaluated using a 

different methodology and under a different set of criteria than those addressed in Question GI-10 

D. A discussion of that methodology is provided in this response. 

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 10-5, 10-6, and 10-7 probability design wind speeds for the contiguous United 

States estimated using the above database and the Enhanced Fujita Scale. (NCDC, 2010b) 

The two-degree box where the INIS 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 107

 year return period or a probability of exceeding of 10-7. DOE-STD1022-2002, 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.

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Legend:  4o Box ‐ Red; 1o Box ‐ Green; 2o Box ‐ Blue

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 1 and 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 energetics is similar to 

1

10

100

1000

10000

100000

1000000

10000000

0 50 100 150 200 250 300

Straight Gust Wind Speed vs Tornado Wind Speed for 1, 2, & 4 Degree Boxes

STRAIGHT GUST WINDS

40 BOX, 10 BOX, 20 BOX

WIND SPEED (MPH)

RETURN

PERIOD

(YRS) TORNADO WINDS

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a large Category A reactor (>200MWt). It is determined that IIFP process buildings and other 

structures containing licensed material or process buildings containing processes or materials 

potentially affecting licensed materials are properly categorized as PC-3. 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-1 structures (2 x 

10-2 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-1 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 (10-2), for 

PC-3 structures is 117 mph (10-3) and for PC-4 structures is 135 mph (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 frequency of 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 10-4 (135 mph), or 2) design the facility to withstand a straight-line 

wind load of 10-3 (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 

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 IIFP 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 10-5yr-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 10-4, which is designed 

to withstand a 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 10-5 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 

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of 10-4 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: 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 Mexico are usually moderate, although relatively strong 

winds often accompany occasional frontal activity during late winter and spring months and 

sometimes occur just in advance of thunderstorms. Frontal winds may exceed 30 mile/hr for 

several hours and reach peak speeds of more than 50 mile/hr.

This section describes the basis for evaluation of wind loading on the structures at the IIFP 

Facility in Lea County, New Mexico. Three sources of wind loading are evaluated; wind loading 

from a hurricane, straight wind loading and wind loading from 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. Hurricane 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 

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

dissipated hurricanes. (NCDC, 2010a) 

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 average of 1.53 tornadoes per year. Of these 92 

tornado events for Lea County between 01/01/50 and 01/31/10, 63 - F0, 20 - F1, 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-1022-2002 including Appendix D. It was determined from this evaluation that straight 

gust wind speeds will be used as the design basis for buildings and structures at the IIFP 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-

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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 1 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 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 energetics is similar to 

a large Category A reactor (>200MWt). It was determined that IIFP process buildings and other 

structures containing licensed material or process buildings containing processes or materials 

potentially affecting licensed materials are properly categorized as PC-3. 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 “exceedance” for 

straight winds and for tornadoes for several DOE sites for Performance Categories PC-1 thru PC4 structures. The design wind speeds listed in Table 3-2 for PC-1 structures (2 x 10-2 probability 

of “exceedance”) 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-1 structures per the USGS wind speed maps is 90 mph (2 x10-2), the design wind speed per 

Table 3-2 for PC-2 structures is 96 mph (10-2), for PC-3 structures is 117 mph (10-3) and for PC-4 

structures is 135 mph (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 frequency of 10-4. 

This 10-4 performance goal is met at the IIFP facility by designing PC-3 structures using a 135 

mph straight wind gust at the 10-4 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 10-3 with a Ratio of Hazard to Performance 

Probability of 10 may be used to meet the performance goal of 10-4. 

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 10-5. Also, according to 

Appendix A of NUREG/CR-4461, Rev.2, strike probabilities for the one-degree, the two-degree 

and the four-degree boxes containing the IIFP site are 5.235 x 10-5yr-1, 8.444 x 10-5 yr-1 and 3.975 

x 10-5 yr-1 respectively. Therefore, selection of a design basis wind speed for IIFP PC-3 structures 

of 135 mph at the 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 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 

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mentioned above, those structures will meet the performance category of 10-4, and be designed to 

withstand a 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 10-5 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 10-4 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: Sections 1.3.2.6 and 1.3.2.7, of Revision A of the IIFP 

Integrated Safety Analysis Summary have been incorporated above in Section 1.3.2.3 “Extreme 

Winds” as subsections “Hurricanes” and “Tornadoes and Straight Winds”, respectively. The 

Sections will be removed in their entirety and subsequent Sections and subsections will be 

renumbered accordingly. 

1.3.2.6 Tornadoes

Tornadoes are occasionally reported in New Mexico, most frequently during afternoon and early 

evening hours from May through August. There is an average of nine tornados a year in New 

Mexico. Tornadoes occur infrequently in the vicinity of the IIFP site. Only two tornadoes were 

reported in Lea County from 1980 to 1989. Only one tornado was reported in Andrews County, 

Texas in the same period. 

1.3.2.7 Tropical Storms and Hurricanes

Hurricanes are low pressure weather systems that develop over the tropical oceans and as they 

move inward they lose their intensity quickly once they make landfall. The IIFP site is 

approximately 500 mile from the nearest coast, it is likely that any hurricane that moved in that 

direction would have downgraded to a tropical depression before it reached IIFP.

License Documentation Impact: Section 1.6.3.3, “Extreme Winds” of Revision A of the IIFP 

License Application (now Section 1.7.3.3, in response to RAI RP-13) will be revised as follows 

to include marked paragraphs: 

Extreme Winds

Wind speeds over the State of New Mexico are usually moderate, although relatively strong 

winds often accompany occasional frontal activity during late winter and spring months and 

sometimes occur just in advance of thunderstorms. Frontal winds may exceed 30 mile/hr for 

several hours and reach peak speeds of more than 50 mile/hr. 

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. 

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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. These 

structures will be designed to withstand a straight gust wind speed of 135 mph at the 10-4

probability of “exceedance” level. 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 at this design basis. 

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General Information 

GI-10 

E. Regarding the design basis threat for a tornado, provide the source of the information that 9 

tornados occur annually in New Mexico, e.g., National Oceanic and Atmospheric 

Administration. Provide the source of the information which indicates that two tornados 

occurred in Lea County. Specify the probability frequency of a tornado hitting an IIFP 

building and provide the basis for this information. Indicated if this frequency information or 

some other reason is used as a basis for not assigning Items Relied on for Safety (IROFS) for 

tornados in the ISA. 

RESPONSE: NOAA NCDC Storm Events provides data for 527 tornado events in New Mexico 

over a 60 year period for an average of 8.78 tornadoes per year. Lea County reported 92 

tornadoes for the same period for an average of 1.53 tornadoes per year. Of these 92 tornado 

events for Lea County between 01/01/50 and 01/31/10, 63 - F0, 20 - F1, 8 - F2, and one- F3 

tornadoes were reported. 

Also, according to Appendix A of NUREG/CR-4461, Rev.2, strike probabilities for the onedegree, the two-degree and the four-degree boxes containing the IIFP site are 5.235 x 10-5yr-1, 

8.444 x 10-5 yr-1 and 3.975 x 10-5 yr-1 respectively. 

The design basis wind speed for the IIFP facility is 135 mph at a 10-4 probability level. According 

to data provided in NUREG/CR-4461, Rev. 2, it is highly unlikely that a tornado with winds 

exceeding 135 mph will occur in this locale. Also, all strike probabilities for the one-degree, twodegree and four-degree boxes in Appendix A are at a less than 10-4 probability level. 

License Documentation Impact: Section 1.3.2.6 of Revision A of the IIFP Integrated Safety 

Analysis Summary will be deleted has been incorporated into Section 1.3.2.3, subheading 

“Tornadoes and Straight Winds (see RAI GI-10D). 

License Documentation Impact: Former Section 1.6.3.3, “Tornadoes” (now Section 1.7.3.3, in 

response to RAI RP-13) of Revision A of the IIFP License Application will be revised to read as 

follows: 

Tornadoes are occasionally reported in New Mexico, most frequently during afternoon and early 

evening hours from May through August. There is an average of nine tornadoes a year in New 

Mexico. Tornadoes occur infrequently in the vicinity of IIFP. Only two tornadoes were reported 

in Lea County from 1880 to 1989. Only one tornado was reported in Andrews County, Texas in 

the same period. NOAA National Climate Data Center (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 average of 1.53 tornadoes per year. Of these 92 tornado events for Lea County 

between 01/01/50 and 01/31/10, 63 - F0, 20 - F1, 8 - F2, and one- F3 tornadoes were reported. 

During this same sixty-year period, no F4 or F5 tornadoes were reported. (NCDC, 2010a)

License Documentation Impact: Paragraph three from section 3.6.1.6 of Revision A of the IIFP 

Environmental Report will be revised to read as follows: 

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Tornadoes are occasionally reported in New Mexico, most frequently during afternoon and early 

evening hours from May through August. There is an average of nine tornadoes a year in New 

Mexico. Tornadoes occur infrequently in the vicinity of IIFP. Only two tornadoes were reported 

in Lea County from 1880 to 1989. Only one tornado was reported in Andrews County, Texas in 

the same period. From NOAA National Climate Data Center (NCDC) Storm Events, it was 

determined that 527 tornado events were reported for the state of New Mexico for the period 

1950-2010 for an average of 8.78 per year. Lea County reported 92 tornadoes for the same period 

for an average of 1.53 tornadoes per year. Of the 92 tornado events between 01/01/50 and 

01/31/10, 63 - F0, 20 - F1, 8 - F2, and one- F3 tornadoes were reported in Lea County. During 

this sixty-year period, no F4 or F5 tornadoes were reported. See Figure 3-60 showing the Tornado 

Probability Map of the United States. 

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General Information 

GI-10 

F. In response to this RAI, provide information from the Process Hazards Assessment (PHA) 

which demonstrates that the Accident Analysis 101.9 from ISA Table 4-3 has a correct value 

of 10-4. Indicate whether this number is based on the probability of a tornado striking the 

facility. Add information to the description in the ISA Summary Section 1.3.2.6 which 

indicates the source of information for determining the tornado data. 

RESPONSE: According to Appendix A of NUREG/CR-4461, Rev.2, the two-degree box which 

contains the IIFP site has a strike probability of 8.444 x 10-5 yr-1. Strike probabilities for the onedegree and four-degree boxes are 5.235 x 10-5yr-1 and 3.975 x 10-5 yr-1 respectively. 

The design basis wind speed for the IIFP facility is 135 mph at a 10-4 probability level. According 

to data provided in NUREG/CR-4461, Rev. 2, it is highly unlikely that a tornado with winds 

exceeding 135 mph will occur in this locale (less than 10-5 probability). Also, all strike 

probabilities for the one-degree, two-degree and four-degree boxes in Appendix A are at a less 

than 10-4 probability level. The assignment of a likelihood index of -4 is a conservative estimate 

based upon strike probabilities of less than 1 x 10-4 but greater than 1 x 10-5. 

License Documentation Impact: Former Section 1.3.2.6 of Revision A of the IIFP Integrated 

Safety Analysis Summary will be deleted and incorporated in Section 1.3.2.3, “Tornadoes and 

Straight Winds” as shown in Response to RAI GI-10 D and GI 10-E. 

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General Information 

GI-10 

G. Considering the population density in Lea County, the record of only 2 damaging lightning 

strikes since 1950 does not provide adequate evidence of limited risk. Consistent with 

70.64(a)(2), add a statement to the LA and ISA Summary that demonstrates the proposed 

IIFP and the associated power systems are designed and built with heavy grounding or 

lightning protection to handle lightning strikes. Also, in response to the RAI, provide 

information from the PHA which demonstrates that the accident analysis for a lightning 

strike at the IIFP is low consequence, taking into account the average yearly thunderstorms. 

RESPONSE: Information taken from NOAA indicates that Lea County is in a region that has an 

average flash density of 4 to 5 flashes/km2

/yr. The conversion of this flash density to a 40 acre 

basis for the IIFP fenced area indicates that the site could expect 0.65 to 0.81 flashes per year 

(equivalently less than one flash per year). IIFP structures, equipment and associated power 

systems will be designed and built with heavy grounding and/or lightning protection to handle 

lightning strikes. 

License Documentation Impact: Section 1.6.3.3 “Lightning” of Revision A of the IIFP License 

Application (now Section 1.7.3.3, “Lightning”, in response to RAI RP-13) will be revised to read 

as follows: 

Only two lightning events having sufficient intensity to cause loss of life, injury, significant 

property damage, and/or disruption to commerce were reported in Lea County, New Mexico, 

between January 1, 1950 and April 30, 2004 (see IIFP ER). The closest lightning event occurred 

in Hobbs with minor property damage of $3,000 on August 12, 1997. The second occurred in 

Lovington on August 8, 1996, causing two deaths. 

The NOAA database indicates that Lea County is in a region that has an average flash density of 

4 to 5 flashes/km2/yr. The conversion of this flash density to a 40 acre basis for the IIFP fenced 

area indicates that the site could expect 0.65 to 0.81 flashes per year (equivalently less than one 

flash per year). IIFP structures, equipment and associated power systems will be designed and 

built with heavy grounding and/or lightning protection to handle lightning strikes. 

(http://www.lightningsafety.noaa.gov/stats/08_Vaisala_NLDN_Poster.pdf)

License Documentation Impact: Section 1.3.2.5 of Revision A of the IIFP Integrated Safety 

Analysis Summary will be revised to read as follows: 

Only two lightning events having sufficient intensity to cause loss of life, injury, significant 

property damage, and/or disruption to commerce were reported in Lea County, New Mexico, 

between January 1, 1950 and April 30, 2004 (see IIFP ER). The closest lightning event occurred 

in Hobbs with minor property damage of $3,000 on August 12, 1997. The second occurred in 

Lovington on August 8, 1996, causing two deaths. 

The NOAA database indicates that Lea County is in a region that has an average flash density of 

4 to 5 flashes/km2/yr. The conversion of this flash density to a 40 acre basis for the IIFP fenced 

area indicates that the site could expect 0.65 to 0.81 flashes per year (equivalently less than one 

flash per year). IIFP structures, equipment and associated power systems will be designed and 

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built with heavy grounding and/or lightning protection to handle lightning strikes. 

(http://www.lightningsafety.noaa.gov/stats/08_Vaisala_NLDN_Poster.pdf) 

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OFFICIAL USE ONLY – SECURITY-RELATED INFORMATION 

General Information 

GI-11 LA Sections 1.6.3.4-1.6.3.8 contain information on ground water. Consistent with the acceptance 

criteria in NUREG-1520, Section 1.3.4.3(4), provide the following information: 

A. The third full paragraph in LA Section 1.6.3.4 indicates runoff from the site will not travel to 

a river. For completeness, in this same paragraph, specify the distance to the nearest river. 

Also, modify this commitment to be consistent with the statement in ER Section 3.4.11.5 that 

“IIFP plant has no direct outfall to a surface water body.” Clarify the meaning of direct 

outfall. 

RESPONSE: The distance to the nearest river (Pecos River) from the IIFP facility site is 

approximately 50 miles. This information along with the referenced statement in ER Section 

3.4.11.5 and the definition of “direct outfall” will be added and clarified in the LA Section 

1.6.3.4. 

License Documentation Impact: Paragraph three of former LA Section 1.6.3.4, “Characteristics 

of Nearby Rivers, Streams and other Bodies of Water” (now a subheading under 1.7.3.4 in 

response to RAIs RP-13 and GI-5) will be revised to read as follows: 

Surface drainage at the site is contained within two local playa lakes that have no external 

drainage. The nearest river to the IIFP facility site is 50 miles, or greater, away (the Pecos River) 

and rRunoff does not from the site is unlikely to drain to this river.one of the state’s major rivers.

Surface water is likely lost through evaporation, resulting in high salinity conditions and the 

waters in soils associated with the playas. These conditions are not favorable for the development 

of viable aquatic or riparian habitats. The IIFP facility has no direct outfall to a natural body of 

surface water. IIFP defines “direct outfall” as a discharge of facility water directly into a natural 

body of surface water such as a river or stream, or as a water discharge normally identified as an 

“outfall” in a National Pollutant Discharge Elimination (NPDES) permit. At the IIFP Facility, 

process water and cooling water are either recycled back into the process systems or evaporated 

in the Environmental Protection Process (EPP) Facility as part of the treatment. Process areas 

where hazardous chemicals or licensed materials are processed and handled have sealed dikes, 

curbs and pumps, where necessary, to collect and transport leaks or spills in those areas back into 

the process or to the EPP for treatment as process water. Sanitary wastewater from toilets, 

lavatories and showers receives primary, secondary and tertiary treatment and is used to water an 

on-site tree farm in accordance with New Mexico ground-water permit requirements, where 

applicable. Disposition of sanitary water and collected rain or storm water is further described in 

Section 1.1.5.3 above. There is no designated FEMA Zone “A” area that would be inundated 

during a 100-year flood event.

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General Information 

GI-11 

B. The ER Section 4.4.7 refers to a Stormwater Pollution Prevention Plan (SWPPP). This plan 

does not appear to be a commitment addressed in the LA. Since the ER is not part of the 

license application, incorporate the commitment to maintain the SWPPP into the LA. Add a 

commitment similar to ER Sections 3.4.11.4 and 3.4.11.5 to the LA. 

RESPONSE: The information relative to a Stormwater Pollution Prevention Plan (SWPPP) for 

the IIFP Facility operations that is described in the IIFP ER Section 4.4.7 will be included as a 

new paragraph five in the former LA Section 1.6.3.6 “Groundwater Hydrology” (now subheading 

under 1.7.3.4 in response to RAIs RP-13 and GI-5.) The information in the IIFP ER for 

commitment to a SWPPP is found in ER Section 3.4.10; not the referenced ER Sections 3.4.11.4 

and 3.4.11.5. The SWPPP commitment in ER Section 3.4.10 will be added appropriately as 

paragraph four in LA Section subheading “Groundwater Hydrology in the new 1.7.3.4.

License Documentation Impact: New paragraphs 4 and 5 will be added to the IIFP LA former 

Section 1.6.3.6 (new 1.7.3.4) subheading “Groundwater Hydrology.” 

A NPDES--Construction General Permit for stormwater discharge is required because 

construction of the IIFP plant will involve the grubbing, clearing, grading or excavation of one or 

more acres of land. This permit is required prior to certain pre-construction activities and to 

construction activities and will be administered by the Environmental Protection Agency (EPA) 

with oversight review by the New Mexico Water Quality Bureau. Various land clearing activities 

such as off-site borrow pits for fill material are covered under this general permit. IIFP 

construction contractors will be clearing approximately 40 acres during the construction phase of 

the project. IIFP will develop a Storm Water Pollution Prevention Plan (SWPPP) and file a 

Notice of Intent (NOI) with the EPA, at least seven days prior to the commencement of 

construction activities, in accordance with regulatory requirements 

A Spill Prevention Control and Countermeasure (SPCC) plan will be implemented for the facility 

to identify potential spill substances, sources and responsibilities. In addition, storm water 

discharges during plant operation will be controlled by a Stormwater Pollution Prevention Plan 

(SWPPP) to assure that runoff released to the environment will be of acceptable water quality. 

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