Jntdrnatlonul Istotpe IMc

September 12, 2011

ATTN: Document-Control Desk

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

NRC Docket No. 40-9086

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

TAC L32739.

To Whom it May Concern,

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

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

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

process facility.

1. Official Responses to Seismic and Structural RAIs, Rev. C - Public Version

2. Official Responses to Seismic and Structural RALs Rev. C - Security Related Information

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

questions regarding this letter or require additional information.

Sincerely,

John J. Miller, CIHP

Radiation Safety Officer

JJM-2011-49

Enclosure as Stated

cc: Dr. Matthew Bartlett

U.S. Nuclear Regulatory Commission

Mail Stop E2C40M

6003 Executive Blvd.

Rockville, MD 20852

4137 Commerce Circle, Idaho Falls, Idaho 83401

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

Website: www.intisoid.com
Public Version

Enclosure 1 JJM-2011-49 September 12, 2011

Official Responses to Seismic and Structural RAIs

SS-1. Background.:

The LA and ISA Summary include several typographical errors.

Issue:

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

errors need to be corrected.

Request:.

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

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

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

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

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

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

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

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

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

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

verify that the values listed in the table are correct.

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

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

RESPONSE TO REQUEST #SS-1-1: The Peak Horizontal Ground Acceleration for a 1,000

return is 0.05g instead of the 0.03g as incorrectly stated in LA Section 1.6.4.2.

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

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

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

documented as the result of !he NEF LAlicensing activities of an enrichment facility located near

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

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

Acceleration.(pga) for a 1,000 and 2,500 year return is 44-40.05g and 0.12g respectively (USGS,

2002).

Table 1-78Seismic Criteria for New Mexico Site

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

T 500 yrs . 1000 yrs ' 2500 yrs

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

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

N 5 yrs 50 yrs 50 yrs

pga 0.03g (1) 0.05g (2) 0.12(2)

Weber, 2008; USGS, 2002

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RESPONSE TO REQUEST #SS-1-2: The negative sign for the Celsius temperatures listed in

LA Table 1-6 on Page 1-39 was inadvertently omitted.

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

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

Revision A of the IIFP Environmental Report (see-also RAI GI-0OA) will be revised as follows:

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

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

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

RESPONSE TO REQUEST #SS-1-3: The ISA Summary Section 1 provides a site description

which focuses on those factors that could impact safety (geography, meteorology, seismology,

etc.) of the site and surrounding area.

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

3.2.1 will be revised to read as follows:

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

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

focusing on those factors that could impact safety is contained in ISA Summary, Section 21 and a

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

RESPONSE TO REQUEST #SS-1-4: The ISA Summary Section 2.1, "Overview of Facility

Site," provides a layout of the facilities on the site with a summary description of the facilities

and the location of those facilities.

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

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

description of the IIFP Facility is provided in LA Chapter 1 Section 1.1.

RESPONSE TO REQUEST #SS-1-5: The ISA Summary Table 1-1 was inadvertently

corrupted when copying and editing Table 3-18 of the Environmental Report to the LA.

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

Analysis Summary will be deleted and replaced with revised (see RAI GI-1OA) ER Table 3-18

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

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

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

11.93 cm (4.7 in).

RESPONSE TO REQUEST #SS-1-6: ISA Summary Table 1-2 will be revised as stated below

and as in the response to RAI GI- 10 A.

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

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

Environmental Report will be revised as follows:

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

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

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

RESPONSE TO REQUEST #SS-1-7: The LA is currently under review in response to the

RAIs as well as a general review for typos or corrections need to be made.

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

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

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SS-2. Background:

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

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

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

credible external events. In addition,

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

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

Issue:

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

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

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

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

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

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

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

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

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

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

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

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

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

of missiles it considered in its ISA.

Reguest:

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

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

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

consequence).

2. Provide technical basis tojustify the perceived risk level for each of the hazards identified in

Item 1.

RESPONSE TO REQUEST # SS-2-1: Characterizations of tornadoes/winds, snow, rain and

flood hazards have been performed. The following includes a discussion of those

characterizations and changes to be made to Revision A of the IIFP Integrated Safety Analysis

Summary.

Floods/Rain

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

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

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

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

performed using Department of Energy (DOE) documents DOE-STD-1020-2002, DOE-STD1022-94 and DOE-STD-1023-95. For the IIFP Facility, a Performance Category-3 (PC-3) facility

classification, as defined by the referenced DOE documents, was used. From that assessment,

IIFP determined that a comprehensive flood hazard assessment is not required. Preliminary

screening indicates that flooding is not a design basis event other than in consideration of storm

water runoff. Following is a discussion of the preliminary flood hazard assessment.

DOE 1020-2002 Chapter 4 "Flood Design and Evaluation Criteria" cites criteria that must be

considered to ensure that Structures, Systems and Components (SSCs) satisfy performance goals

for PC-3 facilities. Evaluation of flood design includes:

I. Determination of the Design Basis Flood Level (DBFL) for each flood hazard as defined

by the hazard annual probability of exceeding and the applicable combinations of flood

hazards.

2. Development of a flood design strategy for the DBFL that satisfies the criteria

performance goals.

3. Evaluation of the site storm water management system including site runoff and drainage,

and roof drainage.

4. Design of civil engineering systems to the applicable DBFL and design requirements.

(e.g., buildings, buried structures, site drainage, retaining walls, dike slopes, etc.). This

criterion includes the design to withstand hydrostatic and/or hydrodynamic forces and

debris loads.

In accordance with Table 4-2 "Design Basis Flood Events" in DOE-1020-2002, the following

hazards must be considered:

A. River Flooding including peak flood elevation, wind-waves, ice forces, potential for

erosion, debris, etc.

B. Dam failure including wind-waves and potential for erosion, debris, etc.

C. Storm surge, seiche (due to hurricane, squall lines, etc.) including tide effects and

wave action.

D. Tsunami including tide effects.

E. Local Precipitation including flooding based upon the site runoff analysis, roof

"ponding" and rain and snow loading.

1. Determination of the Design Basis Flood Level (DBFL)

A preliminary screening analysis was performed in accordance with the above DOE-1020-2002

criteria. Below are the results of that screening:

In accordance with DOE-1020-2002 Table 4-1 "Flood Criteria Summary", the Mean Hazard

Annual Probability (MHAP) for Performance Category PC-3 is 1 x 1 0 -4. The preliminary

screening analysis was performed with a MHAP of I x 10-4 as a minimum.

A. A preliminary screening for the potential of river flooding of the IIFP Facility site reveals

that the nearest river (Pecos River) is approximately 50 miles south and southwest from

and 700 feet in elevation below the IIFP Facility site at its nearest point. Based upon this

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information, the potential for river flooding is screened out as a potential source of

flooding of the IIFP Facility site.

B. A preliminary screening for the potential of flooding of the IIFP Facility site from a dam

failure reveals that the nearest dam is Brantley Dam forming Brantley Lake and Lake

McMillan. Brantley Dam is located on the Pecos River approximately 61 miles northeast

and approximately 550 ft below the elevation of the IIFP Facility site. Avalon Dam

forming a smaller Lake Avalon is located on the Pecos River approximately 66 miles east

of and 630 feet in elevation below the IIFP Facility site. No other dams or significant

bodies of water are located within approximately 300 miles of the IIFP Facility site.

Therefore, flooding from lakes (storm surge, wave action seiche) or from the breaching

of dams is screened out as a potential source of flooding of the IIFP Facility site.

C. The IIFP Facility site is approximately 500 miles north of and 3800 feet in elevation

above the Gulf of Mexico; therefore, storm surges, wave action, seiche or tide effects

from hurricanes or squall lines from ocean waters is screened out as a source of flooding

of the IIFP Facility site.

D. The IIFP Facility site, being approximately 500 miles north of and 3,800 feet in elevation

above the Gulf of Mexico, is not subject to Tsunami or tide effects.

E. As a result of the preliminary screening analysis detailed above, it is determined that the

only flooding hazard applicable to the IIFP Facility site is storm water runoff from a

design basis rain event.

2. Development of a flood design strategy for the DBFL

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

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

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

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

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

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

annual probability are 7.2 inches, 14.4 inches, and 17.0 inches respectively. Although DOE-1020-

2002 specifies a MHAP of 1.0 x 10 4 for Performance Category PC-3, the conservative

precipitation estimates for an annual probability of 1.0 x 10- are used in the evaluation of the

IIFP Facility.

Since the only credible flooding event affecting the IIFP Facility site is a design basis rain event,

the flood design strategy is developed from this basis. This includes:

A. Evaluation of the local site topography and contours to determine the effect of natural

drainage on the site.

B. Means of managing storm water to ensure a design basis rain event does not present a

flooding hazard in the process buildings containing IROFS SSC's.

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C. Evaluation of process building roof design to ensure that structural failure does not occur

during a design basis rain event.

D. Design of process buildings to withstand hydrostatic and/or hydrodynamic forces and

debris loads caused by a design basis rain event.

3. Evaluation of local site topography

The IIFP Facility site is located in the northwestern portion and upper end of the LandrethMonument Draw drainage basin designated as basin 13070007 by the USGS with an area of

approximately 4,270 square miles (USGS, 2011), (US EPA, 2011).

The 40-acre IIFP Facility site is within a 640-acre section of land adjacent to and just east of NM

Highway 483 and north of U.S. Highway 62/180. The general slope of the terrain in this area is

from northwest to southeast. The natural lie of the terrain allows only limited rainwater from the

northwest (approximately 16.1 acres) to flow over the site. Most rainwater is naturally diverted

via low areas to the southwest and to the northeast around the site.

The slope of run-on to the site from the northwest is approximately 0.2 1%. The slope of the runoff to the northeast is approximately 0.46%, to the southeast is approximately 0.35% and to the

southwest is approximately 0.38%. Thus the site is naturally self-draining thereby preventing "ponding" or accumulation of water except in two small playas (depressions) located near the

west boundary.

According to drainage evaluations made by GL Environmental, a New Mexico based

environmental consultant, ("Existing Groundwater Conditions in Section 27, Township 18 South,

Range 36 East", 12/8/20 10), once drainage is diverted around the IIFP Facility site, the terrain

tends to drain toward the southeast to a collection playa approximately 8 miles away at an

elevation approximately 225 feet lower than the IIFP Facility site.

Included, as a separate document, with this "Official Response to Seismic and Structural"

document package is a drawing (Sketch F-1, Rev A, "640 Acre Plan, Site Drainage") showing the

general contours of the land surrounding the IIFP Facility site. The contour drawing is based on

the IIFP Facility concept. Detail civil engineering design and surveys have not yet been

performed. The drawing was prepared from satellite imagery and is being included to show that

the natural drainage in the area promotes constant flow across the site with a highly unlikely

potential for accumulated flooding.

Due to the natural drainage of the area and the site grading and drainage system, it is reasonable

to predict that rainwater from a design basis rain event will not flood the IIFP Facility site but that

any rainwater entering the site that does not percolate into the soil will flow over and off the site.

4. Evaluation of site stormwater management system and development of DBFL

Using the conceptual contour drawing, Sketch Fl, and assuming no credit for grading or storm

water sewer system design or installation, a maximum DBFL affecting the process buildings is

determined to be 4.8 inches from a 7.2 inch/hour 1.0 x 10.5 precipitation event [Natural Resources

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Conservation Service (NCRS) Method]. This evaluation considered the 1-hour, 24-hour, and 48-

hour all-season precipitation estimates for 1.0 x 10-5 annual probability (7.2 inches, 14.4 inches,

and 17.0 inches, respectively) using the probable maximum area of 16.1 acres of rainfall that

might affect the process buildings and a slope of run-on (.00207 ft/ft) to the site from the 16.1

acres.

The site will be graded to divert rainwater away from process areas of the facility. Floor

elevations of process buildings will be constructed a minimum of 6 inches above surrounding

grade to promote drainage away from the buildings. Process buildings and structures will be

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

such an event) from leaving the structure. This curbing although not credited in the DBFL also

serves as flood barriers for those structures.

Roofs of all process buildings will be constructed of metal with a minimum pitch of 5/12 and

with gutters and down-spouts however this design is not credited in the DBFL.

The site storm water system consisting of area inlets and storm sewers connected to the

Stormwater Retention Basin in the southeast area of the IIFP Facility site will be designed and

constructed for a 4 inch, 1 hour rain event slightly above the 3.2 inch, 1 hour rain event with a 1.0

x 10-2 annual probability as published in NOAA Atlas 14. This storm water system will not be

relied upon for protection in case of a design basis 7.2 inch, 1 hour rain event with a 1.0 x 10-1

annual probability.

Berms and dams will not be relied upon or credited for protection in case of a design basis 7.2

inch, 1 hour rain event with a 1.0 x 10-5 annual probability.

All IROFS SSC's and related instrumentation, controls, electrical equipment and supports will be

located well above the grade level of the first floor of process buildings.

5. Design of civil engineering systems to the applicable DBFL

Using the maximum calculated run-on velocity of 0.734 ft/sec, and a flow depth of 4.8 inches,

preliminary calculations show that the maximum horizontal hydrodynamic pressure exerted on a

process building by a design basis flood is 1.05 lb/square foot which equates to a force of 37.6 lb

on the largest building, the DUF 6 Autoclave Building with maximum dimension of 90 ft. This

force is negligible compared with the seismic force or straight wind force imposed upon the

building, but will be considered in the design of building structures and foundations.

It is apparent that any impact of water-borne debris buoyant enough to be carried by 4.8 inches of

water traveling at a velocity of 0.734 ft/sec would not damage the wall of a process building

containing IROFS SSC's.

Tornado/Wind

The evaluation of tornadoes and straight winds was made based on NUREG/CR-446 1, Revision 2

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

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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 I 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 Ix 10-5

, 1 x 10"6, and 1x10-7 probability design wind speeds (i.e.,

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

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

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

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

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

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

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

from 364 events of the 435 events observed.

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

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

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

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

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

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

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

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

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

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a

10000000

RETURN

PERIOD

(YRS)

1000000

100000

10000

1000

100

10

1

;traght. t Wind Speed vs-Tornado=Wind, Peed-for1, r2,& 4IDegree Boxes ....... ....... .. ......... .

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........... _.._... . ..........

.. .I . . . . .. = ' .A.....T: ... ........ T .. I ----- t+- ----

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I il1 1 1

0 50 100 150

WIND SPEED (MPH)

200 250 300

Legend: 40 Box - Red; 1

0 Box - Green; 20 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 (Appendix D and Annex to Appendix D) by reference

to DOE-STD-1020-2002.

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

exposure and for tornadoes at IOim (33 fi) 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

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

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

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

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

material or process buildings containing processes or materials potentially affecting licensed

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

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

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

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

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

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

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 (1 x 102),

for PC-3 structures is 117 mph (1 x 10-3) and for PC-4 structures is 135 mph (1 x 104).

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

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

1 0 "4. This criteria can be met in two ways: 1) design the facility to survive the force of winds with

an occurrence probability of 1x10-4 (135 mph), or 2) design the facility to withstand a straightline wind load of Ix10- 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

10.1 yr'. Strike probabilities for the one-degree and four-degree boxes are 5.235 x 105yrf and

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

speed at the 1 0 4 probability level represents a conservative approach with respect to wind speed.

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

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

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

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

mentioned above, those structures will meet the performance category of 1 x 10-4, which is

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

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

methodology in NUREG-1520, Revision 1, the collapse or loss of the building integrity is

considered to be highly unlikely and meets the qualitative frequency scale of 1 x 10-5 per year or

less. Events that occur at a highly unlikely frequency meet the performance criteria for acceptable

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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 I x 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.

Snow

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

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

Summary Section 1.3.2.7 and the new text is shown in the License Documentation Impacts

below.

License Documentation Impacts Related to Response SS-2-1:

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

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

replaced with the following:

1.3.2.86 Floods

The IIFP site does noet fall within 100 year or 500 year fleadplains (1112-1, 2009). The sitei

located in a semi arid lceatiOn with limited bodies of water.The site is located in an area which

does not fall within a mapped 100 year or 500 year flood plain and 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.

Since there is no significant body of water or river 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 (See assessment discussion below). According to information obtained from NOAA

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

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

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

only 14 of the events, all of which occurred in the cities and towns of Lea 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 property would likely receive some drainage from New Mexico 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 indicates that water would naturally drain

away from the property toward the east and south as gradual but significant elevation declines

occur in those directions for several miles.

A preliminary flood hazard assessment for the IIFP Facility was performed using Department of

Energy (DOE) documents DOE-STD- 1020-2002, DOE-STD- 1022-94 and DOE-STD- 1023-95.

For the IIFP Facility, a Performance Category-3 (PC-3) facility classification, as defined by the

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referenced DOE documents, was used. From that assessment. IIFP determined that a

comprehensive flood hazard assessment is not required. Preliminary screening indicates that

flooding is not a design basis event other than in consideration of storm water runoff. A summary

of the preliminary flood hazard assessment is discussed below.

In accordance with DOE-1020-2002 Table 4-1 "Flood Criteria Summary", the Mean Hazard

Annual Probability (MFIAP) for Performance Category PC-3 is I x 10"4. The preliminary

screening analysis was performed with a MHAP of I x 10-1 as a minimum.

A. A preliminary screening for the potential of river flooding of the IIFP Facility site

reveals that the nearest river (Pecos River) is approximately 50 miles south and

southwest from and 700 feet in elevation below the IIFP Facility site at its nearest

point. Based upon this information, the potential for river flooding is screened out as

a potential source of flooding of the IIFP Facility site.

B. A preliminary screening for the potential of flooding of the IIFP Facility site from a

dam failure reveals that the nearest dam is Brantley Dam fiorming Brantley Lake and

Lake McMillan. Brantley Dam is located on the Pecos River approximately 61 miles

northeast and approximately 550 ft below the elevation of the IIFP Facility site.

Avalon Dam forming a smaller Lake Avalon is located on the Pecos River

approximately 66 miles east of and 630 feet in elevation below the IIFP Facility site.

No other dams or significant bodies of water are located within approximately 300

miles of the IIFP Facility site. Therefore, flooding from lakes (storm surge, wave

action seiche) or from the breaching of dams is screened out as a potential source of

flooding of the I1FP Facility site.

C. The IIFP Facility site is approximately 500 miles north of and 3800 feet in elevation

above the Gulf of Mexico; therefore. storm surges, wave action. seiche or tide effects

from hurricanes or squall lines from ocean waters is screened out as a source of

flooding of the IIFP Facility site.

D. The IIFP Facility site, being approximately 500 miles north of and 3,800 feet in

elevation above the Gulf of Mexico, is not subject to Tsunami or tide effects.

E. As a result of the preliminary screening analysis detailed above, it is determined that

the only flooding hazard applicable to the IIFP Facility site is storm water runoff

firomn a design basis rain event.

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

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

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

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

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

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

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

The 40-acre IIFP Facility site is within a 640-acre section of land adjacent to and just east of NM

Highway 483 and north of U.S. Highway 62/I80. The general slope of the terrain in this area is

from northwest to southeast. The natural lie of the terrain allows only limited rainwater from the

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northwest (approximately 16.1 acres) to flow over the site in the vicinity of the process buildings.

Most rainwater is naturally diverted via low areas to the southwest and to the northeast around the

40-acre site.

The slope of run-on to the 40-acre site from the northwest is approximately 0.2 1%. The slope of

the run-off to the northeast is approximately 0.46%, to tile southeast is approximately 0.35% and

to the southwest is approximately 0.38%. Thus the site is naturally self-draining thereby

preventing "ponding" or accumulation of water except in two small plavas (depressions) located

near the west boundary.

According to drainage evaluations (GI,. 2010). once drainage is diverted around the IIFP Facility

site, the terTain tends to drain toward the southeast to a collection plava approximately 8 miles

away at an elevation approximately 225 feet lower than the site of the I IFP Facility.

Detail civil engineering design and surveys have not yet been performed. However, the drainage

for the area surrounding the 40-acre conceptual design IIFP Facility was evaluated using general

contours of the area. The contours show that the natural drainage in the area promotes constant

flow across the site with highly unlikely potential for accumulated flooding. Using the general

contours evaluation for the conceptual design facility land area and assuming no credit for site

grading or storm water sewer installation, a maximum design basis flood level (DBFL) affecting

the process buildings is estimated to be 4.8 inches from a 7.2 inch/hour 1.0 x 10-5 precipitation

event rNatural Resources Conservation Service (NCRS) Method]. This evaluation considered the

I-hour, 24-hour, and 48-hour all-season precipitation estimates for 1.0 x 10.5 annual probability

(7.2 inches, 14.4 inches, and 17.0 inches, respectively) using the probable maximum area of 16.1

acres of rainfall that might affect the process buildings and a slope of run-on (.00207 ft/ft) to the

site from the 16.1 acres. The DBFL will be verified after the IIFP Facility site detail civil

engineering survey is completed and prior to determination of site drainage grade reCtuirements

and design of building, roads and infrastructure.

Due to the natural drainage of the area and the planned site grading and drainage system, it is

reasonable to predict that rainwater from a design basis rain event will not flood the IIFP Facility

site but that any rainwater entering, the site and that does not percolate into the soil will flow over

and off the site.

Based upon the above precipitation estimates for the site and preliminary calculations perforned

as part of the prescreeningt flood hazard assessment, the effect of extreme precipitation of short

duration on process buildings and IROFS SSCs at the ITFP Facility is minimal. In the area north

and northwest of the developed site, the terrain will be contoured to divert run-on around the site

so that only the precipitation that falls on the developed portion of the site will affect facility

design. The site storm sewer system will be designed for a 4-inch, I hour maximum rain event

slightly above the 3.2 inch, I hour rain event with a 1.0 x 10.2 annual probability as published in

NOAA Atlas 14, however the storm sewer system will not be relied on or credited for protection

against a design basis flood event. Buildings and structures containing IROFS SSCs will be

constructed a minimum of six inches above grade level and above the level of plant roadways in

order to physically remove (elevate) them from potential floodwater. Process buildings and

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

internal spills (in such an event) from leaving the structure, and this curbing although not credited

in the DBFL analysis also serves as flood barriers for those structures.

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

Analysis Summary will be revised as follows:

1.4.5 Design-Basis Flood Events Used for Accident Analysis

The IIFP F-P/DUP Ssite iz loeated outs has not been mapped but does not lie within areas that

are mapped in the 100-year or 500-year flood-plain=; in and around Hobbs, New Mexico

according to information provided in the FEMA Mapping Information Platform. A detail

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

likelihood of any major flood at the facilitv plai4 site is determined to be was-low and the

consequences are wefe limited (due to no fissile material existing at the site). Thus, flood type

accidents are not a significant risk for facility plaf operations.

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

Analysis Summary will be deleted and replaced with the following:

1.3.2.3 Extreme Winds

'.Mind speeds over the State of Nc,' Mexico are usually moder-ate.. although r-elatively strong

winds often aeccompany) occasional frontal activity during late winter- and spring months and

sometimes occur just in advance of thunderstormas. Froental winds may exceed 30 mile/h1r for

sever-al hours anid reach peak speeds O 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

firom 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. 1l-uricane 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 - FO, 20 - F1,8 - F2. and oneF3 tornadoes were reported. During this same sixty-year period, no F4 or F5 tornadoes were

reported. (NCDC, 2010a)

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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-1 022-2002 including Appendix D. It was detenrined 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-

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-l520, Revision I and by reference to DOE-STD-1020-2002 which, in

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

at lOim (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 energies similar to a

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

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

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

material or process buildings containing processes or materials potentially affecting licensed

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

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

DOE-STD-l 020-2002. Table 3-2 lists design wind speeds and probabilities of"exceeding" for

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

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

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

wind speed Fbr 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 (Ix10 2), For PC-3 structures is 117 mph

(Ix10 3 ) and fior PC-4 structures is 135 mph (Ix10"').

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 I x10'. This l x 104

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

using a 135 mph straight wind gust at the lx 104 probability level where no credit is taken for the

Ratio of Hazard to Performance Probability allowed per Table D-2. Therefore, the IlFP 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 IXIx0, 3 with a Ratio of Hazard to

Performance Probability of 10 may be used to meet the performance goal of I x 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 I x10 5 . Also, according to

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Appendix A ofNUREG/CR-4461. Revision 2, strike probabilities for the one-degree, the twodegree and the four-degree boxes containing the IIFP site are 5.235 x 105yr', 8.444 x 10-' yr-I

and 3.975 x 10s yrv" respectively. Therefore, selection of a design basis wind speed for IIFP PC-3

structures of 135 mph at the l x10"4 probability level represents a conservative approach. The I1FP

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 70.6 1, "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 categorv of I x 10.. and be designed to

withstand a I x10 4 probability per year occurrence straight-line wind event. Hence, based on tile

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

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

unlikely and meets the qualitative frequency scale of I x105 per year or less. Events that occur at

a highly unlikely fi'equency 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 IIFP applicable facilities to withstand straight-line wind events with an occurrence

frequency of lxl 04 per year meets ISA risk acceptance levels regardless of the hazardous

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

release.

License Documentation Impact: Additional references will be included in Section 1.7 (new

Section 1.8) of the IIFP License Application (LA) for (ASCE, 2006) and (DOE, 2002). The

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

Section 1.7.3.3 (renumbered in response to RAI RP-13) after subheading Floods and text of the

IIFP License Application.

Snow

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

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

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

also occurred in November.

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

affecting licensed material) at the IIFP site is 81.2 lb/ft2 or 396.8 kg/in 2. This design load is based

on the sum of the 100-year return period snowpack and the load corresponding to the 48-hour allseason precipitation and an annual probability of 1.0 x 10-5 for the facility site area. (Refer to the

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

determining the design basis snow load).

L.78 References

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

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

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

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

2002.

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

(ASCE, 2006), (DOE, 2002), (NRC, 2010) and (GL, 2010). A new Section 1.3.2.7 "Snow"

(below new Section 1.3.2.6 "Floods", numbering change in response to RAI 10 GI-0OD) will be

added to the IIFP ISA Summary, Revision A to read as follows:

1.3.2.7 Snow

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

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

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

also occurred in November.

The design basis extreme environmental "ground" snow load for the IIFP Facility site is 96.7

lb/ft2 or"472.5 kg/mr. This design basis ground snow load is calculated as the sum of the 100-year

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

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

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

buildings (involving or affecting licensed materials) at the IlFP Facility site will be sloped at a

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

Engineers Standard 7-05 "Minimum Design Loads for Buildings and Other Structures" (ASCE 7-

05) to convert the ground snow load into a "roof' snow load, the design basis extreme

environmental "roof" snow load for the buildings on the IIFP Facility site is 81.2 lb/ft2 (396.8

kg/rn 2). This calculation assumes no runoff of snow or rain notwithstanding that roofs of IIFP

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

extreme roof snow load for the purpose of process building design.

IIFP used the data collected bv the Western Regional Climate Center (WRCC) for the Hobbs,

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

(severe) design basis ground snow load of 8.4 lb/ft2 (41.0 kg/m2) (N RC. 2010). Since essentially

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

was necessary.

All-season precipitation estimates for the I IFP Facility site are provided by the National Weather

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

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

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

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

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

inches of precipitation (as water) corresponds to a ground snow load of 88.3 lb/ft2 or 43 1.5 kg/nm2 .

The sum of the ground snow load from precipitation and from snowpack is 96.7 lb/fl2 or 472.5

kg/ni 2 from which the roof snow design load (81.2 lb/ft2 or 396.8 kg/iM2) is determined as

described above.

1.6 References

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

Buildings and Other Structures: SEI/ASCE 7-05 (ASCE Standard)." 2006 DOE, 2002. U.S.

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Department of Energy, DOE STD- 1020-2002, "Natural Phenomena Hazards Design and

Evaluation Criteria for Department of Eneray Facilities." Washinttton. D.C., Januarv 2002.

NRC, 2010. Nuclear Regulatory Commission. NUREG-1951 "Safety Evaluation Report for the

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

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

GL, 2010. GL Enviromental, "Existing Groundwater Conditions in Section 27, Township 18

South, Range 36 East", December 8. 2010.

RESPONSE TO REQUEST #SS-2-2: The ISA Summary Section 5.2.1 is intended to discuss

PHA methodology and not the characterization and justifications for the hazards assessment. The

three paragraphs immediately following Table 5-3 in the Section 5.2.1 of the ISA Summary

Revision A are being removed because the information in those paragraphs is not part of the

description of the PHA methodology. Instead, the natural phenomena hazard characterization and

the technical basis for justification of the perceived risk levels are provided in the above

discussions and further clarified in the ISA Revision A changes shown below.

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

following Table 5-3) are removed.

5.2.1 Hazard Identification Method

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

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

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

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

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

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

PHA.

There are a nvumber of Acuhicle in m44;tin hazard, that ave nct "cnsideroed in the P-IA. A4n aircraft

cr.ash typically c.nsists of an iniitial imf.pact Af the air.raft with tile ground and a slide into the

faceility (dir-ect impact is possible but much less likely). This event is extremely uinlikely even for

ver-y larg-e strucetures. For FEP/DUIP process buildings and all ether fiacilities en the site, a larige

aifei-aft cr-ash is juidgcd to be beyonid extreel unlikely and is noet consider-ed futiiher.

hImpacts from general aviation planes or hclieopters arc cr-edible but cxtremely unlikely.. Although

the damage potential to FE921P/DUP2 facilities has not been quantified, it is re-asnaRAble. to assume

that the- build-ing stnietufes that are designed and built to seismic cr-iteria aesfiin to proatect

the hazardous miater-ials within the buildinigs. Therefor'e, radiological andcr- hatzardous mfaterial

releases arc minimfal. Since small aircr-aft anid/or helicopter cr-ashes are considered low r-isk and

are noet considered furt~her ini the PHA.

H~igh winid, snoaw loading,- floodinig, and other- NPI-l ev~ents are not eansidefed .separate I,. Dute to

the seismic designi capacity of the process buildings.. the FEP/DUP Plant is expected to withstanid

these hazards with minimial damage. Although toppling of equipment or- lightniing induced fir-es

may be possible, radiological and/or- hazardous material releases are mianimal. Therefor-e, these

NPH ev~ents ar-e considered low risk anld are not considered futiiher-.

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SS-3. Background.:

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

against environmental conditions and dynamic effects in facility design, and 10 CFR 70. 62(c)(iv)

requires the applicant to conduct and maintain an ISA that identifies potential accident sequences

caused by credible external events. In addition, 10 CFR 70.61(b) and 70.61(c) require the

applicant to demonstrate that an accident event can be excluded from further consideration based

on either its likelihood or its consequences.

Issue:

In LA Sections 1.1.1, Facility Location, Site Layout and Surrounding Characteristics, 3.2.4.3,

New Facilities or New Processes at Existing Facilities, and 3.2.5.2, Hazard Identification; and

ISA Summary Section 4.4.4, Environmental and Dynamic Effects and Table 3-6, FEP/DUP

Facility Hazards Identification, the applicant indicated that several gas pipelines run across the

proposed site, and pipelines were included as an external human-induced hazard. However,

neither the LA nor the ISA Summary included discussion of gas pipeline characteristics. These

characteristics may include the number of gas pipelines that pass through the proposed site and

their relative distance from the site or facility, nature of the gas these pipelines carry, probability

of gas pipeline explosion, and potential effects (e.g., explosion overpressure) if the probability of

pipeline explosion exceeds an annual probability of 0O- 5 (the applicant's highly unlikely

definition).

The LA indicated that nearby industrial and military facilities were included as an external

human-induced hazard. However, neither the LA nor the ISA Summary included discussion of

nearby industrial and military facilities. The applicant did not discuss potential hazards

associated with transportation routes.

Request:

Describe the potential hazards to the FEP/DUP because of(i) industrial and military facilities,

(ii) gas pipelines, and (iii) transportation routes per Regulatory Guide 1.91.

RESPONSE TO REQUEST #SS-3-i: There are four industrial facilities nearby the IIFP site.

Descriptions of those facilities will be provided in the revisions to the ISA Summary as shown in

the License Documentation Impact below.

There is no military installation within 20 miles of the IIFP site. There are, however, military

operations out of the nearby regional/international airports, including the Lea County Regional

Airport. Additionally, there is a Special Use Airspace for two Military Operations Areas (MOAs)

north of the IIFP Facility. These include the Bronco 3 and Bronco 4 MOAs. Four (4) IFR Military

Training Routes are within a 30 nautical mile radius of the IIFP Facility site. The ISA Summary

will be revised to address military operations.

Hazard Energy Sources as listed in Table 5-3, "FEP/DUP Facility Hazard Identification

Checklist," include the following as "applicable to the PHA"(1) non-facility events as explosions,

fires, and power outages and (2) vehicles in motion, e.g. airplanes, cranes/hoists, forklifts,

helicopters, or trucks/cars. The ISA Summary will also be revised to discuss the potential hazards

from nearby industrial and military facilities.

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License Documentation Impact #SS3-i: Two additional references will be added to Section 1.6.

One will be added for the explosion analysis for Cunningham Station (IIFP, 201 la). The other

reference will be added for the Underground Natural Gas and LPG Pipeline Hazard Evaluation

(IIFP, 201 lb). Section 1.2.4, "Nearby Industrial Facilities." of the ISA Summary Rev A will be

revised to discuss the potential hazards as non-facility hazards and vehicles in motion and to

describe the nearby military facilities as follows:

Section 1.2.4 Nearby Industrial Facilities

Land around the proposed site has been mostly developed by the oil and gas industry. Three gasfueled electric-generatingpewef plants and a gas-processing facility are located nearby including

the indiustrial Xcel Energy Cunningham Station. 1.6 km (1.0 mi) en-from the site on the west

boundary (New Mexico Highway 483); of the proposed wIFP pr.pei.y lifne, Xcel Energy Maddox

Station located 3.5 km (2.2 mi) en-the-east-southeast of the smide-,site and the Colorado Energy

Hobbs Generating Station 3.1 kin (1.9 mi-o*n4-e cast-northeast of the site. The DCP Midstream

Linam Ranch Plant is a natural gas processing facility and is located 5.8 km (3.4-6 mi) southeast

of the IIFP site. Land use within a Five Mile Radius.

Hazard Energy Sources as listed in Table 5-3. "FEP/DUP Facility Hazard Identification

Checklist," include (I) non-facility events such as explosions, fires, and power outages and (2)

vehicles in motion, e.g. airplanes, cranes/hoists, forklifts, helicopters, trains, or trucks/cars.

See ISA Summary Section 1.2.4.3, "Nearby Air Transportation" for the impact to the IIFP

Facility firom vehicles in motion hazards (aircraft and helicopters) at these nearby facilities.

Other potential hazards to the FEP/DUP because of nearby industrial facilities include nonfacility events such as explosions. Since all three proximity criteria from Section 3.5.1.6 of SRP

NUREG 0800 were met, an aircraft crash into the I IFP Facility is an incredible event. Similarly,

an aircraft crash into a nearby industrial facility would be a highly unlikely event. Should an

aircraft indeed crash into a nearby facility, the consequences to the IIFP Facility would be similar

to that of an explosion potentially caused by the aircraft accident. The structures of the I FP

Facility are to be designed to withstand a 6.9 kilopascals (kPa) (1 psi) overpressure as suggested

by the Regulatory Guide 1.91.

An explosion analysis (IIFP, 201 Ia) determined that a natural gas explosion at the nearest

industrial facility, Excel Energy Cunningham Power Station located 1.6 km from the nearest IIFP

Process Building, will not impose a blast wave greater than (or equal to) 6.9 kPa (1 psi) on any of

the IIFP Process Buildings. The structures of the IIFP Facility are to be designed to withstand a

6.9 kPa (I psi) overpressure as suggested by the Regulatory Guide 1.91. Thus. a natural gas

explosion from nearby industrial facilities poses no credible danger to the IIFP Process Buildings.

The explosion analysis and results for nearby gas pipelines are discussed in subsection 1.2.4.2 of

the ISA Summary.

Other hazard energy sources from other industrial facilities to the IIFP Facility are fires and

power outages. Chapter 7 of the IIFP License Application covers "Fire Safety." The fire safety

program is intended to reduce the risk of fires and explosions at the IIFP Facility and documents

how the facility administrates the fire safet program at the IIFP Facility. Fires at adiacent

industrial facilities could lead to power outages or potential explosions at those facilities. Should

a fire at an adiacent industrial facility not be contained and spreads toward the IIFP Facility,

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administrative controls are maintained for vegetation control and limitations on combustible

loads. These administrative controls reduce the potential for a fire to be initiated or sustained at

the IIFP Facility.

A non-facility event at a nearby industrial facility could result in a power outage at the IIFP

Facility. In the event of a power outage the IIFP Facility has a diesel powered emergency

generator located outside the Main Switchgear Building. The IIFP Facility also possesses an

Uninterruptable Power Supply (UPS) system that provides power to all critical loads during the

interim period between power failure and the generator coming LIp to full speed to supply the site.

All buildings are provided with emergency lighting for the illumination of the primary exit paths

and critical operation areas where personnel are required to operate valves, dampers, and other

controls in an emergency. Thus. fires and power outages at nearby industrial facilities do not pose

a credible risk to the safe operation of the IIFP Facility.

There are no military facilities within 20 miles of the proposed site. The closest military

installation is Cannon Air Force Base (AFB) which is 129 miles from the IIFP Facility. Thus,

there is no need to further assess effects of non-facility events such as explosions, fires, or power

outages from military facilities directly on the IIFP site. See ISA Summary Section 1.2.4.3,

"Nearby Air Transportation" for the impact to the IIFP Facility from vehicles in motion hazards

from military operations.

1.6 References

IIFP, 201 ]a. International Isotopes Fluorine Products. Inc., "Maximum Blast Pressure Wave at

IIFP Process Building due to Natural Gas Pipeline Explosion at the Cunningham Power Station."

Paits l and 2; 2011.

IIFP, 201 lb. International Isotopes Fluorine Products, Inc., "Underground Natural Gas and LPG

Pipeline Hazard Evaluation." 2011.

RESPONSE TO REQUEST #SS-3-ii: Several underground fossil fuel pipelines are present in

the vicinity of the 40 acre IIFP Facility site. These include natural gas (NG) and liquefied

petroleum gas (LPG). An engineering drawing (I 00-C-0004, Revision A) of the location of the

pipelines with respect to the IIFP Facility is being included as part of the Seismic and Structural

RAI response documentation package.

The leak or rupture of an underground fossil fuel pipeline, followed by detonation, would

generate a blast pressure wave. The source magnitude of the fossil fuel release would primarily

depend on the fuel type, pipe size, and pipe pressure. Atmospheric conditions (atmospheric

stability class and wind speed) would affect dispersion of the fuel which would strongly influence

the source magnitude of the blast.

The magnitude of the blast pressure wave generated by the blast would rapidly diminish with

distance. Forces imposed on an industrial structure from a blast pressure wave less than one psi

are considered safe (NRC Regulatory Guide 1.91). IIFP conducted a project evaluation entitled,

"Underground Natural Gas and LPG Pipeline Hazard Evaluation" which provides an estimate of

the annual probability that the rupture of a nearby underground fossil fuel pipeline (followed by

ignition) could generate an overpressure blast wave greater than one psi at an IIFP process

building.

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The analytic methods applied to estimate the probability are described in the License

Documentation Impact (new ISA Section 1.2.4.2). These methods are based on NRC guidance,

site specific meteorology, empirical data from the Gas Research Institute, and operational

pipeline safety data from the Pipeline Hazardous Material Safety Administration (PHMSA). Key

pipeline data (fuel type, diameter, and pressure) are known for all but two of the nearby pipelines.

Specifically, there is one NG pipeline for which diameter is unknown, and there is another NG

pipeline for which the pressure is unknown. A 12 inch diameter and a 1500 psi pressure are

conservatively assumed in the IIFP pipeline hazard evaluation.

Upon rupture, the pressure in a pipeline will initially decay rapidly. Beyond the first five minutes,

pipeline pressure will continue to decay but at a slower rate. To simplify the blast calculations, an

average release rate is needed. The average release rate for each pipeline is conservatively based

on a five minute decay factor, even though the release generally persists for 60 minutes prior to

detonation. No credit is taken for release attenuation by the soil matrix.

Site specific atmospheric data was obtained from the State of New Mexico. To facilitate the

evaluation, the data was assembled into a canonical set of 43 wind-speed plus stability-class

combinations. For each pipeline release rate, blast circle results from the Environmental

Protection Agency (EPA) ALOHA computer code were applied to calculate the one psi blast

radius for all 43 sets of atmospheric conditions, and the frequency weighted pipeline exposure

distances were determined per the method specified in NRC Regulatory Guide 1.91. Wind is

conservatively assumed to blow directly toward each process building for every case. PHMSA

pipeline safety data were applied to develop explosion-per-pipeline-mile-per-year metrics for

both natural gas and liquefied petroleum gas transmission and distribution pipelines. Based on

these methods and assumptions, the annual probability that a nearby, fossil fuel pipeline could

rupture, detonate, and cause a one psi (or larger) blast pressure wave at a process building is less

than 3 x 10.6. The probability of this event qualifies as highly unlikely per guidance in NUREG1520, Revision 1; therefore, no further analysis of this event is required.

License Documentation Impact #SS3-ii: A new Section 1.2.4.2 will be added to the IIFP ISA

Summary to address hazards from nearby gas pipelines. This response and impact was also

explained in response to RAI FS-8 and ISA-08.

1.2.4.2 Nearby Gas Pipelines

A New Mexico licensed engineering company performed a survey of the proposed site to identify

nearby underground fossil fuel pipelines. Based on easement records filed with Lea County,

several underground fossil fuel pipelines are located within one mile of the proposed site (one

etroleum gas pipeline and several natural gas pipelines). An engineering drawing (number 100-C0004 Revision A) shows the gas pipeline locations in reference to the IIFP Facility site plan and

is available as part of the IIFP License Application Engineering Drawing Package submitted to

the NRC. As part of the land survey, each pipeline was assigned a designation (i.e., Pipeline 45a).

The survey successfully identified the diameter and pressure for the liquefied petroleum gas

(LPG) pipeline and all but two of the natural gas (NG) pipelines. The pressure is unknown for one

NG pipeline, and the diameter is unknown for the other NG pipeline. Based on the available

pieife4n-data for pipelines located near the IIFP site. the largest NG pipeline diameter is 12 inches

and the larg.est NG pipeline pressure is 1500 psi. These values are conservatively selected to

characterize the pipelines for which diameter and pressure are unknown.

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The leak or rupture of a nearby. underground, fossil fuel pipeline could form an explosive cloud

of gaseous fuel in the atmosphere. Detonation of the explosive cloud would generate a blast

pressure wave. The magnitude of the blast pressure wave would depend primarily on fuel type,

pipe diameter, and pressure. Atmospheric conditions (stability class, wind speed, and wind

direction) would influence the transport and dispersion of the gaseous fuel and therefore influence

the size of the explosive cloud and the magnitude of the blast. The magnitude of a blast pressure

wave attenuates rapidly with distance. A blast pressure wave less than one psi is considered

conservatively safe for industrial structures (NRC Regulatory Guide 1.91. 1978).

An evaluation (IIFP, 2010b) was performed to determine the annual probability that the rupture

of a nearby fossil fuel pipeline (followed by detonation) could generate a blast pressure wave

greater than one psi at a process building. Maior calculation steps and key analytic assumptions

for the pipeline explosion probability evaluation are listed below.

[Step 011 Based on 24 years of fossil fuel gas pipeline safety data obtained firom the Department

of Transportation (DOT) Pipeline Hazardous Material Safety Administration (PHMSA) website,

an explosion per year per pipeline mile rate is developed for NG pipelines (a separate rate is

developed for LPG pipelines).

[Step 021 Guillotine pipeline rupture is assumed to occur; a steady gas release ensues: and

detonation of the gas plume occurs as much as one hour after the pipeline rupture.

[Step 031 Blast radii are determined by the Environmental Protection Agency (EPA) approved

ALOHA computer code for every set of wind speed and stability class that occurs in the Lea

County region (there are 43 sets of atmospheric conditions identified). Site specific

meteorological data was provided by the State of New Mexico. Blast radii are determined for a

range of average pipeline release rates and a power series curve fit is developed for each set of

atmospheric conditions (k = I to 43):

BlastRadiusk = WkTZk

Where Blast Radiusk is the blast radius (meters); W1_ is the mantissa of the power series curve fit,

T is the average release rate friom the pipeline (kg/sec): and Zk is the exponent of the power series

curve fit. The subscript "k" represents each of the 43 sets of atmospheric conditions. Power series

curve fits provide an excellent fit to all of the results generated by ALOHA.

[Step 04] For each pipeline, the initial release rate QOi,,i 3, is calculated based on choked flow

conditions from the end for the broken pipe. Equal flow from both ends of the ruptured pipeline is

conservatively assumed. Based on empirical data from a year 2000 report published by the Gas

Research Institute (GR.I-00/0 189. A Model fbr Sizing H-Jie,1 Consequence Areas Associated with

Natural Gas Pipelines), a release rate decay factor (k) is calculated based on the first five minutes

of the release (Q,--0. 16). An average pipeline release rate, k x Qiitial, is conservatively assumed to

persist for as much as one hour before detonation occurs. Althouuh the soil cover would likely

attenuate the release rate via diffusion and absorption, the analysis assumes no credit for the

presence of the soil cover.

[Step 051 Based on the curve fits in Step 04, for each pipeline, a blast radius is calculated for each

set of atmospheric conditions (k = I to 43). Then. consistent with the method illustrated in Figure

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2 of NRC Regulatory Guide 1.91 (NRC. 1978). for each blast radius, calculations are performed

to determine the pipeline exposure distance. Pipeline exposure distance is the span of nearby

pipeline with potential to produce a blast pressure wave greater than one psi at a process building.

It is conservatively assumed that the wind always travels directly toward the nearest process

building.

[Step 061 Each pipeline exposure distance calculated in Step 05 is weighted based on the annual

frequency of the atmospheric conditions.

WeightedExposureDistancek = ExposureDistancek x Freqk

For example, if the calculations reveal that a nearby pipeline has a 287 foot exposure distance

based on D stability and 4 m/s wind conditions (D04). and the annual frequency of D04

conditions is 2.3 percent, then the weighted exposure distance is 2.3% x 287 feet = 6.6 feet.

[Step 071 Based on the equation below, a total, annual, weighted average exposure distance (Srov)

is calculated for each pipeline. The use of a weighted average ensures that redundant exposure

distances are not double-counted.

STOT •TT=43 = 1431 l ExposureDistancek x Freqk

[Step 081 Steps 04 through 07 are performed for each nearby fossil fuel pipeline. The combined

exposure distance for all the NG pipelines is determined separately frlom the exposure distance for

the LPG pipeline. The weighted exposure distance results for the NG pipelines are summed.

NGExposureDistance = STOT,NG

PG Exposure Distance = STOTLPG

[Step 09] Each result from Step 08 (one result to represent the LPG pipeline and one result to

represent the NG pipelines) is then multiplied by the appropriate annual pipeline explosion rate

developed in Step 01. The sum of these products represents the total annual probability that a

nearby, fossil fuel pipeline could rupture, detonate, and cause a one psi (or larger) blast pressure

wave at a process building.

Based on the methods and assumptions described above, the annual probability that a nearby.

fossil fuel pipeline could rupture, detonate, and cause a one psi (or larger) blast pressure wave at a

process building is less than 3 x 10-6. The probability of this event qualifies as "highly unlikely"

per guidance in NUREG-1 520, Revision 1; therefore, no further analysis of this event is required

and IROFS are not necessary to prevent or mitigate this scenario.

RESPONSE TO REQUEST #SS-3-iii: The ISA Summary will be revised to address any

potential transportation explosion hazards.

License Documentation Impact #SS3-iii: A new Section 1.2.4.1 will be added to the ISA

Summary Revision A to describe the potential hazards to the FEP/DUP of transportation routes

per Regulatory Guide 1.91.

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1.2.4.1 Nearby Highways

The Proposed IIFP site is situated within Lea County, on the north side of U.S. 62/180 and on the

east side of NM Highway 483. U.S Highways 62/180 is of four-lane construction and is a wellestablished radioactive waste transportation corridor established by the Department of Energy

(DOE) for shipping transuranic and mixed waste. U.S 62/180 runs southwest toward Carlsbad,

NM, approximately 56 miles ('90.1 kin) from the proposed site. NM 483 runs from intersection of

U.S. 62/180 (Arkansas Junction) to Lovington. NM, approximately 15.4 miles (24. 1 km) from the

IIFP site.

Regulatory Guide 1.91 provides guidance to address transportation explosion hazards near

nuclear power plants. The potential hazard has been reviewed and evaluated in reference to the

Regulatory Guide 1.91 and the NRC Safety Evaluation Report for the National Enrichment

Facility in Lea County, New Mexico. Louisiana Energv Services (NUREG-] 827) (USNRC.

2005).

In NUREG-1 827, the potential hazard of a highway propane explosion was evaluated for

likelihood of occurrence because the postulated accident was in the approximate safe-separation

distance from a proposed safety-significant structure. In the case of the IIFP Facility, the

structures of the proposed conceptual facility are to be designed to withstand a 6.9 kPa (I psi)

overpressure as suggested by the Regulatory Guide 1.91.

The [IFP initial calculation for the lIFP Facility was based on the NUREG-1 827 postulated

accident and considered a 10,000 pound propane truck completely crashing with a resulting

explosion. When calculating TNT equivalents, a 100% TNT mass is used for solid energetic

materials and 240 % TNT equivalence for substances subiect to vapor effective explosions

(Regulatory Guide 1.91. page 3 "C. Regulatory Position").

Using the postulated accident and 10.000 pounds of propane, the TNT explosion equivalence was

determined using a 240% TNT mass equivalence for substances subiect to vapor phase

explosions. The value used in the original RAI response calculation was 24,000 pounds of TNT

equivalence. Based on Regulatory Guide 1.91 conservative safe distance calculations (and the 1

psi incident overpressure for safety significant structure, systems and components (SSCs) that

will be used in the IIFP design basis), the R= kWE-03 for the postulated accident is equal to (45)

x (24,000)13" or approximately 0.24 miles (0.39 kin).

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REDACTED

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SS-4. Background:

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

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

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

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

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

consideration based on either its likelihood or its consequences.

Issue.:

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

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

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

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

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

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

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

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

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

crash hazard to the FEP/DUP tojustify the exclusion.

Reguest.-

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

unlikely for the IIFP FEP/DUP site.

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

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

addresses military operations.

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

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

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

1.2.4.3 Nearby Air Transportation

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

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

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

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

operations and aircraft transits near nuclear facilities.

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

potential radiological consequences is considered to be less than about 1 x 10.7 per year if the siteto-airport distance, D, is between 5 and 10 statute miles and the proiected annual number of

operations is less than 500 D2 , or D is greater than 10 statute miles and the projected annual

number of operations is less than 1000 D2. Seventeen airports within 100 miles of the IIFP

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

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

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

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

distances to the proposed IlFP site, this criterion has been met.

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

potential radiological consequences is considered to be less than about I x 10' per Year if the site

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

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

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

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

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

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

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

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

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

proximity criteria are met.

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

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

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

anoroach rnattern. H-oldine and annroach patterns were evaluated for three airnorts within 20 miles

of the lIFP site. These airports include:

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

* Hlobbs Industrial Airpark - 8.5 statute miles east northeast of the proposed facility site:

and

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

proposed facility.

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

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

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

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

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

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

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

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

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

meet SRP proximity criterion I C.

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

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

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

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

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

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

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

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

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

Industrial Airpark meet SRP proximity criterion I C.

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

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

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

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

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

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

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

Airport meet SRP proximity criterion IC.

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

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

the SRP proximity criterion I C. There are three en-route low-level airways passing through the

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

proposed site. Another airway (V291) is 4.7 statute miles from the site. The closest point to the

V102 airway is 6.5 nautical miles firom IIFP site. All three airways meet the SRP proximity

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

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

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

than 10" per year for the SRP 3.5.1.6 acceptance criterion IC.

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

the V68 airway crashing onto the proposed facility was estimated to be 2.7 x 10"8 for CFR 121

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

further consideration in either design or integrated safety analysis.

Department of Energy (DOE) Standard 30 14-2006 (DOE, 2006) offers an alternative analytic

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

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

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

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

metric. Based on the results firom the DOE evaluation, the calculated probability of 3.3 x 10'

crashes per year at the site is less than the DOE evaluation guideline of 1.0 x1 0 6

.Therefore. the

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

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

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

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

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

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

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

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

in the integrated safety analysis.

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The aircraft hazards determination following the methodology in SR.P Section 3.5.1.6 addressed

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

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

number of total operations from both airports. including the military operations, is far below the

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

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

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

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

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

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

from the lIFP site, This is not expected to pose any hazard to the proposed facility, since the

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

3.6.1.5 Acceptance Criterion 1 B, the probability of aircraft accidents is less than an order of

magnitude of l xl10 per year if the plant is at least 5 statute miles from the nearest edge of

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

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

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

military operations.

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

Determination in Section 1.6.

1.6 References

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

2011.

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

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

performed.

Item Hazard Energy Applicable to PHA? Rationale*

Source or Material Yes No

17.1 Airplane X X Considered beyend extreemely

+ .external initiating event.

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SS-5. Background.:

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

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

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

accident sequences caused by credible external events.

Issue.:

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

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

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

Request:

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

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

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

assessing liquefaction potentialfor the site.

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

capacity, and liquefaction potential.

RESPONSE TO REQUEST #SS-5-1: At this time IIFP is providing information in the License

Documentation Impact below regarding the planned procedure, guidance and standards that it

will used to conduct geotechnical and geophysical investigations to characterize the site soil and

to make an assessment.

License Documentation Impact #SS-5-1: A new Section 1.5.4 will be added to the IIFP ISA

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

geophysical investigation and analysis to read as follows:

1.5.4 Geotechnical and Geophysical Investigation and Analysis

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

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

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

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

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

and their use for determiningz soil parameters. is as follows:

0 Perform pathfinder surveys for determination of essential settlement parameters with

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

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

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

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

I Perform critical determination of small strain seismic shear modulus and Poisson Ratio

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

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

determined by the dilatometer and seismic cone penetration test soundings:

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

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

150 feet of depth:

Perform soil sampling in Standard Penetration boreholes to obtain disturbed and

undisturbed soil samples: and

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

The proposed drilling and boring location guidelines are as follows:

* Structures: I boring for every, 2500 square feet,

* Pier foundations: 1 boring for every pier. and

* Roads: I boring for every 500 feet.

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

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

and Geophysical Codes and Standards" for applicable ASTM Standards.

License Documentation Impact #SS-5-1: Revised Section 1.7.4.1 (formerly 1.6.4.1) of the IIFP

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

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

paragraph to Section 1.7.4.1 to read as follows:

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

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

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

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

respectively.

RESPONSE TO REQUEST #SS-5-2: The following is the preliminary determination of the

field-free ground motion response spectra for the IIFP Facility site based on the input 2,500 year

return ground motions and a reasonable assumption of the site's soil conditions of either Site Soil

Class B or Site Soil Class C. The Site Soil Class Will be verified as part of the geotechnical

investigation.

1.0 Determination of Mapped Acceleration Parameters and Seismic Design Category

1.1 Following the procedure outlined in ASCE 7-05, Section 11 the spectral

accelerations for the geographic location of the IIFP Facility may be determined

from the historically-based maps shown in ASCE 7-05, Section 22 with isolines

defining regions subject to varying levels of seismic accelerations. These maps

are reprinted from those constructed in the USGS National Seismic Mapping

Project. These maps show both Short Period (.2-see) and Long Period (1-see)

spectral accelerations for the conterminous United States. They are based upon a

grid spacing of approximately .05' and a Soil Site Class B. As an alternative to

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these maps, the spectral accelerations may more accurately be obtained from the

"JAVA Ground Motion Parameter Calculator" application located on the USGS

website: (http ://earthquake.usgs.gov/research/hazmaps/design).

1.2 From preliminary site visits to the IIFP Facility site and from conversations with

Pettigrew Associates (a licensed engineering firm) located in Hobbs, New

Mexico, it is expected that soil conditions in the area will consist of a layer

approximately two feet in depth of soft caliche over hard caliche rock. For this

reason, the conceptual design Site Soil Class is assumed to be either Site Soil

Class B or Site Soil Class C. Below is an analysis of the determination of the

mapped acceleration parameters for the IIFP Facility site for both Site Soil Class

B and Site Soil Class C. If, after geotechnical analysis, the Site Soil Class is

determined to be other than Site Soil Class B or Site Soil Class C, the mapped

acceleration parameters will be determined using the same procedure as detailed

below and using the Site Soil Class as determined from geotechnical analysis.

1.3 Determination of Mapped Acceleration Parameters and Seismic Design Category

(Site Soil Class B).

The Horizontal Spectral Response Accelerations Ss and S 1 from the JAVA

Application, assuming a Soil Site Class B (Default), 5% critical damping and site

location coordinates ofN32.71', W-103.34' are as follows:

Period Sa

(Sec) (g)

0.2 0.216 (Ss, Site Soil Class B)

1.0 0.041 (SI, Site Soil Class B)

1.3.1 The Horizontal Spectral Response Accelerations SMs and SMI (adjusted

for MCE and local Site Soil Class B) are calculated from ACCE 7-05

equations 11.4-1 and 11.4-2 as follows:

SMs=FaxSs SMI=FvxSl

For Site Soil Class B, Site Soil Coefficients from ASCE 7-05 Table 11.4-

1 and Table 11.4-2 are as follows:

Fa = 1.0 and Fv = 1.0

Period Sa

(Sec) W

0.2 0.216 (SMs, Site Soil Class B)

1.0 0.041 (SMI, Site Soil Class B)

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1.3.2 The Horizontal Design Spectral Response Accelerations SDs and SDI

are calculated using ASCE 7-05 equations 11.4-3 and 11.4-4 as follows.

SDs = 2/3 x SMs SD1 = 2/3 x SM1.

Period Sa

(Sec) fg)

0.2 0.144 (SDs, Site Class B)

1.0 0.027 (SDI, Site Class B)

1.3.3 In accordance with ASCE 7-05 11.6, the Seismic Design Category shall

be determined from the most severe category of Table 11.6-1 relating

Short Period Horizontal Design Spectral Response Acceleration versus

Occupancy Category or Table 11.6-2 relating Long Period Horizontal

Design Spectral Response Acceleration versus Occupancy Category.

1.3.4 Based upon the SDs of 0.144 and an Occupancy Category III, Seismic

Design Category A is selected from Table 11.6-1. Based upon the SD1 of

0.027 and an Occupancy Category III, Seismic Design Category A is

selected from Table 11.6-2. Seismic Design Category A is selected as the

Seismic Design Category for the IIFP Facility assuming a Site Soil Class

B.

1.4 Determination of Mapped Acceleration Parameters and Seismic Design Category

(Site Soil Class C).

1.4.1 The Horizontal Spectral Response Accelerations Ss and S I from the

JAVA Application, assuming a Soil Site Class B (Default), 5% critical

damping and site location coordinates ofN32.71', W-103.34' are as

follows:

Period Sa

(Sec) (g

0.2 0.216 (Ss, Site Soil Class B)

1.0 0.041 (S1, Site Soil Class B)

1.4.2 The Horizontal Spectral Response Accelerations SMs and SM 1 (adjusted

for MCE and local Site Soil Class C) are calculated from ASCE 7-05

equations 11.4-1 and 11.4-2 as follows:

SMs=FaxSs SM1=FvxSl

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For Site Soil Class B, Site Soil Coefficients from ASCE 7-05 Table 11.4-

1 and Table 11.4-2 are as follows:

Fa = 1.2 and Fv = 1.7

Period Sa

(Sec) Wg

0.2

1.0

0.259 (SMs, Site Soil Class C)

0.070 (SMI, Site Soil Class C)

1.4.3 The Horizontal Design Spectral Response Accelerations SDs and SDI

are calculated using ASCE 7-05 equations 11.4-3 and 11.4-4 as follows:

SDs = 2/3 x SMs

Period

(Sec)

0.2

1.0

SDI = 2/3 x SM1.

Sa

WgC

0.173 (SDs, Site Class C)

0.047 (SDI1, Site Class C)

2.0 Determination of Seismic Design Category

2.1 In accordance with ASCE 7-05 11.6, the Seismic Design Category shall be

determined from the most severe category of Table 11.6-1 relating Short Period

Horizontal Design Spectral Response Acceleration versus Occupancy Category

or Table 11.6-2 relating Long Period Horizontal Design Spectral Response

Acceleration versus Occupancy Category.

2.2 Based upon the SDs of 0.173 and an Occupancy Category III, Seismic Design

Category B is selected from Table 11.6-1. Based upon the SDI of 0.047 and an

Occupancy Category III, Seismic Design Category A is selected from Table

11.6-2. The more severe Seismic Design Category B is selected as the Seismic

Design Category for the IIFP Facility assuming a Site Soil Class C.

License Documentation Impact #SS-5-2: None at this time.

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SS-6. Background.:

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

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

accidents that could lead to loss of safety functions. 10 CFR 70. 62(c)(iv) requires the applicant to

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

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

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

or its consequences.

Issue:

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

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

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

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

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

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

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

from aircraft crash hazards.

Request:

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

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

impacts of general aviation planes or helicopters.

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

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

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

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

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

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

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

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

integrated safety analysis.

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

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

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

in response to RAI SS-4.

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SS-7. Backzround:

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

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

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

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

likelihood or its consequences.

Issue:

In LA Section 1. 12. 1, Process Buildings and Process Areas and ISA Summary Sections 2.4,

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

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

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

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

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

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

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

reasonableness of the IIFP proposed design.

Reguest:

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

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

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

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

design codes used for reinforced concrete and steel structures.

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

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

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

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

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

silos, and other mechanical systems.

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

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

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

Process Buildings.

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

motion corresponding to an annual probability of lO-5 on radiological and chemical

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

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

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RESPONSE: (Requests #SS-7-1 through #SS-7-5):

RESPONSE TO REQUEST #SS-7-1: An updated conceptual facility site plan drawing is being

included with this Seismic and Structural RAI response package. Conceptual structural floor plan

drawings of all process buildings showing horizontal cross sections at each floor level are being

provided. Conceptual structural elevation drawings of all the process buildings are also being

furnished.

RESPONSE TO REQUEST #SS-7-2: The following provides the structural design criteria for

the design of concrete and steel structures including their foundations for the Fluorine Extraction

Process and Depleted Uranium De-conversion (FEP/DUP) Plant (IIFP Facility) to be built by

International Isotopes Fluorine Products in Lea County, New Mexico. This section also provides

the methodology that will be used for the structural design of this facility.

Governing Codes and Standards

For the design of structures not housing equipment designated as IROFS, the following codes and

standards will be used:

NMCBC 2009, New Mexico Commercial Building Code

IBC 2009, International Building Code

ASCE 7-05, Minimum Design Loads for Buildings and Other Structures

ACI 3!8-08, Building Code Requirements for Structural Concrete

ACI 530-08/ASCE 5-08/TMS 402-08, Building Code Requirements for Masonry Structures

ANSI/AISC 360-05, Specification for Structural Steel Buildings

AISC Steel Construction Manual 13th Edition

ANSI/AISC 341-05, Seismic Provisions for Structural Steel Buildings

AWS D1.1-2004, Structural Welding Code - Steel, American Welding Society

For the design of those structures housing equipment designated as IROFS, the following codes

and standards will be used:

NMCBC 2009, New Mexico Commercial Building Code

IBC 2009, International Building Code

ASCE 7-05, Minimum Design Loads for Buildings and Other Structures

ANSI/AISC N690-06, Specification for Safety-Related Steel Structures for Nuclear Facilities

ANSI/AISC 360-05, Specification for Structural Steel Buildings

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AISC Steel Construction Manual 13'h Edition

AWS D1.1-2004, Structural Welding Code - Steel, American Welding Society

ACI-349-06, Code Requirements for Nuclear Safety Related Concrete Structures

ASCE 4-98, Seismic Analysis of Safety-Related Nuclear Structures

Materials

All structural materials will conform to the specifications listed below, as a minimum. The latest

version of these standards will be used at the time of procurement of these materials.

a) Structural Steel:

Wide Flange and WT Shapes: ASTM A992 or ASTM A572 Gr. 50

Structural channels, angles: ASTM A36 (unless otherwise noted on drawings)

Plate less than 3/8-inch thick: ASTM A36

Plate 3/8-inch thick to 4-inch thick: ASTM A572, Gr. 50

b) Cold formed steel tubing: ASTM A500, Gr. B; Fy = 46 ksi

c) Hot formed steel tubing: ASTM A501

d) Steel Pipe: ASTM A53, Gr. B

e) Structural Steel Connections:

Primary structural connections will consist of high strength bolting materials as follows:

Bolts: ASTM A325 Type 1 or ASTM A490 Type 1

Nuts: ASTM A563, (Heavy Hex) Grade C or Grade DH

Washers: ASTM F436, Type 1 or ASTM F959 (Direct Tension Indicator)

Secondary field connections limited to stair stringers, ladders, and handrail may consist of the

following materials:

Bo!ts: ASTM A307, Grade A

Nuts: ASTM A563, Grade A Hex

Washers: ASTM F436, Type 1

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Galvanized parts will be connected with galvanized bolts. Galvanizing will be in accordance with

ASTM A 123.

f) Structural steel welding filler standard will be: E70XX Electrodes per AWS Dl.1

g) Concrete:

Cement per ASTM C 150, Type II, Low alkali

Concrete will have the following 28 day compressive strengths as a minimum:

F'c = 4000 psi for structural concrete

F'c = 2000 psi for encasements, thrust blocks, electrical ducts, lean concrete backfill

h) Reinforcing Steel:

Reinforcing bars: ASTM A615, Grade 60 or ASTM A706, Grade 60

Welded wire fabric: ASTM A185

i) Masonry:

Masonry will conform to the NMCBC and the following properties:

Block: ASTM C90 (Type I) Normal Weight; Minimum Compressive Strength of

Concrete Masonry Units (CMU) = 1900 psi

Mortar: ASTM C270, Type S; Minimum Compressive Strength of Masonry and

f'm 1500psi

j) Cast-in-Place Anchor Bolts:

Standard and High Strength Bolting Components:

Bolts: ASTM F1554, Grade 36, 55 or 105

Nuts: ASTM A563, Gr. A or DH (Heavy Hex)

Washers: ASTM F436, Type 1

k) Drilled-in Anchors and Reinforcing Bars:

Expansion Type Anchor: Hilti Kwik Bolt TZ or approved equal

Sleeve Type Anchor: Hilti HSL or approved equal

Undercut Anchor: Hilti HDA Undercut anchor, or approved equal

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I) Handrail:

ASTM A53 Grade B 1-1/2-inch Dia. I.P.S., Sch 40 Handrail, and 2-inch Dia. I.P.S.,

Schedule 40 or Schedule 80 posts

m) Floor Grating and Stair Treads: ASTM A101I1/AIOI IM steel, galvanized

n) Checkered Plate: ASTM A786 /A786M

Bolts and nuts connecting grating, stair treads, or checked plate will conform to ASTM A307

Grade A or approved equal. Grating will be hot-dipped, galvanized after fabrication in

accordance with ASTM A 123.

o) Metal Decking: ASTM A1008 or ASTM A653-94

Fy = 33.0 ksi or higher

Unit design stress < 0.60 Fy, where Fy = 36 ksi maximum

p) Welded Studs:

Type S3L Shear Connectors or Type H4L Headed Concrete Anchors as provided by Nelson, or

approved equal.

Mild Steel Fy = 51 ksi F, = 65 ksi

RESPONSE TO REQUEST #SS-7-3: IIFP Process Buildings will be of braced frame structural

steel construction with spread footings, reinforced concrete floor slabs and metal roofs.

A 3D mathematical finite element model of each process building will be constructed, and a

linear dynamic modal analysis will be performed on each process building, using computer

software SAP 2000, developed by Computer and Structures, Inc. Dynamic analysis will be based

on response spectra method.

Response spectra used for the building analysis will be based on a Soil-Structural Interaction

(SSI) analysis which will be performed for each process building. Foundation/soil/upper

structure will be coupled using a 3D finite element program SASSI. Strain dependent soil

properties will be used based on upper bound, lower bound, best estimate and enveloped soil

parameters. Soil has no potential for the liquefaction under the seismic event.

The methodology for the seismic analysis of the process buildings will be based on the guidelines

provided in ASCE 4-98. Design Basis Earthquake (DBE) for process buildings, peak ground

acceleration (PGA) at the free-field ground surface will be selected for the site that has an

extremely low probability of occurrence based on the site geology and seismology study. Seismic

input ground motions will be smoothed response spectra, conservatively estimated to account for

uncertainties in future earthquake.

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The methodology used to determine the seismic loads, ground acceleration and design parameters

to be used in the design of the non-process buildings and structures will be in accordance with the

requirements of International Building Code and ASCE 7.

RESPONSE TO REQUEST #SS-7-4: Seismic qualification of equipment for active seismic

IROFS will be performed in accordance with the requirements of IEEE Standard 344, 'Seismic

Qualification of Class 1E Equipment' and Regulatory Guide 1.100, 'Seismic Qualification of

Electrical and Mechanical Equipment for Nuclear Power Plants'.

In-structure seismic response spectra for various damping values will be developed at the IROFS

locations from the seismic soil-structure interaction analysis.

Seismic design of the supports and anchorages for IROFS equipment will be based on an

equivalent static approach in accordance with the guidelines provided in ASCE 4-98, Seismic

Analysis of Safety-Related Nuclear Structures. The peak horizontal and vertical acceleration

values will be chosen from appropriate in-structure response spectra. These values will be

increased by a factor 1.5 to account for multi-mode effects.

Equipment such as outdoor elevated tanks, silos, tall scrubbers and stacks will be modeled based

on the finite element method or as a lumped mass stick model. Linear dynamic modal analysis

will be performed. Effect of sloshing will be considered for the fluid containing tanks.

Piping, conduit and other miscellaneous supports and hangers will be evaluated using an

equivalent static approach. The peak horizontal and vertical acceleration values will be chosen

from appropriate in-structure response spectra. These values will be increased by a factor 1.5 to

account for multi-mode effects.

The seismic response from each orthogonal direction of earthquake will be combined using the

SRSS method. Alternatively, the combined seismic response for all three seismic components

may be obtained by using the 100-40-40 rule, as permitted by ASCE 4-98.

Seismic design/qualification of components and support structures mounted at the building grade

elevation, DBE ground motion response spectra will be used.

RESPONSE TO REQUEST #SS-7-5:

1. Design Loads:

a) Dead Loads (D):

Dead loads will be the total weight of materials forming the permanent part of a

building or structure, empty vessels, piping, conduit, cable tray, ductwork, and

equipment, air handling units and other equipment, supports for same, built-in

partitions, insulation, fire protection covering, other permanent fixtures and long term

stored materials.

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b) Live Loads (L) and Roof Live Loads (Lr):

Live loads and roof live loads will be defined as the weight of all movable loads such

as personnel, tools, miscellaneous equipment, movable partitions, hoists, parts of

dismantled equipment and in-process material.

c) Pressure Differential Loads (Pa):

Maximum differential pressure loads generated by a postulated design basis accident

or pipe break.

d) Snow Loads (S):

The design-basis ground snow load for IIFP structures will be 10 lb/ft2 as specified in

ASCE 7-05. There is also a rain-on-snow surcharge of 5 lb/ft2 recommended by this

standard which will, be considered. Since IIFP is using DOE Performance Category 3

criteria for its risk assessment of process buildings, an importance factor of 1.2 will be

used to calculate the final design-basis snow load (DOE-1020-2002).

e) Rainfall Loading (R):

For all buildings, rainwater will be carried away from roof surfaces using rain gutters

connected to the storm drains and intermittent downspouts along the building

perimeter. Provisions for minimizing the potential for ponds occurring on roofs will be

achieved by using metal sloped roofs.

f) Flood Loading (F):

The IIFP site does not fall within mapped 100-yr or 500-yr floodplains. The site is

located in a semi-arid location with limited bodies of water.

Since the grade level of the Facility is set substantially above the maximum flood level

for rivers, dams, lakes and other large bodies of water, the only potential flooding of

the Facility results from local intense rainfall. Protection against local intense rainfall

flooding is provided by natural contour or site grading to provide positive flows away

from the buildings and by installing the floor levels of process buildings above the

design basis flood level from a local intense rainfall. Flood Loading (F) has been

determined to be negligible compared with other loads,, but will be converted to an

equivalent hydrostatic load in accordance with ASCE 7-05, Paragraph 5.4-3

"Hydrodynamic Loads" and will be included in the calculations. See official response

toSS RAI-2 for analysis of Flood Loading.

g) Lateral Earth Pressure (H) as Applicable to Foundation Design:

The lateral earth pressure coefficients, soil density and ground water table will be

obtained by geotechnical study.

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h) Thermal Loads (To and Ta):

Thermal loads are defined as self-straining forces arising from contraction or expansion

resulting from temperature change or differential temperature between the opposite

exposed surfaces of a structural element. Thermal loads may result from either

operating (To) or accidental environmental (Ta) conditions and will be determined

accordingly.

i) Straight Wind Loads (W):

Per IBC 2006, straight wind loads for structures containing no IROFS will be

calculated in accordance with the provisions of ASCE 7-05. Wind design will be based

on the following:

Exposure C- Open terrain with scattered obstructions

V = 90 mph

Iw = 1.00 - Based on buildings classified as Category II occupancy

Kzt = 1.0

Wind loads for structures containing IROFS will be calculated in accordance with the

provisions of DOE-1020-2002, for a 10,000-year period of recurrence.

Exposure C- Open terrain with scattered obstructions

V = 135 mph

Iw = 1.15 - Based on buildings classified as Category III occupancy

Kzt = 1.0

j) Extreme Tornado Winds (Wt):

Process buildings and structures housing IROFS equipment will not be designed to

withstand extreme tornado wind loadings, which include tornado missiles and

extreme straight wind. An analysis of wind and tornado loading determined that

straight wind loads bound tornado wind loads for the IIFP Facility site. See official

response to SS RAI-2 for details of this analysis.

k) Seismic Loads:

International Building Code Earthquake (E):

All facility structures containing no IROFs will be designed to withstand the

earthquake loads defined in Sections 1614 to 1623 of the International Building

Code. Every structure is designed to resist the total horizontal and vertical seismic

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forces acting non-concurrently in the direction of each of the main axes of the

structure. Seismic Use Group = II and Seismic Importance Factor IE = 1.25 based on

buildings classified as Category III occupancy.

Design Basis Earthquake (Es):

Process buildings and structures housing IROFs equipment will be designed to the

Design Basis Earthquake (Es). The peak ground acceleration and Ground Response

Spectra will be developed based on DOE-1020-2002 performance criteria for a PC-3

equivalent structure and corrected for site soil class as determined in the geotechnical

investigation.

2. Load Combinations for Non-Process Buildings:

For structural design of all facility structures and buildings that do not contain IROFs, the

following load combinations will be considered in accordance with ASCE 7-05:

a) Concrete Load Combinations:

1. 1.4(D+ F)

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

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

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

5. 1.2(D) + 1.E + L + 0.2S

6. 0.9(D) + 1.6W + 1.6H

7. 0.9(D) + L.OE + 1.6H

Notes:

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

occupancies in which live load is less than or equal to 100 pounds per square foot (psf), with

the exception of garages or areas occupied as places of public assembly.

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

lateral earth pressure provides resistance to other forces, it will not be included in H but will

be included in the design resistance.

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

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

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b) Steel Load Combinations:

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

listed above or the Allowable Strength Design (ASD) load combinations listed below

can be used:

1. D+F

2. D+H +F +L+(ToorTa)

3. D+H +F+(LrorSorR)

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

5. D+H +F+(WorO.7E)

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

7. 0.6(D) + W + H

8. 0.6(D) + 0.7E + H

Note:

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

the sloped roof snow load (ps).

3. Load Combinations for Process Buildings:

For process buildings and structures which house IROFS equipment, the following load

combinations will be considered:

a) Concrete Load Combinations per ACI 349-06:

Normal Load Combinations

1. 1.4 (D + F + Ro) + To

2. 1.2 (D + F +To+ Ro) + 1.6 (L +H)+ 1.4 C + 0.5 (Lr or S or R)

3. 1.2(D+F+To+Ro)+0.8(L+H)+ 1.4C+ 1.6(LrorSorR)

Severe. Environmental Load Combinations

4. Not used, since operating basis earthquake load (earthquake load for which

plant's power production equipment is designed to remain functional without

undue risk to public health and safety) is not applicable. The emergency

generator and UPS system are designed to remain functional during any

postulated natural phenomena hazard event.

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5. 1.2 (D + F + Ro) + 1.6 (L + H + W)

Extreme Environmental and Abnormal Load Combinations

6. 1.0 (D +F + C + H +Ta+ Ra+ Es)+ 0.8L

7. Not used since straight wind (W) governs over tornado wind (Wt) for the Facility

site due to probability of occurrence.

8. 1.0 (D + F + C + H + Ta+ Ra) + 1.2 Pa+ 0.8L

9. Not used since no postulated high energy pipe reaction (Yr), jet impingement

(Yj) or pipe missile impact (Ym) are expected during a design basis natural

phenomena hazard.

Preliminary analysis has shown that flood load (F) is negligible for the design of the IIFP process

buildings.

Ra, Ro and To and Ta are expected to be negligible.

Rain load (L) on process building roofs is negligible, since all process building roofs are sloped

metal (5/12) pitch minimum with no parapets or other appurtenances that might inhibit roof

drainage.

Crane load (C) is only applicable in Autoclave Building.

b) Steel Load Combinations Per AISC N690-06 if Load and Resistance Factor

Design (LRFD) is used:

Normal Load Combinations

1. 1.4 (D + Ro) + To +C

2. 1.2 (D + Ro + To) + 1.6L + .4C + 0.5 (Lr or S or R)

3. 1.2 (D + Ro + To) + 1.6 (Lr or S or R) + 0.8L + .4C

Severe Environmental Load Combinations

4. 1.2 (D + Ro) + 1.6W + 0.8L + C + 0.5 (Lr or S or R) + To

5. Not used, since operating basis earthquake load (Eo) (earthquake load for which

plant's power production equipment is designed to remain functional without

undue risk to public health and safety) is not applicable. The emergency

generator and UPS system are designed to remain functional during any

postulated natural phenomena hazard event.

Extreme Environmental and Abnormal Load Combinations

6. D+0.8L+C-+ To+Ro+Es

7. Not used since straight wind (W) governs over tornado wind (Wt) for the Facility

site due to probability of occurrence.

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8. D+0.8L+C+1.2Pa+Ra+Ta

9. Not used since no postulated high energy pipe reaction (Yr), jet impingement

(Yj) or pipe missile impact (Ym) are expected during a design basis natural

phenomena hazard.

c) Steel Load Combinations Per AISC N690-06 if Allowable Strength Design (ASD) is

used:

Normal Load Combinations

1. D+L+Ro+To+C

2. D+(LrorSorR)+Ro+To+C

3. D + 0.75L + 0.75(Lr or S or R) + To +C

Severe Environmental Load Combinations

4. D + Ro + W +.75L + C + 0.75(Lr or S or R) + To

5. Not used, since operating basis earthquake load (Eo) (earthquake load for which

plant's power production equipment is designed to remain functional without

undue risk to public health and safety) is not applicable. The emergency

generator and UPS system are designed to remain functional during any

postulated natural phenomena hazard event.

Extreme Environmental and Abnormal Load Combinations

6. D+L+C+Ro+To+Es

7. Not used since straight wind (W) governs over tornado wind (Wt) for the Facility

site due to probability of occurrence.

8. D+L+C+Pa+Ra+Ta

9. Not used since no postulated high energy pipe reaction (Yr), jet impingement

(Yj) or pipe missile impact (Ym) are expected during a design basis natural

phenomena hazard.

4. Foundations:

Based on the preliminary soil condition, shallow foundations are proposed for the structures. All

major equipment and structure foundations will be designed for a minimum frost penetration of

12 inches. The final foundation type will be determined after the geotechnical study is completed.

Foundations for structures will be designed to provide a factor of safety against bearing failure of

3 for static loads and 1.1 for static loads + dynamic loads. These analyses will be based on unfactored loads, including Extreme Environmental Load Es. Settlement will be calculated and

checked against the allowable settlement.

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All foundations will be checked against sliding and overturning due to building code earthquake

(E for buildings and structures containing no IROFs), design basis earthquake (Es for process

buildings and structures containing IROFs), and design basis wind (W) (90 mi/hr for buildings

and structures containing no IROFs) (135 mi/hr for process buildings and structures containing

IROFs) in accordance with the following:

Minimum Factors of Safety:

Load Combination Overturning Sliding

D+H+E 1.5 1.1

D + H +W 1.5 1.1

D+H+Es 1.1 1.1

Soil bearing capacity, soil sub-grade modulus, coefficient of friction against sliding, lateral earth

pressure coefficients and other critical parameters will be determined by geotechnical study.

5. Structural Design Methodology:

Detailed 3-D Finite element models of the structures will be developed using SAP2000. Static

and linear dynamic analysis will be performed on the finite element models.

For IBC earthquake load (E), static analysis will be used. Every structure is designed to resist the

total horizontal and vertical seismic forces acting non-concurrently in the direction of each of the

main axes of the structure. Seismic Use Group = II and Seismic Importance Factor IE = 1.25

based on buildings classified as Category III occupancy.

For Design Basis Earthquake (Es), linear dynamic response spectra analysis will be performed.

Three orthogonal components of earthquake ground motions (two horizontal and one vertical)

will be considered. Responses from the various direction components shall be combined in

accordance with ASCE 4. Wind pressure on the buildings based on the design wind speed will be

distributed in accordance with ASCE 7.

For all the load combinations, the structural strength and deformations will be evaluated and

checked against the relevant code requirements.

Good design detailing practice and consistency in accordance with the relevant codes will be

followed to ensure adequate ductility of the structures.

License Documentation Impact: (Request # SS-7-1): Add the following drawings to the

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

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

Application:

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

1 00-C-000 1 Rev E.

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2. Add conceptual structural floor plans, conceptual equipment layout plans and

conceptual elevation drawings of process buildings. (Drawings: 400-M-1201-D, 400-M1202-C, 400-M-1203-A, 500-M-1201-C, 500-M-1202-D and 500-M-1203-A).

License Documentation Impact (Request #SS-7-2): The codes and standards will be added to

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

IIFP Facility buildings with emphasis on seismic design.

License Documentation Impact (Requests #SS-7-3 through #SS-7-5): None at this time.

RESPONSE TO REQUEST #SS-7-6: Based upon guidance provided in NUREG- 1520, an

assessment of building damage and the resulting radiological and chemical consequences from a

seismic event that has a I x 10.5 annual probability is not required. The consequences of a I x 10-5

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

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

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

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

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

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

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

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

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

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

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

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Table 5-8. Initiating Event Failure Frequency Index Values

Failure

Frequency Based on Evidence Commelits

Index*

-6 External Event with frequency of <1 0 6

/yr 4"nitiaiflg e k Ie" ne-I-ROF ededExternal Event with frequency of>10 6

/yr ifinitiating event, n. IROFS needed.

and <10 5/yr

-4 No occurrences in 30 years for hundreds of Ra..ely .an bejustified by evidenc.e.

similar systems in industry

-3No occurrences in 30 years for tens of Requires robust multiple pas.sive f.ailures system to or r'es-,t failure in;of a

similar systems in industry ad.b system..............

advrse081seuen~ees

-2 No occurrences of this type in this facility in Applicable r p si .. s te .. falr. -- 30 years ______________pssivesyste_________

-1 A few occurrences during facility lifetime Applicable for routine

0 Occurs every I to 3 years App, iea.b. . fOr otperator errorS, l... Of

power%, oV oF routinie /thef s)'Steml flurle.

I Several occurrences per year

2 Occurs every week or more often

*Based on the example provided in NUREG-1520. Indices less than (more negative than) -1 should not be

assigned unless the configuration management, auditing, and other management measures are high quality.

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Table 5-9. Likelihood Categories

Event Likelihood Probability of Occurrence Qualitative Description

Likelihood Category

Not Unlikely 3 Greater than 10-4 per event per year

Unlikely 2 Between 1 0 -4 and 10-5 per event per Consequence Category 2

year accidents must be "unlikely."

Consequence Category 3

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

unlikely."

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

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

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

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

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

Table 5-10. Risk Matrix and Risk Index Values

Likelihood of Occurrence

Severity ikelihood Category L LikelihoodCategory12Category ikelihood Category 2 Likelihood3 of Coseuece 1Unlikely NoteUnlkel

Highly Unlikely (2)Not Unlikely

(1)(3)

Category 3 Acceptable Risk Unacceptable Risk' Unacceptable

High Consequence Risk

(3) 3 16

Category 2 Acceptable Risk Acceptable Risk >l S Unaccýptablej i 

Intermediate Consequence 1 iý,k

(2 ) 2 4 6

Category I Acceptable Risk Acceptable Acceptable

Low Consequence Risk Risk

(3) 1

2 3

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

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

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

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

earthquake, we still meet the criteria for acceptable risk.

License Documentation Impact #SS-7-6: The "Comments" column of Table 5-8 of the IIFP

ISA Summary will be deleted as shown in the Request #6 Response shown above.

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SS-8. Background:

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

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

design of the facility.

Issue:

In LA Section 2.2.7, DB contractor, the applicant stated that it will rely on the DB contractor to

ensure that design meets all applicable Federal, State, and local codes and standards required

for the startup stage of the project. However, the applicant did not provide this list.

Request.

Provide a list of applicable Federal, State, and local codes and standards that the DB contractor

will use for the startup stage of the project.

RESPONSE: The following is a list of applicable Federal, State, and local codes and standards

that the DB contractor will use during the detailed design, construction and startup stage of the

project to ensure adequate protection against natural phenomena, environmental conditions, and

dynamic effects. The DB contractor will also ensure, as part of the written contract, that design

meets these applicable federal, state and local codes and standards.

License Documentation Impact: Revise Section 2.3 "Building Codes and Standards" of the

IIFP ISA to replace existing building codes with an updated and expanded list of building codes.

After Table 2-2 following the second paragraph of 2.3, insert new Sections 2.3.1, 2.3.2, 2.3.3,

2.3.4, and 2.3.5 to read as follows:

2.3 Building Codes and Standards

The design and construction of the on-site IIFP Facility buildings conform to applicable building

codes and standards. The basie construction codes applied include:

intercnatioal Building Code (IBC) as amended by !he NFP 3(C,

N UniFfPA Mechanical Code (UMC) a- amended by the New Mexi(P Mechanical C.7e

" Unifrmi Plumbing Code (UPC) as amended by the New M~exico Plumibinlg Code

O fic nta e tional Energy Conservatuin Code Is (RA ) as amended by the New Me1i2, E0ergy

Conservation Code (NMEGC).

" Intei-national Fire Code (IFC),

*NFPA 10 1 (-ifIe Safety Code), anld-

*Nationial Eleetrieal CoAde as aend b1 the. New M~eico Electrical Codc (NNMEC).

Codes foqllowed tbrf conStruction are thie latest editions, as adopted by the State of New Mexico.

Table 2-2 below is a listing of code conformance for buildings located on site based on New

Mexico Commercial Building Code (NMCBC,. 244~62009), NFPA 13 (NFPA, 2007a20 10), and

NFPA 10 1 (NFPA, 2007Kb209).

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2.3.1 General Buildine Codes and Standards

2009 New Mexico Commercial Building Code (adopts by reference the 2009

International Building Code (IBC) with amendments),

2009 New Mexico Energy Conservation Code (adopts by reference the 2009

International Energy Conservation Code (OECC) with amendments),

2009 New Mexico Plumbing Code (adopts by reference the 2009 Uniform

Plumbing Code (UPC) with amendments),

2009 New Mexico Mechanical Code (adopts by reference the 2009 Uniform

Mechanical Code (UMC) with amendments),

2008 New Mexico Electrical Code (adopts by reference the 2008 national

Electrical Code (NEC) with amendments),

2007 New Mexico Electrical Safety Code (adopts by reference the 2007

National Electrical Safety eCode (NESC) with amendments),

2009 International Fire Code,

2010 American Society for Mechanical Engineering (ASME) Section VIII,

Division I Design and Fabrication of Pressure Vessels,

2010 ASME B3 1 .1 "Power Piping",

2009 ASME B3 1.3 "Process Piping",

2010 ASME B31.5 "Refiigeration Piping and Heat Transfer Components."and

2008 ASME B331.9 "Building Services Piping".

2.3.2 Structural and Foundation Codes and Standards

ASCE 7-05

ACI 318-08

ACI 530-08/

ASCE 5-08/

TMS 402-08

ANSI/ AISC 360-05

AISC

ANSI/ AISC 341-05

AWS D1.1-2004

ANSI/AISC N690-06

ACI-349-06

ASCE 4-98

Minimum Design Loads for Buildings and Other Structures,

Building Code Requirements for Structural Concrete.

Building Code Requirements for Masonry Structures,

Building Code Requirements for Masonry Structures,

Building Code Requirements for Masonry Structures.

Specification for Structural Steel Buildings,

Steel Construction Manual 13' Edition.

Seismic Provisions for Structural Steel Buildings,

Structural Welding Code - Steel, American Welding Society.

Specification for Safety-Related Steel Structures for Nuclear

Facilities

Code Requirements for Nuclear Safety Related Concrete

Structures, and

Seismic Analysis of Safety-Related Nuclear Structures.

2.3.3 Geotechnical and Geophysical Codes and Standards

Editions listed are shown exactly as designated by ASTM organization as being active editions. If

the standard identifier number does not have a date in parenthesis, the active date is designated by

the last two digits in the standard identifier number.

ASTM D420-98 (2003) Standard Guide to Site Characterization for Entgineering, Design, and

Construction Purposes,

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ASTM D421-85 (2007)

ASTM D422-63 (2007)

ASTM D854-10

ASTM D 1140-00 (2006)

ASTM D1452-09

ASTM D1557-09

ASTM D1586-08a

ASTM D 1883-07e2

ASTM D2216-10

ASTM D2487-10

ASTM D2488-09a

ASTM D2850-03a (2007)

ASTM D4220-95 (2007)

ASTM D43 18-10

ASTM D4428-07

ASTM D4633-10

ASTM D4767-11

ASTM D5434-09

ASTM D5778-07

ASTM D6635-01 (2007)

ASTM D6429-99 (2006)

Standard Practice for Dry Preparation of Soil Samples for Particle Size

Analysis and Determination of Soil Constants,

Standard Test Method for Particle Size Analysis of Soils.

Standard Test Method for Specific Gravity of Soils,

Standard Test Method for Amount of Material in Soils Finer than the

No. 200 Sieves,

Standard Practice for Soil Investigation and Sampling by Auger

Borings,

Test Method for Laboratory Compaction Characteristics of Soil Using

Modified Effort (56,000 ft-lb/ft3 (2,700 KN - m/in)),

Standard Method for Penetration Test and Split-Barrel Sampling of

Test Method for California Bearing Ratio (CBR) of Laboratory,-

Compacted Soils,

Standard Test Method for Laboratory Determination of Water

(Moisture) Content of Soil and Rock.,

Standard Classification of Soils for Engineering Purposes (Unified Soil

Classification System),

Standard Practice for Description and Identification of Soils (Visual

Manual Procedure),

Test Method for Unconsolidated, Un-drained Strength of Cohesive

Soils in Tria~xial Compression,

Standard Practices for Preserving and Transporting Soil Samples,

Standard Test Method for Liquid Limit, Plastic Limit, and Plasticity

Index of Soils.

Standard Test Method for Cross-hole Seismic Testing,

Standard Test Method for Energy Measurement for Dynamic

Penetrometers,

Standard Test Method for Consolidated-Un-drained Triaxial

Compression Test on Cohesive Soils,

Guide for Field Logging of Subsurface Explorations of Soil and Rock,

Standard Test Method for Performing Electronic Friction Cone and

Piezocone Penetration Testing of Soils,

Standard Test Method for Performing the Flat Dilatometer

(SUPPLIER shall implement method exceptions cited in Subpart 3.2.6

of this Specification because of obsolescence of major elements in

ASTM D6429), and

Standard Guide for Selecting Surface Geophysical Methods.

2.3.4 NFPA Codes and Standards

NFPA 10-2010 Portable Fire Extinguishers,

NFPA 13-2010 Installation of Sprinkler Systems.

NFPA 14-2010 Standard for the Installation of Standpipe and Hose Systems,

NFPA 15-2007 Standard for Water Spray Fixed Systems for Fire Protection,

NFPA 20-2010 Installation of Stationary Pumps for Fire Protection,

NFPA 22-2008 Water Tanks for Private Fire Protection.

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NFPA 24-2010 Installation of Private Fire Service Mains and Their Appurtenances.

NFPA 30-2008 Flammable and Combustible Liquids Code,

N FPA 45-2011 Fire Protection for Laboratories Using Chemicals,

NFPA 54-2011 National Fuel Gas Code,

NFPA 55-2010 Storage, Use and Handling of Compressed Gases and Cryogenic Fluids

in portable and Stationary Containers, Cylinders and Tanks,

NFPA 70-2011 National Electric Code,

NFPA 70E-2009 Standard for Electrical Safety in the Workplace®,

NFPA 72-2010 National Fire Alarm Code,

NFPA 80-2010 Standard for Fire Doors and Other Opening Protectives,

NFPA 80A-2007 Recommended Practice for Protection of Buildinvs from Exterior Fire

Exposures,

NFPA 85-2011 Boiler and Combustion Systems Hazards Codes,

NFPA 90A-2009 Installation of Air-conditioning and Ventilating Systems,

NFPA 90B-2009 Installation of Warm Air Heating and Air-conditioning Systems,

NFPA 91-2010 Standard for Exhaust Systems for Air Conveying of Vapors, Gases,

Mists, and Noncombustible Particulate Solids,

NFPA 101-2009 Life Safety Code,

NFPA 110-2010 Emergency and Standby Power Systems,

NFPA 220-2009 Standard on Types of Building Construction

NFPA 221-2009 Standard for High Challenge Fire Walls, Fire Walls, and Fire Barrier

Walls,

NFPA 251-2006 Standard Methods of Tests of Fire Resistance of Building Construction

and Materials,

NFPA 430-2004 Storage of Liquid and Solid Oxidizers.

NFPA 600-2010 Standard on Industrial Fire Brigades,

NFPA 780-2011 Standard fior the Installation of Lightning Protection Systems,

NFPA 801-2008 Standard for Fire Protection for Facilities Handling Radioactive

Materials, and

NFPA 1410-2010 Standard on Training for Initial Emerg;ency Scene Operations

2.3.5 Instrumentation and Controls Codes and Standards

The criteria in the following regulatory guides and standards will be used to ensure that the

instrumentation and control IROFS will be designed to monitor and control their behavior:

NRC Regulatory Guide 1.100-

2009

NRC Regulatory Guide 1.105-

1999

NRC Regulatory Guide 1.118-

1995

NRC Regulatory Guide 1.152-

2006

NRC Regulatory Guide 1.153-

1996

"Seismic Qualification of Electric and Mechanical

Equipment for Nuclear Power Plants,"

"Setpoints for Safety-Related Instrumentation

"Periodic Testing of Electric Power and Protection

Systems."

Criteria for Digital Computers in Safety Systems of

Nuclear Power Plants" (Endorses IEEE Std. 603-

"Criteria for Safety Systems" (Endorses IEEE Std.

603-2009).

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NRC Regulatory Guide 1. 168-

2004

NRC Regulatory Guide 1.169-

1997

NRC Regulatory Guide 1.170-

1997

NRC Regulatory Guide 1.171-

1997

NRC Regulatory Guide 1.172-

1997

NRC Regulatory Guide 1.173-

1997

NRC Regulatory Guide 1.180-

2003

NRC Regulatory Guide 1.209-

2007

NRC Regulatory Guide 1.53-2003

"Verification, Validation, Reviews and Audits for

Digital Computer Software Used in Safety Systems

of Nuclear Power Plants " (Endorses IEEE Std.

1012-1998),

"Corfiguration Management Plans for Digital

Computer Software Used in Safety Systems of

Nuclear Power Plants" (Endorses IEEE Std. 828-

19901

"Software Test Documentation for Digital

Computer Software Used in Safety Systems of

Nuclear Power Plants" (Endorses IEEE Std. 829-

1983).

"Software Unit Testing for Digital Computer

Software Used in Safety Systems of Nuclear Power

Plants" (Endorses IEEE Std. 1008-1987).

"Software Requirements Specifications for Digital

Computer Software Used in Safety Systems of

Nuclear Power Plants" (Endorses IEEE Std. 830-

1993).

"Developing Software Life Cycle Processes for

Digital Computer Software Used in Safety Systems

of Nuclear Power Plants" (Endorses IEEE Std.

1074-1995),

"Guidelines for Evaluating Electromagnetic and

Radio-Frequency Interference in Safety-Related

Instrumentation and Control Systems," " (Endorses

IEEE Std. 1050-1996, IEC Std. 61000-2005, IEEE

Std. C62.41-1991, and MNil Std. 461 F-2007),

"Guidelines for Environmental Qualification of

Safety-Related Computer-Based Instrumentation

and Control Systems in Nuclear Power Plants,"

"Application of the Single-Failure Criterion to

Safety Systems" (Endorses IEEE Std. 603-2009),

"Setpoints for Nuclear Safety-Related

Instrumentation,"

"IEEE Standard for Qualifying Class I E

Equipment for Nuclear Power Generating Stations"

"IEEE Standard Installation, Inspection. and

Testing Requirements for Power Instrumentation.

and Control Equipment at Nuclear Facilities."

"IEEE Standard Criteria for Periodic Surveillance

Testing of Nuclear Power Generating Station

Safety Systems,"

"IEEE Recommended Practices for Seismic

Qualification of Class I E Equipment for Nuclear

Generating Stations,"

"IEEE Standard Criteria for Independence of Class

I E Equipment and Circuits,"

"IEEE Standard Criteria for Safety Systems for

ANSI/I SA-67.04.01-2006

IEEE Std. 323-2003

IEEE Std. 336-2010

IEEE Std. 338-2006

IEEE Std. 344-2004

IEEE Std. 384-2008

IEEE Std. 603-2009

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IEEE 7-4.3.2-2010

IEEE 730-2002

NUREG-0800-2011

NJUREG/CR-6090-1993

Branch Technical Position HICB11-1997

Branch Technical Position HICB17-1997

Nuclear Power Generating Stations."

"IEEE Standard Criteria for Digital Computers in

Safety Systems of Nuclear Power Generating

Stations."

"IEEE Standard for Software Quality Assurance

Plans,"

"Standard Review Plan for the Review of Safety

Analysis Reports for Nuclear Power Plants,"

"The Programmable Logic Controller and its

Application in Nuclear Reactor Systems,

"Guidance on the Application and Qualification of

Isolation Devices," and

"Guidance on Self-Test and Surveillance Test

Provisions."

The most recent versions of the regulatori guides and Branch Technical Positions adopted by the

NRC will be used at the time of the Instrumentation and Controls systems detail design.

License Documentation Impact: A new Section 3.1.4, "Codes and Standards" will be added to

the IIFP License Application Chapter 3 to include the above referenced codes and standards that

are provided in the IIFP ISA Section 2.3.

License Documentation Impact: The former 6th paragraph of Section 1.1.2 of the IIFP License

Application, Revision A, will be revised to read as follows:

1.1.2 Facility Description

See ISA Summary Section 2.3 for a list of applicable Federal, State, and local codes and

standards that the Design and Build (DB) contractor will use during the detailed design,

construction and startup stage of the proiect to ensure adequate protection against natural

phenomena, environmental conditions, and dynamic effects. The DB contractor will also ensure,

as part of the written contract, that design meets these applicable federal, state and local codes

and standards. Buildings, lighting, fire protection, and building support systems are designed in

accordance with latest revisions, of building and construction codes including where

applicable the National Fire Protection Association (NFPA) standards, local and State

codes, and related codes and standards. A list of NFPA Standards is repeated in Chapter 7 of

the LA, Table 7-1.

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

License Documentation Impact: The last paragraph of Section 1.1.2.1 of the IIFP License

Application, Revision A, will be revised this RAI will supersede RAI GI-6B to read as follows:

1.1.2.1 Process Buildings and Process Areas

The process buildings are classified per NFPA 13 as Ordinary Group 2 and are protected with 100

percent coverage, wet-type fire protection sprinkler systems with Class I standpipes between

floors in all exit stairways of multi-story buildings- (NFPA, 2007). Further infonnation is

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provided for code construction conformance requirements in the IIFP Integrated Safety Analysis

Summary. Section i.23. IIFP will contract and use a Design and Build (DB) contractor for detail

design, engineering and construction of the IIFP Facility.

License Documentation Impact: The last paragraph of Section 4.4.2 of the IIFP ISA Summary

will to read as follows:

4.4.2 Natural Phenomena Hazards

Engineering design requirements for all active and passive IROFS will include adequate

protection from natural phenomena events. Seismic, wind, and lightning hazards will be

specifically addressed through implementation of building code design requirements as listed in

Section 2.3. "'•s : rý ........... ..... R..al .d -ce .. e, ..-..... ad.. the -byrI 2..,.. Ne lie..

(,....,T-eia Bulii Ge& (IBC', 200).C ASC2iw 7 0-A (44inimum-. Dej~ I~ad for,.- Bidi.4AI,.R, a-.jA

PrDeeien +'.'ste (FPDA, 20 2 .Table 4-9-10 and Table 4-4-0-1 I document examples of how

the design incorporated natural phenomena hazards for engineered IROFS.

License Documentation Impact: Revise references in Section 2.6 to reflect the updated

versions of building codes to read as follows:

2.6 References

IIFP, 2009. International Isotopes Fluorine Products, Inc., "License Application for FEP/DUP

Facility." inteignatio'al isetepes Flucrine Products,_2009.

NFPA, 2407a210. National Fire Protection Association "NFPA 13, Installation of Sprinkler

Systems." Quincy, MA, MA : National Fire Protcction Association, 2W072010a.

NFPA, 2007b2009. National Fire Protection Association."NFPA 101, Life Safety. Life Safety

Code." Quincy, MA,-M-A-: National Fire Pretection Association, 20072009b.

NMCBC, 20062009. New Mexico Commerical Building Code, Title 14, "Housing and

Construction," Chapter 7, Building Codes General Part 2. s.l. :

http://www.nmcpr.state.nm.us/nmac/parts/title I4/14.007.0002.htm, 4062)009.

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