UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 

WASHINGTON, DC 20555 - 0001 

February 13, 2012 

MEMORANDUM TO: R. W. Borchardt 

 Executive Director for Operations 

FROM: Edwin M. Hackett, Executive Director /RA/

Advisory Committee on Reactor Safeguards 

SUBJECT: INTERNATIONAL ISOTOPES FLUORINE EXTRACTION 

AND DEPLETED URANIUM DE-CONVERSION PLANT 

SAFETY EVALUATION 

During the 591sh meeting of the Advisory Committee on Reactor Safeguards (ACRS), February 

9-11, 2012, the Committee considered the staff’s draft final Safety Evaluation Report (SER) for 

the International Isotopes Fluorine Products, Inc. Fluorine Extraction Process and Depleted 

Uranium Deconversion Plant. The Committee decided not to review the SER and has no 

objection to the staff's proposal to issue the SER as final. The attachment provides additional 

information that supported the Committee’s decision. No response to this memorandum is 

required. 

Attachment: 

As stated 

Reference:

Safety Evaluation Report for the International Isotopes Fluorine Products, Inc. Fluorine 

Extraction Process and Depleted Uranium Deconversion Plant, dated September XXXX 

(ML113140271) 

cc: A. Vietti-Cook, SECY P. Silva, NMSS 

M. Muessle, OEDO S. Jones, NMSS 

M. Kotzalas, OEDO M. Bailey, NMSS 

C. Haney, NMSS 

J. Kinneman, NMSS 
February 13, 2012 

MEMORANDUM TO: R. W. Borchardt 

 Executive Director for Operations 

FROM: Edwin M. Hackett, Executive Director /RA/

Advisory Committee on Reactor Safeguards 

SUBJECT: INTERNATIONAL ISOTOPES FLUORINE EXTRACTION 

AND DEPLETED URANIUM DE-CONVERSION PLANT 

SAFETY EVALUATION 

During the 591sh meeting of the Advisory Committee on Reactor Safeguards (ACRS), February 

9-11, 2012, the Committee considered the staff’s draft final Safety Evaluation Report (SER) for 

the International Isotopes Fluorine Products, Inc. Fluorine Extraction Process and Depleted 

Uranium Deconversion Plant. The Committee decided not to review the SER and has no 

objection to the staff's proposal to issue the SER as final. The attachment provides additional 

information that supported the Committee’s decision. No response to this memorandum is 

required. 

Attachment: 

As stated 

Reference:

Safety Evaluation Report for the International Isotopes Fluorine Products, Inc. Fluorine 

Extraction Process and Depleted Uranium Deconversion Plant, dated September XXXX 

(ML113140271) 

cc: A. Vietti-Cook, SECY P. Silva, NMSS 

M. Muessle, OEDO S. Jones, NMSS 

M. Kotzalas, OEDO M. Bailey, NMSS 

C. Haney, NMSS 

J. Kinneman, NMSS 

Accession No: ML12044A250 Publicly Available Y Sensitive N

Viewing Rights: NRC Users or ACRS Only or See Restricted distribution 

OFFICE ACRS SUNSI Review ACRS 

NAME ADias ADias EMHackett 

DATE 02/14/12 02/14/12 02/15/12 

OFFICIAL RECORD COPY 
Attachment 

February 10, 2012 

MEMORANDUM TO: J. Sam Armijo, Chairman 

 ACRS 

 

FROM: Michael T. Ryan, Chairman /RA/ 

Radiation Protection and Nuclear Materials Subcommittee 

ACRS 

SUBJECT: SUBCOMMITTEE REPORT REGARDING THE INTERNATIONAL 

ISOTOPES FLUORINE EXTRACTION AND DEPLETED 

URANIUM DE-CONVERSION PLANT SAFETY EVALUATION 

On May 25, 2011, the Subcommittee on Radiation Protection and Nuclear Materials met with 

the staff and representatives from International Isotopes Fluoride Products, Inc (IIFP), to discuss 

the staff’s safety evaluation and ISA findings regarding IIFP’s Fluorine Extraction Process and 

Depleted Uranium De-conversion Plant (FEP/DUP). The facility will convert depleted uranium 

hexafluoride (DUF6) tailings into stable depleted uranium oxide (DUO2 or DU3O8) for disposal in 

a low level waste facility, and in the process generate fluoride products for commercial use. The 

applicant is the first to submit a license application under 10 CFR Part 40, and perform an 

Integrated Safety Analysis (ISA) to meet Part 70, Subpart H requirements. The following 

findings resulted from the May 25, 2011 Subcommittee meeting and review of the staff’s draft 

safety evaluation report (SER): 

(1) The principal safety hazard at DUP/FEP is chemical not radiological. Consequences 

from a chemical release are small because of the very low population around the site, 

and large distance to population centers. 

(2) The ISA did not identify any sequences that could lead to intermediate or high radiation 

dose to workers or the public 

(3) Criticality is not a safety issue because of the absence of special nuclear materials. 

(4) The design is simple. The applicant’s ISA summary identified only approximately 100 

accident sequences, and 38 IROFS. 

(5) No IROFS were identified to specifically protect against radiation exposure. 

(6) A number of operational design features and controls have been implemented for 

defense-in-depth purposes. 

The conclusion reached from the above findings indicates that the IIFP’s DUP/FEP poses little 

risk to workers, the environment, and the public. The staff’s SER provides the basis for 

approving the licensing application and should be issued. Further action by the ACRS regarding 

the DUP/FEP license application is not necessary. 
-2- 

DISCUSSION AND SUMMARY 

The IIFP Fluorine Extraction Process and Depleted Uranium De-conversion Plant (FEP/DUP) 

will become the first commercial de-conversion and fluorine extraction facility licensed by the 

NRC under 10 CFR Part 40. IIFP will also be the first Part 40 applicant to conduct an Integrated 

Safety Analysis (ISA) in accordance with Part 70, Subpart H, consistent with Commission 

direction and pending rulemaking. That rulemaking will require applicants authorized to 

possess 2000 kilograms (4400 lbs) or more of UF6, to perform an ISA. FEP/DUP will exceed 

these criteria by possessing up to 1.65 Mlbs of UF6. 

FEP/DUP will be built on a remote site of low population near Hobbes, New Mexico. The facility 

will both deconvert uranium for disposal in a low level radioactive waste (LLRW) facility, and 

produce byproduct materials for commercial use including silicon tetrafluoride (SiF4), boron 

trifluoride (BF3) and anhydrous hydrofluoric acid (AHF). Up to (approximately) 1.5 million 

pounds of SiF4, 1.5 million pounds of BF3, and 1 million pounds of AHF will be produced 

annually for commercial use. 

Uranium tailings (DUF6) for processing will be received in 14-ton steel cylinders from suppliers 

that include URENCO, AREVA, and USEC. Plant operation will involve a two step process. 

The first step will convert DUF6 to DUF4, and produce AHF as by-product material. The second 

step will produce DUO2 or DU3O8 for disposal, and SiF4 and BF3 as commercial by-product 

material. BF3 is the major production gas. Once tailings are processed into DUO2 or DU3O8 for 

disposal, they will be shipped to licensed disposal facilities, either Energy Solutions facility in 

Utah, or (if authorized) Waste Control Specialists in Texas. 

The principal hazard that could impact public health and safety is chemical not radiological, and 

is primarily associated with HF either from a direct release, or as a by-product from UF6, UF4, 

SiF4, or BF3 reaction with air. The much lower level radiological hazard results from UF6, and its 

formation into finely divided UO2F2 particles that could become an inhalation hazard when 

exposed to moisture in air. The ISA did not identify any sequences that could lead to 

intermediate or high radiation dose to workers or the public; nor have any items relied on for 

safety (IROFS) been identified to specifically protect against radiation exposure. 

The applicant’s ISA summary identified approximately 100 accident sequences and 38 

associated IROFS for meeting 10 CFR Part 70 performance criteria. Process system integrity, 

structural design criteria, and fire fighting response were classified as the only “sole” IROFS. 

Fire detection and suppression system have also been included on the list of IROFS. Criticality 

is not a safety issue at FEP/DUP because of the absence of special nuclear materials. 

Incoming materials will be assayed to ensure that only depleted uranium will be processed at 

the facility. 
-3- 

The applicant’s ISA is based on the existing level of design and provides a relationship between 

the hazards, mitigating capability, and consequences. The applicant used a “what if” process 

hazards analysis (PHA) to identify sequence initiators. The analysis does not quantify the risk, 

but helps to systematically evaluate features, events, and processes, and brings into focus the 

more significant safety areas. Risk ranking is not an option using this approach, but with a less 

complex design and smaller number of sequences and associated IROFS, as is the case with 

FEP/DUP, the ISA should be adequate for supporting safety decisions. 

The staff concluded that through active and passive engineering features, management 

oversight of the IROFS, and administrative controls, potential accidents at the DUP/FEP plant 

pose little risk to workers, the environment, and the public. Because of extensive evaluation by 

the staff, low radiological risk, and measures taken to limit the potential release of chemical 

material, further review by the ACRS is not necessary.