July 30, 2010 

MEMORANDUM TO: Thomas G. Hiltz, Chief 

 Advanced Fuel Cycle, Enrichment 

 and Uranium Conversion Branch 

 Division of Fuel Cycle Safety 

 and Safeguards 

 Office of Nuclear Material Safety 

 and Safeguards 

 

FROM: Matthew Bartlett, Project Manager /RA/ Y. Faraz for

 Advanced Fuel Cycle, Enrichment 

 and Uranium Conversion Branch 

 Division of Fuel Cycle Safety 

 and Safeguards 

 Office of Nuclear Material Safety 

 and Safeguards 

SUBJECT: JULY 06 - 08, 2010, SUMMARY OF SITE VISIT TO CONDUCT 

INEGRATED SAFETY ANALYSIS HORIZONTAL AND VERTICAL 

SLICE AND DISCUSSION DRAFT REQUESTS FOR 

ADDITIONAL INFORMATION WITH INTERNATIONAL 

ISOTOPES INC. (TAC NO. L32739) 

 On July 6-8, 2010, U.S. Nuclear Regulatory Commission staff met with International 

Isotopes Inc. staff to discuss the Integrated Safety Analysis documentation for the International 

Isotopes Fluorine Products Facility proposed to be located in Lea County, New Mexico. The 

Meeting Summary is enclosed and contains no proprietary or classified information. 

Docket No.: 40-9086 

Enclosure: As stated 

cc: 

John J. Miller, CHP 

4137 Commerce Circle 

Idaho Falls, ID 83401 

CONTACT: Matthew Bartlett, FCSS/NMSS 

 301-492-3110
MEMORANDUM TO: Thomas G. Hiltz, Chief 

 Advanced Fuel Cycle, Enrichment 

 and Uranium Conversion Branch 

 Division of Fuel Cycle Safety 

 and Safeguards 

 Office of Nuclear Material Safety 

 and Safeguards 

 

FROM: Matthew Bartlett, Project Manager /RA/ Y. Faraz for

 Advanced Fuel Cycle, Enrichment 

 and Uranium Conversion Branch 

 Division of Fuel Cycle Safety 

 and Safeguards 

 Office of Nuclear Material Safety 

 and Safeguards 

SUBJECT: JULY 6-8, 2010, SUMMARY OF SITE VISIT TO CONDUCT INEGRATED 

SAFETY ANALYSIS HORIZONTAL AND VERTICAL SLICE AND DISCUSSION 

DRAFT REQUESTS FOR ADDITIONAL INFORMATION WITH 

INTERNATIONAL ISOTOPES INC. (TAC NO. L32739) 

 On July 6-8, 2010, U.S. Nuclear Regulatory Commission staff met with International Isotopes Inc. staff 

to discuss the Integrated Safety Analysis documentation for the International Isotopes Fluorine Products 

Facility proposed to be located in Lea County, New Mexico. The Meeting Summary is enclosed and contains 

no proprietary or classified information. 

Docket No.: 40-9086 

Enclosure: As stated 

cc: 

John J. Miller, CHP 

4137 Commerce Circle 

Idaho Falls, ID 83401 

CONTACT: Matthew Bartlett, FCSS/NMSS 

 301-492-3110

DISTRIBUTION:

FCSS r/f DDorman, FCSS CHaney, NMSS MWeber, NMSS DMcIntyre, OPA SFleger, RES 

MSheikh, RII JHenson, RII RTrojanowski, RII TGody, RII SHarwell, NRR JDeJesus, FCSS 

DSeymour, RII JWeil, OCA GChapman, NMSS RVirgilio,OSP CSafford, OGC IDinitz, NRR 

GKulesa, FSME HGraves, RES DRahn, FCSS YFaraz, FCSS MTschiltz, FCSS MNorris, NSIR 

TPham, FCSS LSilvious, NSIR DArroyo, FCSS TJohnson, FCSS KEverly, NSIR KKline, FSME 

BPurnell, FCSS JDowns, FCSS DHase, NSIR BWray, NSIR JBongarra, NRO GTuttle, FCSS 

SEchols, FCSS MAdams, FCSS RWescott, FCSS MKotzalas, FCSS MDusaniwskyj, NRR 

 

ML102070207 

OFFICE NMSS/AFCB NMSS/AFCB NMSS/AFCB 

NAME MBartlett YFaraz for TRichmond THiltz YFaraz for

DATE 7/27/10 7/30/10 7/27/10 

OFFICIAL RECORD COPY 
Enclosure 

MEETING SUMMARY 

SUMMARY OF CLOSED MEETING WITH 

INTERNATIONAL ISOTOPES INC. FLUORINE PRODUCTS INC. 

ON INTEGRATED SAFETY ANALYSIS 

LICENSEE: International Isotopes Inc. 

 4137 Commerce Circle 

 Idaho Falls, Idaho 83401 

DOCKET NO.: 40-9086 

DATE AND TIME: July 6 to July 8, 2010 

 

LOCATION: Nuclear Safety Associates 

 100 Union Valley Rd. Suite #101 

 Oak Ridge, Tennessee 37830 

ATTENDEES: See attached participant list.

PURPOSE: The purpose of this meeting was to conduct an Integrated Safety Analysis 

(ISA) horizontal and vertical slice reviews and discuss draft requests for 

additional information with International Isotopes Inc. (INIS) Fluorine 

Products Facility (IIFP) 

DISCUSSION: 

The U.S. Nuclear Regulatory Commission (NRC) conducted a site visit in Oak Ridge, 

Tennessee with INIS and their contractor on July 6-8, 2010. The visit was to review the 

applicant’s onsite ISA documents and to discuss draft requests for additional information (RAIs) 

regarding the safety review. The NRC provided draft RAIs to the applicant prior to the site visit 

in order to facilitate the discussions. The RAIs addressed the following areas of review: ISA, 

Fire, Chemical Safety, Health Physics, Quality Assurance (QA), and Seismic/Structural, see 

attached. 

The applicant began the meeting by providing a slide presentation on the ISA methodology. 

Following this presentation, the meeting was broken into two separate parts. The first part 

addressed hazard analyses and the second dealt with structural and seismic issues. The 

review team conducted a horizontal and vertical slice review of the ISA. The team also 

conducted several break-out sessions with the applicant to discuss the draft RAIs. 

Horizontal and Vertical Slice: 

The ISA team conducted a horizontal and vertical slice review of the ISA and Process Hazard 

Analysis (PHA). The reviewers confirmed the methodology used by the applicant to determine 

the consequences of the accident sequences identified in the PHA is consistent with the 

information presented in the ISA Summary. The horizontal review revealed that the ISA 

continues to undergo updates, due in part to the lack of specific design information, which is still 

under development by the applicant. Updates to the ISA Summary are needed to complete the 

safety evaluation, which the staff indicated would be requested in the formal RAIs. The vertical 
 2 

review examined several accident sequences in depth including the applicant’s what-if analysis, 

accident sequences, items relied on for safety (IROFS), method for assigning likelihood and 

consequence, etc. 

The chemical, fire, and ISA reviewers all selected several accident sequences which the 

applicant described in detail. The staff observed that the applicant used a number of generic 

IROFS to mitigate multiple distinct accident sequences. Further explanation of these IROFS 

and how they apply to specific accident sequences may be warranted. Several passive IROFS 

appeared to be doubly credited for reducing likelihood. The applicant provided additional 

explanation of its approach in this regard, and the staff indicated it would consider this in its 

detailed evaluation of the IROFS and provide an RAI if needed. 

Request for Additional Information:

Break-out sessions were conducted for the NRC reviewers to discuss RAIs with their 

counterparts on the applicant’s review team. Several major issues were discussed. 

HEALTH PHYSICS: 

The reviewer discussed the draft RAIs with particular attention to several important topics. The 

INIS application states ICRP-68 will be used for airborne activity limits rather than the values 

contained in Appendix B to Title 10 of the Code of Federal Regulations (10 CFR) Part 20. This 

typically requires an exemption to the regulations. INIS indicated it had not been aware of the 

exemption requirement and would evaluate the best path forward. Discussion concerning the 

planned ventilation system revealed that additional design characterization was needed before 

the related RAIs could be addressed. INIS proposed a volumetric free release criterion for the 

fluoride products based on 10 CFR 40.13, i.e. one twentieth of one percent. This quantity is not 

typically used as a free release criterion since it was based on the strategic control of national 

resource materials rather than exposure. A more common standard used by industry for 

clearance is 30 pCi/g or 1 mrem/yr, which is based on American National Standards 

Institute/Health Physics Society N13.12-1999. INIS indicated it would evaluate the best release 

criteria in response to the RAIs. The NRC reviewer also indicated he would need access to the 

ISA methodology and calculations which were used to conduct the radiation protection accident 

consequence analysis. INIS indicated the information was available upon request. 

QUALITY ASSURANCE: 

The QA reviewer met with the contractors QA representative to discuss the RAIs. The applicant 

indicated some information requested in the RAIs was not available during the site visit since 

the QA program was still under development. Information on how the applicant plans to 

address certain criteria of the Other QA Elements were needed, in addition to additional 

information on QA Process Description (QAPD). The NRC indicated the information could be 

provided in response to the RAIs. Two additional RAIs would be provided to address the QAPD. 

SEISMIC/STRUCTURAL: 

The seismic reviewers examined the areas of seismic, high-wind and tornado hazards, and 

structural analysis. The review included introduction to preliminary and conceptual documents, 

interviews with the applicant’s staff, examination of cross cutting topics between Structural and 

the ISA and discussions of the draft RAIs, to ensure mutual understanding of the issues. The 

applicant presented their approach for the Aircraft Hazard and Natural Gas Pipeline Explosion 
 3 

Hazard analysis. The applicant indicated the information to address portions of the RAIs would 

be available once the detailed design contractor begins work and the site surveys are 

completed. The applicant indicated the geophysical survey is underway in Lea County, New 

Mexico to verify the location of various underground and above ground utilities. An additional 

RAI would be provided to clarify the codes and standards that the facility would be built to meet. 

FIRE: 

Draft fire protection RAIs were discussed with the applicant’s fire protection engineer. The 

applicant stated they have a clear understanding of the RAIs and are beginning to formulate 

their response. Draft fire protection RAI FS-7 will be deleted. The applicant specified that the 

dust present in the dust collection area is contained, non-combustible, and non-flammable. A 

new fire protection RAI will be added on the characterization of the hazard posed by nearby 

natural gas pipelines. The applicant is aware of the analysis that is needed and is formulating a 

response. 

CHEMICAL: 

The applicant demonstrated a clear understanding of the draft RAIs. Based on the discussions 

they were able to demonstrate that Chemical Safety RAIs 9, 10, 15, and 19 were completely 

addressed with information already on the docket. Therefore, these RAIs will be removed from 

the formal RAIs. The applicant indicated that calculations referenced in the ISA Summary for 

mitigation do not exist. These calculations would be developed once additional design 

information becomes available. Several inconsistencies observed in the ISA were reported as 

corrected in updated versions of the ISA, which have not been provided to the NRC. The 

applicant indicated the document updates would be provided as part of the response to the 

RAIs. 

Document Review: 

The NRC staff reviewed the following documents: 

• FEP/DUP Accident Consequence Evaluation, Rev. A 

• Accident Consequence Evaluation Worksheets, NSA-TR-10-10, Rev. A 

• Process Hazard Assessment (PHA), NSA-TR-10-11, Rev. A 

• Design Basis Analysis and Characterization of Hurricane Winds, Tornado and Straight 

Winds – Revision A, June 15, 2010 – Draft 

• Characterization of Floods for the IIFP Facility – Draft 

• Methodology to Characterize a Natural Gas Pipeline Explosion in the Area of the IIFP 

Facility – Draft 

• Design Consideration for the Snow Load – Draft 

• Aircraft Hazard Risk Determination – Rev. A, July 2010 

• 640 Acre Plan – Preliminary Utility Easement 

• 40 acre Plot Plan Natural Gas Line Exposure for Explosion Analysis 

• DUF6 Autoclave Building and DUF4 Process Building – Major Equipment Plans 

(Conceptual) – Drawing No. 500-M-1201 Revision B 

• DUF6 Autoclave Building and DUF4 Process Building – Structural Elevations 

(Conceptual) – Drawing No. 500-M-1202 Revision B 

• Major Equipment and Building Plans for Fluorine Extraction Process (FEP) Production 

Facility – Conceptual – Drawing No. 400-M-1201 Revision B 
 4 

• FEP Production Facility Structural Elevations - Conceptual – Drawing No. 400-M-1202 

Revision A 

Closing Remarks:

The NRC requested the applicant to provide the PHA and ISA Slide Presentation. These 

documents have been included in this meeting summary as attachments. 

Attachments: 

1. Participants list 

2. PHA 

3. ISA Slide Presentation 
 Attachment 1 

UNITED STATES NUCLEAR REGULATORY 

COMMISSION HEADQUARTERS

MEETING ATTENDEES

U.S. Nuclear Regulatory Commission (NRC) Horizontal and 

Vertical Slice Review of Integrated Safety Analysis and Discuss 

Draft Requests for Additional Information 

July 6-8, 2010 

Rockville, Maryland 

Name Organization 

John Miller INIS 

James Thomas Nuclear Safety Associates (NSA) 

Thomas Thompson NSA 

Sheri Stephenson NSA 

Marshall Shepherd NSA 

Donnie Chumbler NSA 

Ron Green NSA 

Tammy Wheeler NSA 

Daniel Theisen NSA 

Carol Mason NSA 

Andrew O'Connell NSA 

Tena Graben NSA 

Thomas Hiltz NRC 

Yawar Faraz NRC 

James Downs NRC 

Matthew Bartlett NRC 

Jonathan DeJesus NRC 

Lydiana Alvarado NRC 

Gregory Chapman NRC 

Madhumita Sircar NRC 

Damaris Arroyo NRC 

Asad Chowdhury Southwest Research Center