April 26, 2011 

MEMORANDUM TO: Dennis C. Morey, Acting Chief 

 Conversion, Deconversion, and 

 Enrichment Branch 

 Division of Fuel Cycle Safety 

 and Safeguards 

 Office of Nuclear Material Safety 

 and Safeguards 

FROM: Matthew A. Bartlett, Project Manager /RA/

 Conversion, Deconversion, and 

 Enrichment Branch 

 Division of Fuel Cycle Safety 

 and Safeguards 

 Office of Nuclear Material Safety 

 and Safeguards 

SUBJECT: APRIL 14, 2011, CALL REGARDING REQUESTS FOR ADDITIONAL 

INFORMATION FOR FINANCIAL ASSURANCE AND HUMAN 

FACTORS TO SUPPORT THE INTERNATIONAL ISOTOPES, INC., 

LICENSE APPLICATION SAFETY REVIEW (TAC NO. L32739) 

 The U.S. Nuclear Regulatory Commission’s staff held a conference call with the 

International Isotopes, Inc.’s, (INIS) licensing manager and contractors on April 14, 2011. The 

purpose of the call was to discuss the draft responses to the Requests for Additional Information 

(RAI) for the financial assurance and human factors reviews. A summary of the call and the 

talking points provided in advance of the call are enclosed. INIS reviewed this summary for 

factual correctness. 

CONTACT: Matthew A. Bartlett, NMSS/FCSS 

 (301) 492-3119 

Docket No. 40-9086 

Enclosures: 

1. Agenda and List of Participants 

2. Call Summary for Draft RAI Responses 

 for Financial Assurance and Human Factors 

3. Financial Assurance and Human Factors Talking Points 

cc: Mr. John J. Miller, CHP 
 

MEMORANDUM TO: Dennis C. Morey, Acting Chief 

 Conversion, Deconversion, and 

 Enrichment Branch 

 Division of Fuel Cycle Safety 

 and Safeguards 

 Office of Nuclear Material Safety 

 and Safeguards 

FROM: Matthew A. Bartlett, Project Manager /RA/

 Conversion, Deconversion, and 

 Enrichment Branch 

 Division of Fuel Cycle Safety 

 and Safeguards 

 Office of Nuclear Material Safety 

 and Safeguards 

SUBJECT: APRIL 14, 2011, CALL REGARDING REQUESTS FOR ADDITIONAL 

INFORMATION FOR FINANCIAL ASSURANCE AND HUMAN FACTORS TO 

SUPPORT THE INTERNATIONAL ISOTOPES, INC., LICENSE APPLICATION 

SAFETY REVIEW (TAC NO. L32739) 

 The U.S. Nuclear Regulatory Commission’s staff held a conference call with the International Isotopes, Inc.’s, 

(INIS) licensing manager and contractors on April 14, 2011. The purpose of the call was to discuss the draft 

responses to the Requests for Additional Information (RAI) for the financial assurance and human factors reviews. A 

summary of the call and the talking points provided in advance of the call are enclosed. INIS reviewed this summary 

for factual correctness. 

CONTACT: Matthew A. Bartlett, NMSS/FCSS 

 (301) 492-3119 

Docket No. 40-9086 

Enclosures: 

1. Agenda and List of Participants 

2. Call Summary for Draft RAI Responses 

 for Financial Assurance and Human Factors 

3. Financial Assurance and Human Factors Talking Points 

cc: Mr. John J. Miller, CHP 

DISTRIBUTION: 

AFCB r/f JMarble RPrzygodzki 

ADAMS Accession No.: ML111090144 

OFFICE NMSS/FCSS/AFCB NMSS/FCSS/AFCB NMSS/FCSS/AFCB NMSS/FCSS/AFCB 

NAME MGuardiola MBartlett LAllen DMorey 

DATE 4/19/11 4/21/11 4/23/11 4/ 26 /11 

 OFFICIAL RECORD COPY 
Enclosure 1 

AGENDA AND LIST OF PARTICIPANTS FOR 

TELEPHONE CONFERENCE TO DISCUSS DRAFT 

REQUEST FOR ADDITIONAL INFORMATION RESPONSES 

APRIL 15, 2011 

AGENDA

8:30 AM - 9:15 AM Discussed Financial Assurance 

9:15 AM - 10:00 AM Discussed Human Factors 

PARTICIPANTS

NAME AFFILIATION

Maria Guardiola U.S. Nuclear Regulatory Commission (NRC) 

Matthew Bartlett NRC 

Roman Przygodzki NRC 

Julie Marble NRC 

John Miller International Isotopes, Inc., (INIS) 

Jim Thomas INIS/Contractor 

et al. INIS/Contractor 
Enclosure 2 

CALL SUMMARY FOR 

DRAFT REQUEST FOR ADDITIONAL INFORMATION RESPONSES 

FOR FINANCIAL ASSURANCE AND HUMAN FACTORS 

Financial Assurance 

The U.S. Nuclear Regulatory Commission’s (NRC) staff requested clarification on the shipping 

costs of waste disposal for certain materials. In addition, NRC staff wanted International 

Isotopes, Inc., (INIS) to explain their 25 percent overhead for third-party labor. NRC staff 

requested INIS to clarify whether the costs of disposal and shipping of DUF6, DUF4, DUO2, and 

UO2 are included in the estimate. INIS indicated that additional detail would be provided. The 

NRC’s staff requested INIS to provide quoted rates for low-level radioactive waste packaging, 

transportation and disposal. Although a contract is not currently in place, INIS will provide 

additional basis for the waste disposal estimates in the application. INIS indicated they would 

not provide forward-looking financial information. However, they would support a license 

condition which would require a yearly update to the Decommissioning Funding Plan over the 

first few years of operations. The license condition could be removed after several years of 

operations through a license amendment. 

Human Factors 

NRC staff agreed with INIS’s plan to provide a human factors (HF) implementation plan as 

stated in the draft responses to the request for additional information (RAI), but also requested 

the plan be incorporated into the license application. This plan would contain much of the 

information needed to address the RAIs. INIS questioned both the level of detail being 

requested by the RAIs and why there was a need to incorporate the implementation plan into 

the license application. The NRC project manager provided INIS an example of an HF 

implementation plan which had been incorporated into and approved for a previous license 

application (Agencywide Documents Access and Management System, Accession 

Number ML102080476). The HF reviewer cautioned that the example was developed before 

NUREG-1520, Revision 1 was implemented; and INIS’s implementation plan should be 

consistent with the NUREG-1520, Revision 1, rather than the example. INIS reiterated that their 

application was submitted prior to publication of the updated NUREG-1520, Revision 1. INIS will 

make a good effort to address the questions. 

The NRC staff emphasized that the RAI responses should focus on how the HF program will be 

developed. The RAI responses should describe the process for identifying and implementing 

HF, rather than providing specific details about facility systems. INIS believed the commitments 

to complying with the regulatory guidance demonstrate compliance with the regulations. The 

NRC staff indicated additional description of the program implementation is needed to address 

the RAIs. 

INIS expressed concern that the level of detail requested in the RAIs would not be available till 

after the formal design is completed in late 2011. NRC staff understands that the design is not 

finalized; therefore, INIS does not need to provide details associated with the design. NRC staff 

indicated that INIS should describe the process they will use to meet the acceptance criteria in 

NUREG-1520, Revision 1, Appendix E. 

INIS plans to provide the final RAI responses by the end of April 2011.