UNITED STATES

NUCLEAR REGULATORY COMMISSION

ADVISORY COMMITTEE ON REACTOR SAFEGUARDS

WASHINGTON, DC 20555 - 0001

April 2, 2012

MEMORANDUM TO: File

FROM: Sherry Meador /RA/

Technical Secretary, ACRS

SUBJECT: CERTIFICATION OF THE RADIATION PROTECTION 

AND NUCLEAR MATERIALS SUBCOMMITTEE 

MEETING TRANSCRIPT, OPEN SESSION, MAY 25, 

2011 

The attached document of the subject meeting is the official record of the 

proceedings of this meeting. A copy of the official record is attached.

Attachment:

As stated
Official Transcript of Proceedings

NUCLEAR REGULATORY COMMISSION

Title: Advisory Committee on Reactor Safeguards

Reactor Protection and Nuclear Materials

Open Session

Docket Number: (n/a)

Location: Rockville, Maryland

Date: Wednesday, May 25, 2011

Work Order No.: NRC-901 Pages 1-178

NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers

1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005

(202) 234-4433
DISCLAIMER

UNITED STATES NUCLEAR REGULATORY COMMISSION’S 

ADVISORY COMMITTEE ON REACTOR SAFEGUARDS

The contents of this transcript of the proceeding of the United States Nuclear 

Regulatory Commission Advisory Committee on Reactor Safeguards, as reported 

herein, is a record of the discussions recorded at the meeting. 

This transcript has not been reviewed, corrected, and edited, and it may contain 

inaccuracies. 
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1 UNITED STATES OF AMERICA

2 NUCLEAR REGULATORY COMMISSION

3 + + + + +

4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS

5 (ACRS)

6 + + + + +

7 SUBCOMMITTEE ON REACTOR PROTECTION AND

8 NUCLEAR MATERIALS

9 + + + + +

10 OPEN SESSION

11 + + + + +

12 WEDNESDAY, MAY 25, 2011

13 + + + + +

14 ROCKVILLE, MARYLAND

15 + + + + +

16 The Subcommittee met at the Nuclear

17 Regulatory Commission, Two White Flint North, Room

18 T2B1, 11545 Rockville Pike, at 1:30 p.m., Dr. Michael

19 T. Ryan, Chairman, presiding.

20 SUBCOMMITTEE MEMBERS PRESENT:

21 MICHAEL T. RYAN, Chairman

22 J. SAM ARMIJO

23 DENNIS C. BLEY

24 SANJOY BANERJEE

25 JOHN D. SIEBER
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1 CONSULTANT TO THE SUBCOMMITTEE PRESENT:

2 JOHN FLACK

3

4 NRC STAFF PRESENT:

5 DEREK WIDMAYER, Designated Federal Official

6 THOMAS HILTZ

7 MATTHEW BARTLETT

8 YAWAR FARAZ

9 SUSAN COOPER

10 SEAN PETERS

11 JULIE MARBLE

12

13 ALSO PRESENT:

14 STEVE LAFLIN

15 JOHN J. MILLER

16 JAMES THOMAS

17 RON GREEN

18 BILL BROWN

19

20

21

22

23

24

25
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1 AGENDA

2 Opening Remarks and Objectives ......... 4

3 Opening Remarks NRC Staff ............ 6

4 Overview of International Isotopes, Inc.

5 Facility ................. 7

6 Overview of Regualatory Process . . . . . . . . . 72

7 Risk-Informing Nuclear Materials . . . . . . . 120

8 Committee Discussion . . . . . . . . . . . . . 174

9 Adjourn

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25
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1 P R O C E E D I N G S

2 1:29 p.m.

3 CHAIRMAN RYAN: Okay, it's the appointed

4 hour. The meeting will now come to order. This is a

5 meting of the Advisory Committee on Reactor Safeguards

6 Subcommittee on Radiation Protection and Nuclear

7 Materials. I'm Michael Ryan, Chairman of the

8 Subcommittee. Members in attendance are Dana Powers,

9 Dennis Bley, Harold Ray, Jack Sieber, Said Abdel10 Khalik and Sam Armijo. 

11 Drs. Bley and Banerjee announced on the

12 phone a few minutes ago they're a little late getting

13 in from the airport by plane, but they will be joining

14 us shortly, and Dr. Powers is otherwise engaged on

15 another matter, and he will join us shortly. So I

16 think I've covered everybody.

17 MR. WIDMAYER: Said, I think, is the only

18 one that --

19 CHAIRMAN RYAN: Said will not be here.

20 MR. WIDMAYER: Will not be here, yes.

21 CHAIRMAN RYAN: Okay, and Dr. Abdel-Khalik

22 will not attend this subcommittee briefing. The

23 purpose of this meeting is to review and hold

24 discussions with the NRC staff and representatives

25 from International Isotopes Fluoride Products, Inc.,
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1 regarding the license application and integrated

2 safety analysis summary for the fluorine extraction

3 process and depleted uranium deconversion plant, to be

4 located in Lee County, New Mexico.

5 Portions of the meeting may be closed, to

6 protect against the release of proprietary-related

7 information. The Subcommittee will also be briefed on

8 NRC's HRA research activities, as they apply to (1)

9 dry cast storage ad potential for cast drops, and (2)

10 medical procedures and applications.

11 The Subcommittee will gather information,

12 analyze relevant issues and facts, and formulate

13 proposed positions and actions as appropriate. Derek

14 Widmayer is the Designated Federal Official for this

15 meeting. The rules for participation in today's

16 meeting have been announced in the Federal Register as

17 part of the notice of this meeting, previously

18 published in the Federal Register on May 10th, 2010.

19 A transcript of the meeting is being kept,

20 and will remain available as stated in the Federal

21 Register notice. It is requested the speakers first

22 identify themselves and speak with sufficient clarity

23 and volume, so they can be readily heard. We have not

24 received any requests from members of the public to

25 provide comments. If there is anyone on the phone
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1 line at this time, would you please introduce

2 yourself? Do we have anyone? Yes please. Is there

3 anybody on the phone line?

4 (No response.)

5 CHAIRMAN RYAN: Hearing none, the

6 briefings are being held for information only. Unless

7 otherwise decided by Committee members, ACRS letters

8 are not being proposed at this time, based on this

9 briefing.

10 We will now proceed with the meeting, and

11 I call upon Mr. Thomas Hill, acting Deputy Director,

12 Special Projects and Technical Support, Division of

13 Fuel Cycle Safety and Safeguards, NMSS, to open the

14 presentations.

15 MR. HILTZ: Thank you, Dr. Ryan. As Dr.

16 Ryan said, my name is Tom Hiltz. I'm an acting Deputy

17 Director in the Division of Fuel Cycle and Safeguards,

18 in the Office of Nuclear Material Safety and

19 Safeguards, and it is a pleasure, and we're grateful

20 for the opportunity to come before the Subcommittee

21 and discuss our review of the proposed International

22 Isotopes facility to be located near Hobbs, New

23 Mexico.

24 With me at the table is Matt Bartlett.

25 Matt Bartlett is the project manager in charge of the
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1 licensing review, and in support is Yawar Faraz. He's

2 the senior reviewer for the ISA, and Dennis Morey.

3 Dennis is the acting Branch Chief for the Conversion,

4 Deconversion and Enrichment Branch.

5 We have a presentation prepared. I

6 understand we'll follow the International Isotopes

7 presentation. I do want to, again, express our

8 appreciation to be able to come and provide

9 information to the Subcommittee.

10 I think as you know, several months ago,

11 we made you aware of this project and thought it may

12 be of interest, certainly from awareness perspective,

13 for the ACRS to be aware of the review, because in our

14 view, it's unique in a couple of aspects.

15 It is the first deconversion facility that

16 the NRC will license, and although it's not a terribly

17 complex activity or complex facility, it is the first

18 of a kind. It also the first Part 40 facility that

19 will be licensed, using the Part 70 ISA requirements.

20 So with that, I thank you again for the opportunity.

21 CHAIRMAN RYAN: Thanks, Tom. Steve from

22 INIS will be, I think, the first speaker from the

23 applicant.

24 MR. LAFLIN: Thank you, Mr. Chairman. I'm

25 Steve Laflin. I'm the CEO of International Isotopes.
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1 I've been the CEO of International Isotopes since

2 about 2001. Prior to that, I started off my career in

3 the nuclear Navy submarines about a dozen years, and

4 then had worked in the nuclear industry, after picking

5 up a degree in Physics from Idaho State University.

6 So this afternoon, also presenting for the

7 company is John Miller. John is our radiation safety

8 officer. He's been our one and only radiation safety

9 officer. We've been very fortunate to have John on

10 board. He's also a former Navy nuke. He also has a

11 Masters, a Bachelor's degree in Health Physics, a

12 Master's in Environmental Science, and nearly complete

13 with a Ph.D., I believe.

14 John's been absolutely key to our role in

15 establishing rigorous safety programs for the company,

16 handling our licensing process, and he's been an

17 integral part of the licensing for the new nuclear

18 facility that we did, the uranium deconversion

19 project.

20 Also joining us this afternoon is Jim

21 Thomas, sitting on the table over here. Although Jim

22 won't be, we hadn't planned on him speaking, he is

23 certainly there to help, here to help us and backup

24 and answer questions that we may have on it.

25 Jim is the president of Advanced Process
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1 Technology Systems, or APTS. We hired Jim and his

2 staff at APTS to help us with the licensing, the

3 engineering work on this project. Jim's background is

4 quite impressive in the front end of the fuel cycle.

5 He was the operations manager for the Honeywell

6 conversion plant, the metropolis facility back in the

7 older days. He as the operation manager for gas

8 diffusion projects. 

9 He was a senior executive with USEC before

10 and during the transitions. He's been involved in

11 both DOE and NRC licensing, and I believe transitions

12 from one to the other. He was also working on

13 developing the SILEX technology with USEC back in the

14 day, before they dropped their technology and NGE

15 picked that up.

16 So you know, Jim's background, 30 plus

17 years in all of those areas in the front end of the

18 fuel cycle has been incredibly valuable to us. Jim's

19 been able to put together a team of equally

20 experienced and skilled engineers, that have helped us

21 with the design of the licensing for the project.

22 So one of these skilled folks is Ron

23 Green, who is also joining us today. Ron is our

24 expert on integrated safety analysis. So we will

25 leave probably the majority of this presentation to
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1 his topics on integrated safety analysis.

2 Ron has about 20 years of experience in

3 ISA, DOE or DOE facilities primarily, nuclear

4 criticality facilities and such, the kinds of things

5 where you would typically, more typically expect to

6 see ISA analysis performed.

7 So with that, we'll just give a, just a

8 few slides here, just as a brief intro on

9 International Isotopes, and stress a couple of points

10 that may or may not have come out in the previous

11 materials. We've been in business since '95, so we're

12 celebrating our 15th year of business this coming

13 October.

14 As a public company, we carry out

15 licensing under the Part 30 facility for our nuclear

16 medicine products, cobalt products for radiation

17 therapy, iodine-131, also for imaging and thyroid

18 cancer treatment, and then a whole range of nuclear

19 medicine calibration and reference standards.

20 We're one of only two companies really in

21 the world today that are manufacturing those

22 calibration standards. That's been our core business

23 in Idaho.

24 The new opportunity we're here, of course,

25 to talk about today is our new expanded business
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1 opportunity, which is our vision for this first

2 commercial depleted uranium deconversion and fluorine

3 extraction facility. A big mouthful for a title for

4 a project, and maybe we'll come up with an acronym

5 some day for this thing. But right now, we'll leave

6 it as it is.

7 The object here is not just to deconvert

8 uranium, which is important enough, and I'll explain

9 why we think that's important, but also to produce

10 important products during that process, extract as

11 much value from every step of the deconversion process

12 as we can, and we have the patents that allow us to do

13 that deconversion step, extract very pure products,

14 and also save a great deal of energy in that

15 extraction process, because we're effectively mining

16 a fluorine resource out there in depleted UF 6,

17 depleted uranium hexafluoride.

18 Well, why are we so interested in this

19 business segment? Well, it's basically being driven

20 by the expiration of the megatons to megawatts program

21 in 2013. Because of that, the stage has been set in

22 the U.S. to establish a lot of new commercial

23 enrichment capacity in the U.S.

24 So the chart shows the four major

25 companies that have announced plans to build
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1 enrichment facilities in the U.S., and there's four

2 companies in four various stages of operations.

3 URENCO is clearly leading the way. They are operating

4 a facility. They're producing tails today.

5 They've started off at three million

6 separative work units. They've increased it to 5.7,

7 and I believe they are trying to expand that to nine.

8 So they've grown almost triple their capacity, almost

9 before within the first six month of their operations.

10 AREVA, of course, I think I would say

11 they're in probably second place. They have a license

12 right now under review by the Nuclear Regulatory

13 Commission, which they're anticipating, I think,

14 approval and issuance of that license some time late

15 this year. They have a site located in Idaho and plan

16 to start construction in the spring. It's also about

17 a three million SWU facility, but they've also doubled

18 the fed facility capacity as well. 

19 General Electric, with their SILEX

20 technology, which is under license review right now,

21 and then USEC, which has a license for their American

22 Centrifuge Project, and some work under way there,

23 waiting on a loan guarantee and some other financing

24 issues.

25 The key point, I think, to make with these
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1 four guys coming online is that these four facilities

2 are not really based on a speculation in a nuclear

3 renaissance. These four facilities are coming online

4 to address a current opportunity for fuel, for uranium

5 enrichment that has to be satisfied today, as a result

6 of this megatons to megawatts agreement with the

7 Russians.

8 URENCO, for example, already has, as far

9 as I'm aware, over ten years of contract commitments

10 for their output of their facility. So these

11 companies have made sure that they have had contracts

12 in place before their commitment comes in place.

13 So that said, if one of these does not

14 succeed, say for example, a GE SILEX technologies does

15 not succeed, we believe that the other guys that have

16 technologies and have licenses will readily expand.

17 Ultimately, the total capacity that's

18 represented on that map, we think, will come to past.

19 The output, just roughly in terms of ratios of these

20 things, it's basically ten pounds of natural UF6 into

21 the enrichment process, to produce one pound of

22 enriched UF6 for fuel. So you end up with nine pounds

23 of byproduct or depleted material.

24 The result of the activities that have

25 been done in the U.S. over the last 40 or 50 years
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1 have already produced this stockpile, which there's a

2 picture of here, material that has basically never

3 been deconverted or treated. 1.6 billion pounds at

4 the last count, which has simply been stored outside,

5 some of it for nearly 50 years.

6 What we're trying to do is provide a

7 commercial solution to new enrichment capacity, to

8 prevent this, so that they'll never be a picture 20

9 years from now of another 1.5 billion pounds of

10 material that's out there. The DOE conversion plants

11 that are coming online some time in the near future,

12 those facilities will be running for about 25 years,

13 in order to process the existing stockpile.

14 If you look at the projected output of

15 enrichment capacity from those four enrichment plants,

16 you can see that within 20 years, we're going to build

17 up another 1.5 billion pounds, roughly, of new

18 commercial depleted material that would be sitting on

19 the ground some place. So we can --

20 MEMBER SIEBER: Will you be -- at the

21 three government gaseous diffusion plants, there must

22 be tons and tons and tons of UF6, as tailings. Will

23 you be processing any of that?

24 MR. LAFLIN: No. We've planned our

25 business purely on a commercial basis, purely to
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1 address new commercial depleted uranium that's

2 produced by URENCO, AREVA, USEC, under a commercial

3 operation NGE.

4 MEMBER SIEBER: So they'll be in

5 relatively new cylinders when you get them?

6 MR. LAFLIN: Yes.

7 MEMBER SIEBER: Okay, as opposed to the

8 40, 50, 60 year-old cylinders --

9 MR. LAFLIN: Yes, exactly. We're going to

10 -- we'll let the government deal with their own

11 existing stockpiles of material. We're going to

12 address new material, and in fact, you know, you

13 mentioned the old cylinders. 

14 But that's just another one of the

15 benefits we can offer, is if we're processing

16 cylinders on a regular basis, we can reempty, reuse

17 and recover those cylinders, as opposed to what the

18 DOE will do, which is cut them open and refill them

19 and use them as a waste package. So that wastes a lot

20 of steel and a lot of energy as well.

21 MEMBER SIEBER: When you recover them, you

22 would use them again for UF6, as opposed to any other

23 use, right?

24 MR. LAFLIN: Right.

25 MEMBER SIEBER: Okay, and you need
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1 separate packaging for the uranium tailings, that's

2 the output at your facility?

3 MR. LAFLIN: Right. The ultimate product

4 will be uranium oxide from our process, after the

5 fluorine's been removed, and that's --

6 MEMBER SIEBER: In some form, UO2.

7 MR. LAFLIN: UO2, U-308.

8 MEMBER SIEBER: And are you, would you

9 describe what that packaging looks like, because I

10 think your storage and shipping package would also be

11 a disposal package?

12 MR. LAFLIN: That's correct.

13 MEMBER SIEBER: Is that part of this

14 license application?

15 MR. LAFLIN: No. Waste package is not.

16 I mean the waste process, in describing the complete

17 cradle to grave operation is.

18 MEMBER SIEBER: Yes. I didn't find

19 anything in your application that referred to the

20 package, but if you know anything about it, I would be

21 curious what it is.

22 MR. LAFLIN: It's a Type A waste, so it

23 basically requires a strong, tight container. So

24 anything from a 55-gallon drum through, you know,

25 CVAN (ph) containers, depending on the quantities,
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1 that we work out the most economic disposal path with

2 the disposal site, will determine the type of package

3 that we use.

4 CHAIRMAN RYAN: And you had to balance all

5 of the DOT requirement in there somewhere along the

6 line?

7 MR. LAFLIN: Right. Yes, absolutely,

8 absolutely.

9 MEMBER SIEBER: And it has low specific

10 activity. It's not -- it can migrate if the package

11 fails, and it doesn't chemically react with anything?

12 MR. LAFLIN: Right. The uranium oxide is

13 very chemically stable.

14 MEMBER SIEBER: Okay. 

15 MR. LAFLIN: So it's a two-step process

16 envisioned for the facility. We'll take in the UF 6

17 cylinders and then step it down from UF6 to UF4. That

18 first deconversion step will produce anhydrous

19 hydrochloric acid is our first product, and that's a

20 commercial product that can be sold.

21 Then the second step, UF 4 using a FEP,

22 which is our fluorine extraction process, patents to

23 produce silicon tetrafluoride and boron trifluoride.

24 Boron trifluoride will be the major gas we'll produce

25 out of the facility.
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1 MEMBER ARMIJO: Those gases would go into

2 the semiconductor industry or integrated circuitry?

3 MR. LAFLIN: Several. BF3, for example,

4 our major customers, will be to go to, there's a

5 company that uses BF3 to make B10 for reactor poisons

6 and shielding and neutrons. They will be a major

7 customer of ours. Also, other customers which take

8 BF3 and then make complexes with that for the

9 petrochemical industry, for the solar industry, and

10 for the pharmaceutical industry.

11 CHAIRMAN RYAN: Are you going to talk

12 somewhere about carryover or what contamination levels

13 of uranium in your products would be, or you expect?

14 MR. LAFLIN: Yes. I wasn't going to talk

15 specifically about it, but you asked the question.

16 There's two major advantages to this fluorine

17 extraction process. The first is that it's a solid to

18 solid reaction process. You heat UF4 in the presence

19 of a metal oxide, and experimentally, it would say

20 that nothing should carry over.

21 But we've demonstrated that. We've built

22 a pilot plant in Idaho and we've operated that.

23 There's absolutely no uranium carryover into the

24 product whatsoever on the outlet side. We've even

25 installed mechanical filters immediately in the
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1 reaction vessels, that should be exposed to, and we

2 still can't detect uranium even on those vessels.

3 The other big advantage is that since

4 you're extracting fluorine right off of UF 6, you

5 already end up with a pure product from the very

6 beginning. You know, the folks that we compete with

7 in the industry to produce something is 4, 5, 9 pure,

8 and they have to expend a lot of energy to get there.

9 We don't. We're able to produce, even

10 anhydrous hydrofluoric, we're even able to produce a

11 pound of hydrofluoric acid for about six times less

12 energy than the conventional methods for producing

13 anhydrous hydrofluoric. There is a chance, because

14 HF, the hydrofluoric, comes off in this first step of

15 the process, in the UF6 deconversion stage.

16 There is, during possibly upset conditions

17 or unusual conditions, a chance that you could have

18 uranium in that anhydrous hydrofluoric acid. So we've

19 designed our system to have filter systems in initial

20 receiving tanks, so that we can stop and we can

21 evaluate that material.

22 If it does have uranium, there is a market

23 out there for uranium conversion, that really doesn't

24 care if uranium is present in the anhydrous

25 hydrofluoric acid. So we'll have a market for it,
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1 even if it does carry a uranium legacy.

2 CHAIRMAN RYAN: Thank you.

3 MEMBER SIEBER: Will your plant operate as

4 a batch plant or a continuous process?

5 MR. LAFLIN: It will be a continuous

6 process, but there's a separation between each step of

7 this process.

8 MEMBER SIEBER: Right, different

9 equipment.

10 MR. LAFLIN: Two parallel -- right, two

11 parallel continuous processes.

12 MEMBER SIEBER: Okay.

13 MR. LAFLIN: We spent a lot of time on

14 site selection. The last thing in the world I wanted

15 to do is to try and build a facility some place where

16 people would not welcome a nuclear facility. We were

17 just not willing to take on and fight an uphill

18 battle. 

19 So we get a pretty extensive site

20 selection screening. We looked in several states, and

21 then conducted a lot of public meetings beforehand,

22 and we had -- and then basically created a scorecard,

23 a score sheet for all of the different sites, and let

24 them bid for us and for our facility there. 

25 New Mexico won. I mean New Mexico put a
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1 very aggressive package together, offered lots of

2 incentives for us to locate there, one of which was

3 the property that was really ideally suited for us.

4 Large piece of ground. Our facility itself will

5 stretch out and occupy about a 40 acre footprint. 

6 We'll actually have a full section of

7 properties. We can locate almost smack dab in the

8 middle of that facility. There's an aerial view here

9 of that, and where you see the small facility up there

10 in the upper left corner, this is the full section,

11 Section 27 that's identified, so just to give

12 ourselves further isolation from neighbors and anybody

13 around the facility.

14 The public reception has been outstanding

15 down here. We've gone through two public meetings so

16 far on the licensing process. We conducted 40

17 meetings before we selected this location down there.

18 We've had some folks raise some concerns,

19 which they rightfully should do, because this is a

20 chemical facility really, and once people recognize

21 that, they want to know that we're safely handling the

22 chemicals down there, and we've explained to them

23 that, you know, how our processes work and how we'll

24 do that.

25 They believe the NRC licensing process
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1 itself gives them a lot of confidence that we'll be

2 regulated and operating safely once we're in place.

3 MEMBER ARMIJO: What is that facility or

4 that area where all those white splotches are? Is

5 that another chemical facility --

6 MR. LAFLIN: It's this area?

7 MEMBER ARMIJO: That, yes. What is it?

8 MR. LAFLIN: That's just -- it's an old

9 road or gravel pit, but it's only like eight or ten

10 feet deep to mine. They mine caliche there typically,

11 which looks like white chalk rock. 

12 MEMBER ARMIJO: I'm very familiar with it.

13 MR. LAFLIN: On this earlier picture,

14 that's basically what the site looks like.

15 MEMBER ARMIJO: Yes, okay. I just wanted

16 to make sure that that wasn't another chemical plant

17 of some sort.

18 MR. LAFLIN: No, no.

19 MEMBER SIEBER: Well, that site has some

20 mixed blessings. I understand the water table's 120

21 feet below the surface, and you require, what 10,000

22 gallons a month?

23 MR. LAFLIN: Yes, 10,000 a day, and we

24 have water rights for 50 acres, 50 acre feet. So we

25 have enough water rights for about ten times the
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1 capacity of the facility. It's a mixed blessing,

2 though, because if you look at all those lines crossed

3 out, you know, it's a relatively scarred region, with

4 power lines, with gas lines, with easement rights.

5 So that's why we're not quite dead center

6 there, because we had to pick a spot that was 40

7 acres, that was free of any underground gas lines or

8 access right-of-ways that could give us problems in

9 the future.

10 MEMBER SIEBER: You feel you'll have

11 enough water supply to operate your facility, and you

12 have tank storage for fire water, I understand, in

13 your plan?

14 MR. LAFLIN: Yes, yes.

15 MEMBER SIEBER: So you'll have sufficient

16 fire water to handle any expected fires?

17 MR. LAFLIN: Yes. Part our criteria for

18 site location was making sure that we had plenty of

19 access for utilities, for water, for all of those

20 services.

21 MEMBER SIEBER: No tornadoes, no real

22 seismic activity?

23 MR. LAFLIN: No. It's a pretty benign

24 region actually.

25 MEMBER SIEBER: I was thinking it would
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1 make a great retirement home for me. 

2 MR. LAFLIN: You get sand storms, though.

3 Dust and sand storms. They call it breezy conditions,

4 though, down there, the sand. It's like Idaho. It's

5 a breezy condition until it's over, sustained winds

6 over 30 miles an hour, and then it's actually a wind.

7

8 So now I'd like to turn it over for a few

9 minutes here to John first, just to talk about our

10 licensing for this facility and some of the

11 evaluations and engineering controls that we've put in

12 place.

13 MR. MILLER: Okay. Thank you for the

14 opportunity. I'd like to start out and say that we

15 took a defense indepth approach to the facility and

16 process design, relying primarily on engineered

17 controls. A good example is all of our effluents are

18 treated three times before they're released.

19 You know, the defense indepth approach

20 also supports worker safety. In addition, it reduces

21 the impacts to the environment and the public. If you

22 look at the data that we have on the screen there, you

23 know, our public dose that we modeled to the NEI is

24 three to the minus six rem per year, and our air

25 emissions, fluorine as HF, if you compare that with
25

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1 the state of Idaho, we're at 0.1 percent of what is

2 emitted right now in the state of New Mexico.

3 Just for informational purposes, the bulk

4 of that HF release is from the two coal- fired power

5 plants up in the northwest corner of the state. 

6 Additionally, we've talked about water

7 usage. Water is at a premium in this part of the

8 country. So we went to great effort to reduce the

9 amount of water we need.

10 We've got that down, estimated uses at

11 10,000 gallons per day, primarily where recycling and

12 recovering our process water to reduce the amount of

13 water that we do use, and the 10,000 gallon per day is

14 about 40 percent waste water, sanitary water, and then

15 water that's lost as condensate, and then groundwater

16 protection.

17 Groundwater is the water source down

18 there. So the state of New Mexico, the communities,

19 are very concerned about the ground water. So we've

20 went to a zero discharge facility, zero discharge

21 including sanitary waste. There's a lot of septic

22 systems down there, but we've went to a water

23 treatment facility instead of using a septic --

24 MEMBER SIEBER: You still have a septic

25 system, but you're treating the effluents --
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1 MR. MILLER: The effluent's treated. It's

2 not a septic system. The effluent of the water

3 treatment facility was going to go onto a tree farm.

4 MEMBER SIEBER: Okay, yes. I read that.

5 CHAIRMAN RYAN: I was going to ask you a

6 couple of questions on this slide. What's your

7 aquifer look like? Is it continuously connected with

8 regional aquifers? Are you isolated in a system or --

9 MR. MILLER: It's the Ogallala aquifer.

10 It's a large --

11 CHAIRMAN RYAN: It's a very large aquifer.

12 MEMBER ARMIJO: Very large aquifer.

13 CHAIRMAN RYAN: You really don't have any

14 isolation from the important ground water aquifer.

15 Not that you're going to put anything in it, but

16 that's your connection is to a -- I see. Let's see.

17 I had one other question. You said you had a three18 tiered system of measurement to verify the --

19 MR. MILLER: Filtration.

20 CHAIRMAN RYAN: Are you monitoring in

21 between each filter, or only out the back end?

22 MR. THOMAS: We have monitoring between

23 every --

24 CHAIRMAN RYAN: Please speak into the mic,

25 sorry.
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1 MR. THOMAS: Yes. We have monitoring

2 between all of the treatment systems that have

3 uranium.

4 CHAIRMAN RYAN: Yes.

5 MR. THOMAS: Now the sanitary system

6 wouldn't have monitoring in between. It's a triple

7 system too that uses UV as the final disinfection,

8 before we put the water onto the tree farm.

9 CHAIRMAN RYAN: Right.

10 MR. THOMAS: But all the other, all the

11 uranium systems have monitoring in between as

12 protective devices. We did not want to operate, for

13 example, one dust collector without the secondary in

14 place. So we'd want to know if that dust collector's

15 a problem so we can stop the operation.

16 CHAIRMAN RYAN: That's the key.

17 MR. THOMAS: You can't keep a tertiary

18 system.

19 CHAIRMAN RYAN: You have to stop the

20 operation before you inundate, you know, the other

21 parts of the system downstream.

22 MR. THOMAS: That's correct.

23 CHAIRMAN RYAN: That's interesting.

24 That's great. And the tree farm, how much water does

25 it use up? Have you figured out that you'll actually
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1 be using all the water you put in the tree farm? I

2 know that's a tough calculation.

3 MR. THOMAS: No. We've actually

4 calculated how much water a tree needs in New Mexico.

5 A two inch diameter tree uses about nine gallons of

6 water a day, and we'll have about 4,000 gallons. So

7 we're looking at about a two acre tree farm.

8 CHAIRMAN RYAN: Okay. So you're going to

9 size the tree farm, to make sure the water is used

10 locally --

11 MR. THOMAS: And of course we've got

12 additional land there if we need to expand the tree

13 farm.

14 CHAIRMAN RYAN: Yes. Fair enough. Okay.

15 That's all.

16 MEMBER SIEBER: I don't think an

17 overabundance of water is the big issue.

18 CHAIRMAN RYAN: No.

19 CHAIRMAN RYAN: No, here in the east,

20 people put water on tree farms and there's already

21 enough water, and their water tends to go somewhere

22 else.

23 MR. MILLER: Now, at the tail end, and we

24 talked about this earlier as well, we're left with

25 depleted uranium oxide, which is destined for
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1 disposal. As soon as we identified the location, we

2 began engaging with the Rocky Mountain Low Level Waste

3 Compact, to discuss the waste disposal issues.

4 And, you know, there's two aspects that we

5 needed to get clear with the Rocky Mountain Low Level

6 Waste Compact. The first one was, you know, they

7 agreed with our interpretation of the depleted uranium

8 hexafluoride. I mean we're utilizing the depleted

9 uranium hexafluoride, strip the fluorine gas, fluorine

10 off of it to produce product.

11 So we view the UF6 as a resource, as a raw

12 material for our process. We wanted the Rocky

13 Mountain Waste Compact to concur with that

14 interpretation, and they did. So that now, there's an

15 order, what they put into place for DUF 6, what is

16 being sent to International Isotopes for fluorine

17 extraction does not enter the Rocky Mountain Low Level

18 Waste Compact as a waste, so there is not any waste

19 import issues associated with that.

20 You know, the other aspect is, you know,

21 we're going to be exporting waste out of the Rocky

22 Mountain Low Level Waste Compact. So we needed to,

23 you know, work with them to plan in the future on how

24 we were going to handle, you know, all these multiple

25 waste exports, what we would be doing.
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1 Now as far as sites, you know, we've

2 looked at U.S. or Energy Solution's Clive, Utah

3 facility, at WCS, about 45 miles to the east. There's

4 an opportunity there. Then if you look at the amount

5 of waste that we will be producing, that kind of

6 follows the same chart that Steve showed earlier, as

7 the fuel enrichment facilities ramp up production. So

8 that's --

9 CHAIRMAN RYAN: Just so everybody's clear,

10 you're out of Compact for Texas; correct?

11 MR. MILLER: Correct. That would be an

12 out-of-compact. We would be importing into the Texas

13 Low Level Waste Compact if we chose to go WCS.

14 CHAIRMAN RYAN: And I guess, let's say the

15 annual volumes, you have fairly reasonable annual

16 volumes, is that right? Help me read those charts.

17 MR. LAFLIN: Up to 70,000, or between 70

18 and 80 thousand cubic feet, and that's based on the

19 initial two phases of capacity of the plant. The

20 initial plant capacity that's actually under licensing

21 today would be more around that 35,000 cubic feet per

22 year level.

23 CHAIRMAN RYAN: So just in practical

24 terms, how many shipments a week, a day, a month or a

25 year is that facility?
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1 MR. LAFLIN: That's about 250 shipments a

2 year.

3 CHAIRMAN RYAN: That's one every day of

4 the working week year.

5 MR. LAFLIN: Roughly one semi-truck a day.

6 CHAIRMAN RYAN: Yes.

7 MEMBER SIEBER: Now the Rocky Mountain

8 Compact waste site that would receive depleted uranium

9 from your facility, where is that located?

10 MR. MILLER: Yes. The Rocky Mountain

11 doesn't have a compact. But they're authorized to use

12 the Northwest Compact. So going straight into Clive,

13 Utah would not require, you know, importation from

14 Clive. They have access to Clive.

15 MEMBER SIEBER: That's pretty close?

16 MR. MILLER: It's fairly close.

17 MEMBER SIEBER: Yes. In the west, it's

18 pretty close.

19 MR. MILLER: Yes. 

20 CHAIRMAN RYAN: It's over 100 miles, as

21 opposed to hundreds.

22 MEMBER ARMIJO: Yes. Just give me some

23 help here. The waste volume you're talking about,

24 70,000 max under maximum conditions, is that a

25 significant fraction of what the Energy Solutions site
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1 can take? I mean is that a small amount or is that a

2 moderate amount?

3 MR. LAFLIN: We're told it's not. I mean

4 we ran these numbers and looked at what their waste

5 capacity is down there, and I believe we could ship to

6 them for 20 years, and they've also got access to

7 expand their facility possibly. If we run into -- if

8 we go to waste control specialists instead of Energy

9 Solutions, they have even greater capacity there.

10 MEMBER ARMIJO: Okay. But that would be

11 more complicated, because you'd be out of the Compact.

12 MR. LAFLIN: A bit more complicated, and

13 a lot depends on what their Compact, their newly14 established Compact and what decisions they make with

15 that over the next year or so.

16 MEMBER ARMIJO: So you'd agree that -- I

17 mean as far as I understand the Texas situation.

18 That's in a state of development. You know, it's not

19 real clear how that's all going to land, but that's in

20 negotiation at this point, among all parties.

21 MR. LAFLIN: Yes, absolutely. 

22 MEMBER ARMIJO: Okay.

23 MEMBER SIEBER: And your waste product is,

24 how shall I say it, relatively inert?

25 MR. LAFLIN: Yes, I would agree with that.
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1 Chemically inert.

2 (Simultaneous speaking.)

3 MEMBER SIEBER: -- natural uranium ore

4 would be?

5 MR. LAFLIN: Well you know --

6 MEMBER SIEBER: It travels, but it takes

7 a million years to move across the room. Okay.

8 MR. LAFLIN: Yes. 

9 MR. MILLER: I'll go through the licensing

10 process. You're familiar, I'm sure, with the

11 licensing process. I'll just give you a real quick

12 summary. The first slide up there, we discuss, you

13 know, a letter of intent submitted to the NRC in April

14 2009. 

15 You know, prior to that letter, we met

16 several times with the NRC, to provide them a

17 presentation of the product or the process, you know,

18 to let them know that we were planning on submitting

19 a license, and then eventually we submitted the letter

20 of intent.

21 We received, you know, a letter back from

22 the NRC. It was in May of 2009, that they acknowledge

23 the intent to license the facility. In that letter,

24 consistent with SECY Paper 07-146, you know, we were

25 directed to prepare the license application, you know,
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1 using Part 70, Subpart H.

2 So we prepared the license application,

3 had that submitted in December of 2009, used Reg Guide

4 1520, Revision 0, and for the environmental report, we

5 used Reg Guide 1748. NRC formally accepted the

6 application in February of 2010, and then we received

7 a request for additional information in September of

8 2010 and then in November of 2010.

9 We just finished up the responses to the

10 RAIs, and you know, what isn't on the slide and what

11 I'd like to say is, you know, hats off to Matt and Tom

12 and the reviewing team, because this process, you

13 know, it's been a trying process, but it was a lot

14 less difficult than what I expected it to be.

15 You know, Matt and I probably talked two

16 or three times a week, to make sure that the license

17 application and the RAIs and the responses are all

18 constantly going through.

19 CHAIRMAN RYAN: So the RAIs are complete

20 from the applicant's point of view, and I guess the

21 staff will tell us on their, where they are in the

22 acceptance process for all of this a little bit later

23 on.

24 MR. MILLER: Right. Now our next big step

25 was with the New Mexico Environmental Department, and
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1 we don't like to reinvent the wheel, and we like to

2 take advantage of lessons learned. We really used

3 URENCO LES as a resource for us. They had a bit of a

4 difficult time going through the NMED permitting

5 process.

6 We met with LES and in fact, we even

7 entered into a contract with them, to help us, you

8 know, go through the permitting requirements. Some of

9 the permits that we need are listed up there.

10 Ground water discharge, air emissions,

11 waste water, land application permit for the tree

12 farm, you know, hazardous waste generators, storm

13 water discharge permit, which is out of EPA. We met

14 early on with --

15 CHAIRMAN RYAN: Now just a clarification.

16 Are all these -- these are all state level. So your

17 EPA permit is the state EPA? Do you have an agreement

18 with the federal EPA in their issuing a permit?

19 MR. MILLER: Not surface water, storm

20 water, storm water.

21 CHAIRMAN RYAN: Okay.

22 MR. THOMAS: The storm water permit is a

23 federal, but the state --

24 CHAIRMAN RYAN: So it's the state program,

25 on authority from the federal EPA?
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1 MR. THOMAS: Right.

2 MEMBER ARMIJO: Is that the only permit

3 you require directly from the EPA?

4 MR. MILLER: Yes.

5 MEMBER BLEY: Where do you stand on these?

6 MR. MILLER: Well, we still have to submit

7 applications for, formal applications for all the

8 permits. 

9 MR. LAFLIN: But the two long-lead items,

10 for the ground water and the air discharge permit,

11 both we're anticipating roughly 18 months for both of

12 those. The ground water permit is actually in process

13 right now, and then the air permit process will start

14 -- or I have that backwards.

15 MR. THOMAS: We're doing the air permits

16 and we start the ground water permit in August.

17 MR. LAFLIN: Yes.

18 CHAIRMAN RYAN: Thanks.

19 MR. LAFLIN: Just to avoid either one from

20 being critical path. But just go back to the meetings

21 with NMED, you know. We met, again shortly after, or

22 even before selecting Hobbs, and then again after the

23 selection was made.

24 You know, we had meetings with all the

25 NMED bureaus, gave them presentations on the process,
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1 you know, just to be as transparent as possible, to

2 let them understand what we were intending to do.

3 We did enter into an agreement with NMED,

4 similar to URENCO, where we limit the quantity of

5 uranium that we have on site, and the time that we can

6 store cylinders and oxide disposal containers. Then

7 we have some reporting requirements. 

8 You know, this isn't -- it really doesn't

9 affect our process. We're a just-in-time type of

10 operation. So what we envision is bringing UF 6 in,

11 processing it and, you know, oxide's going to go out.

12 So the agreement with NMED, we don't think, is going

13 to really be a burden.

14 MEMBER ARMIJO: Just before you go on, you

15 know, do you buy the depleted uranium hexafluoride

16 from these various suppliers, or do you just take it

17 off their hands, do your process and send them back in

18 their containers?

19 MR. LAFLIN: We're actually paid to take

20 the UF6. So we're providing a --

21 MEMBER ARMIJO: So you take it off their

22 hands, and you process that material? At that point,

23 it's really your property?

24 MR. LAFLIN: We take title to it at the

25 time we accept the UF6. But part of our current
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1 contract with URENCO, and we envision the same term in

2 our other contracts, is that we're actually paid for

3 the waste disposal at the time we take title to it.

4 So in addition to the toll, there's a waste disposal

5 cost, based on the cubic foot charge at the ultimate

6 disposal sites.

7 MEMBER ARMIJO: Right, and the containers,

8 the cylinders, do they go back to the source?

9 MR. LAFLIN: Depends on the customer.

10 Some customers want their cylinders recycled,

11 recovered and reused, and that's something we'll

12 consider. It's not part of this application, but we

13 plan to address in the future is a cylinder cleaning14 testing-reuse station at the facility.

15 For the time being, I think the way it's

16 described in the license application now is the

17 cylinders would be used possibly as waste containers.

18 MEMBER ARMIJO: Okay.

19 MR. LAFLIN: Or could be just simply

20 shipped back to the customer if they wanted it back.

21 MEMBER ARMIJO: Yes. But you wouldn't

22 maintain an inventory of cylinders on your own, just

23 --

24 MR. LAFLIN: Not planned right now, no.

25 MEMBER SIEBER: You wouldn't actually have
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1 to clean them. All you'd have to do is hydrotest

2 them, right?

3 MR. LAFLIN: If they require testing, and

4 if they're within a five year life, you could just

5 send them back for reuse. With that, I guess we'll

6 hand over to Ron and talk about the integrated safety

7 analysis parts of the license application.

8 MR. GREEN: Okay.

9 MEMBER ARMIJO: Ron, before you go into

10 the ISA, could you just give us a little overview of

11 the chemical process steps, you know, the main pieces

12 of the process? I'm familiar with part of it, having

13 worked at a fuel factory at GE. So I think we knew

14 that part of the conversion process. But you do

15 something else. I'd like to understand what you do

16 with your FEP that's different.

17 MR. LAFLIN: Right, and Jim, if I say

18 anything stupid, help me and jump in. Feel free to

19 jump in and help me out here with this. But I'll give

20 you the layman's term for the chemistry part of it,

21 because it's really a quite simple process.

22 So UF6 is a solid material above 135

23 degrees Fahrenheit. So we bring these cylinders into

24 the facility. They go into an autoclave, which is a

25 steel shell basically, expose them to steam heat. It
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1 vaporizes the UF6. We feed that UF 6 at a very low

2 pressure into a reaction tower.

3 The reaction tower, you basically mix

4 hydrogen with the UF 6 gas. You get a pyrophoric

5 reaction in that tower. As it reacts, it basically

6 travels down the tower. The UF6 or the UF4 is formed,

7 falls to the bottom of the tower.

8 The hydrofluoric acid comes off as a gas,

9 basically is extracted off the side of that process

10 and packaged through filters, into compressors, pumps,

11 into a receiving tank.

12 MEMBER SIEBER: Now that's an exothermic

13 reaction?

14 MR. LAFLIN: Yes.

15 MEMBER SIEBER: So there is some kind of

16 potential for that to get out of control, unless you

17 really control that process?

18 MR. LAFLIN: No. In fact, it has to be

19 assisted with heaters. We actually have to heat that

20 reaction tower, in addition to exposing it to the

21 hydro --

22 MEMBER SIEBER: Yes, just to get the UF 6

23 out of the cylinder you have to heat it.

24 MR. LAFLIN: Right, right. But the

25 reaction tower itself, we also have to heat that as
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1 well, to help it achieve early stage reaction

2 temperatures.

3 MEMBER SIEBER: Now I've forgotten the

4 answer to this, but I understood at one time, the Type

5 48 cylinder, if you broke the valve off, you could get

6 a bad reaction, including a reaction inside the

7 cylinder. Is that correct?

8 MR. LAFLIN: The autoclaves that hold the

9 UF6 cylinders have got many interlocks built in there,

10 to detect any leakage of UF6 into that autoclave,

11 looking at -- I mean obviously, there's an inspection

12 on the cylinder before it goes in, but then there's

13 parameters and alarms on the condensate, on the water,

14 on the water levels, on the flow rates, anything that

15 could -- any signs or symptoms of a leak in the

16 cylinder would show up in those alarms and indicators.

17 MEMBER SIEBER: That's not a truly benign

18 process, right? Just heating up UF6 to get it out of

19 the cylinder and into your reaction chamber. There

20 are things that can go wrong. 

21 MR. GREEN: Sure.

22 MEMBER SIEBER: Okay, and you'll explain

23 that when you get to it.

24 MR. GREEN: I don't think we're getting

25 into that kind of detail, but the ISA did evaluate
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1 that.

2 MEMBER SIEBER: Well, could you get to

3 just that little bit, and --

4 MEMBER BLEY: Well, before you answer

5 that, given the large coefficient of thermal expansion

6 and the accident at Sequoyah Fuels 15 years ago,

7 whatever it was, what happens if you've got a cylinder

8 that's too full when you get it? How do you make sure

9 you don't, or that if it blows apart when you start

10 trying to heat it, you don't have a serious problem?

11 MR. LAFLIN: Jim Thomas was actually one

12 of the investigators for that event at Sequoyah, and

13 I mean that heating and creating a hydraulic in a

14 cylinder is something that can be engineer designed

15 around. It has to be considered, and Jim can probably

16 address that very specifically for you if you'd like.

17 MR. THOMAS: Well, of course it starts

18 with our customers being licensed in our safe

19 facilities, enrichment plants, and yes, yes, Sequoyah

20 Fuels was. So they go through their procedures and

21 process, to ensure they don't ship an overfilled

22 cylinder.

23 When it arrives, we have some IROFS, Items

24 Relied On For Safety, to ensure that they haven't sent

25 us one accidentally.
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1 MEMBER BLEY: Such as?

2 MR. THOMAS: We weight them.

3 MEMBER BLEY: Yes, right.

4 MR. THOMAS: We also check their paper

5 work. We would not, and then when the cylinder goes

6 into the autoclave, we also do a cold pressure check,

7 to make sure there's not non-condensables in there

8 that might cause gas pressure. Obviously, the

9 greatest concern of a UF6 cylinder is not to heat when

10 it's overfilled, and we'll have trained people. 

11 We'll have IROFS, and we'll weigh the

12 cylinders to ensure that if someone did a misweight at

13 the shipper, we catch it at the receiver. That's one

14 of our Items Relied On For Safety and requires a

15 double-check. It requires a sign-off by the operator,

16 and we use a weigh-in scale before we place it into

17 the autoclave.

18 MEMBER BLEY: What if one is overfilled

19 and ends up in the autoclave? Is it -- can the

20 autoclave withstand it?

21 MR. THOMAS: It depends on how much it's

22 overfilled. The autoclave probably would have

23 withstood the Sequoyah, because that was an open steam

24 chest. It was not an autoclave. It was not a

25 containment-type autoclave. But what we need to be
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1 careful to understand that even containment-type

2 autoclaves aren't totally leak tight. There can be

3 places where they leak around seals. But it would

4 contain it, to some degree.

5 Also, ruptured the cylinder releases the

6 liquid, if it comes to the liquid point of expansion.

7 So the pressure inside the autoclave -- the autoclave

8 design is for 200 pounds working pressure, it's

9 actually tested higher than that. So if you leak into

10 the autoclave, it is a secondary containment, and the

11 pressure of UF6, even at that overfill of cylinders,

12 is in the order of 70 to 80 pounds.

13 So having IROFS on making sure

14 temperatures aren't exceeded, pressures aren't

15 exceeded, water levels aren't exceeded, connectivity

16 to show that if you have a leak, that's very

17 important. So it's a very important part of the

18 process. 

19 Our autoclaves are very similar to the

20 ones that's been used on the gas diffusion plants for

21 50 years, and many have them. So we have the same

22 type of safety systems and a lot of defense indepth.

23 MEMBER ARMIJO: I presume --

24 MEMBER BLEY: But weighing is your crucial

25 step on this?
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1 MR. THOMAS: As far as the over-filled

2 cylinder, that's correct.

3 MEMBER BLEY: Okay. 

4 MEMBER ARMIJO: I suspect your autoclaves

5 look at lot like what the fuel manufacturers --

6 MR. THOMAS: They look like the Paducah

7 gas diffusion plant autoclaves, and the ones that were

8 at K-25 and the ones that were at Portsmouth, that's

9 operated, you know, many years so they're well-proven.

10 Some people use other types of autoclaves,

11 but the steam autoclave is a well-proven system.

12 CHAIRMAN RYAN: In addition to the

13 weighing, which I understand it's a critical step

14 aspect, do you have an operating margin, you know,

15 that you have built in to, you know, we'll accept a

16 drum that weighs no more than this, and then that's

17 got some margin of safety?

18 MR. THOMAS: We won't accept any cylinder

19 that doesn't meet the shipping weight of a 48 wire,

20 48. They all have their --

21 CHAIRMAN RYAN: Yes, I understand that

22 part. But then that cylinder going into the process

23 and getting heated up is in a different setting then

24 that particular requirement. Is there a margin

25 between that and --
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1 MR. THOMAS: The margin's been built into

2 the ANSI standard for 220 or 235 degrees.

3 CHAIRMAN RYAN: Okay, all right.

4 MR. THOMAS: So if you follow the

5 standard, you've got the margin built in.

6 CHAIRMAN RYAN: I got you, all right.

7 MEMBER BLEY: I'll just ask you one more

8 question about that. Within the IROFS that you have

9 to check for the over-filled cylinder, do you have

10 something that specifically would preclude the kind of

11 misweighing event that occurred at Sequoyah, since you

12 investigating that?

13 MR. THOMAS: Well, the autoclave itself.

14 One of the problems that happened at Sequoyah, they

15 had an over-filled cylinder. They over-filled it.

16 MEMBER BLEY: Was it weighed in the

17 autoclave?

18 MR. THOMAS: No. It's weighed outside the

19 autoclave before you place it in.

20 MEMBER BLEY: Before you blow up the --

21 (Simultaneous speaking.)

22 MR. THOMAS: Yes. The cylinder --

23 MEMBER BLEY: Or like they did, put it on

24 a scale, and they didn't get it all the way on the

25 scale.
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1 MR. THOMAS: They filled the cylinder. We

2 don't fill any cylinders.

3 MEMBER BLEY: No, but somebody else did.

4 MR. THOMAS: Yes, but that's right.

5 MEMBER BLEY: So you could have gotten

6 that --

7 MR. THOMAS: In that accident, they filled

8 the cylinder on a cart, on a load cell and the cart

9 wheel was off and it caused a problem. We weigh it on

10 an actual scale that's not on a cart. You place the

11 cylinder on the scale.

12 MEMBER BLEY: Okay. You have to pick it

13 up and put it on the cart. 

14 MR. THOMAS: That's right.

15 MEMBER BLEY: That helps me. Thanks.

16 MR. LAFLIN: Back to your chemical

17 process. So the first step up to UF 4, and I should

18 mention, too, that this UF 6 to UF4 part of the

19 process, we actually acquired a plant that did this

20 part of the process very, very well. Ran for about 15

21 years filling contracts for the Army, to produce UF4.

22 We're just taking the key components that are still

23 usable today, autoclaves, for example, reaction

24 towers, bridge cranes, those kind of components.

25 But along with that plant, we got all the
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1 operating records and parameters for the plant as

2 well, and actual operator time to help us with the

3 start-up. 

4 The second part of the process, the UF4

5 fluorine extraction part of the process. Again, we've

6 had a pilot plant in Idaho. We've been operating

7 since '96. When we acquired the patents, the company

8 we acquired them from had actually ran this process

9 with a calciner, producing silicon tetrafluoride gas

10 for some time as well, and demonstrating it.

11 It's a very robust process. It's a very

12 simple process. You basically mix UF 4 powder with

13 your metal oxide in a stoichiometric ratio, and you

14 heat that to about 700 degrees Fahrenheit.

15 MEMBER ARMIJO: Do a replacement reaction?

16 MR. LAFLIN: That's it. The fluorine

17 comes off, the uranium stays put and is converted to

18 an oxide. 

19 MR. THOMAS: Steve, for the record,

20 Sequoyah only operated eight years at Gore. Now that

21 process was used many years by other people. But the

22 Sequoyah process ran about eight years.

23 MR. LAFLIN: Yes, and I should also

24 mention too that it was at the Sequoyah facility, but

25 totally separate from the facility, where they had, at
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1 the conversion plant, had the events with UF6.

2 MEMBER ARMIJO: In this FEP process, are

3 you low pressure? Is that a low pressure process?

4 MR. LAFLIN: Yes. You know, we've

5 developed, from our work in Idaho actually, a process

6 patent on the top of the seven patents that we

7 acquired, and part of those, that patented technology,

8 was using a helium flow gas and some oxygen flow with

9 this. But it's at about a pound of pressure for

10 extraction.

11 MEMBER ARMIJO: Not a high pressure --

12 MR. LAFLIN: Not a high pressure, but BF3

13 itself, though, that's a high pressure gas. So once

14 we collect that BF 3, in order to package that and

15 prepare that, it's actually being compressed up to

16 3,000 pounds?

17 MR. THOMAS: No. It's about 1,200, 1,500

18 pounds on the product. But that product doesn't have

19 uranium in it, so it's not a licensed material. But

20 the reactor is running at below atmosphere.

21 MEMBER ARMIJO: Okay. So that's really

22 basically almost like a two or three-step process in

23 the end, as far as major processes?

24 MR. LAFLIN: That's right.

25 MEMBER ARMIJO: Okay. Thank you.
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1 MEMBER SIEBER: Now are these steps are

2 performed by fuel clarification plants, right?

3 (Simultaneous speaking.)

4 MR. LAFLIN: Well, the conversation has

5 been done by fuel classification plants.

6 MEMBER SIEBER: --Year 2. They do it

7 through this kind of a process. So this is not new.

8 MR. LAFLIN: Their process would go all

9 the way from UF6 all the way down to oxide --

10 MEMBER SIEBER: Right.

11 MR. LAFLIN: And extract all the -- and

12 the fluorine is of no concern, and really no value in

13 that process. It's wasted as or sold as small amounts

14 of hydrofluoric acid.

15 MEMBER SIEBER: Right.

16 MR. LAFLIN: The Department of Energy

17 facilities, for example, are using a single-step

18 process that will produce copious quantities of

19 aqueous hydrofluoric acid, which there may or may not

20 be a market for.

21 So our process, again on the hydrofluoric

22 side, we've focused on the anhydrous hydrofluoric, as

23 opposed to aqueous, because it has more commercial

24 value. So, onto integrated safety analysis.

25 MR. GREEN: I am here to describe the ISA
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1 process that we followed and documented, as part of

2 our submittal. We had a team approach with this. We

3 had safety specialists in environmental safety,

4 radiological safety and chemical safety, along with we

5 integrated with the engineers, the process and Design

6 engineers in this process, through pretty much all the

7 steps, all the way through.

8 We followed NUREG-1520 of the Part 70,

9 Subpart H. We followed that recommendation. We

10 followed it explicitly. If you look at 1520 and you

11 look at our submittal, and you can turn the pages, and

12 it follows it exactly as it was laid out in 1520.

13 Some facilities, Lynchburg and NFS, they have

14 different flavors of it. But we went strictly by

15 1520. We were happy with the methodology there. 

16 We consider a low hazard nuclear facility.

17 It doesn't have any criticality concerns, so it's

18 primarily a chemical and radiological concern. The

19 primary hazard we have at this facility is chemical,

20 with the most likely candidate for concern is HF or

21 any kind of fluoride product.

22 We didn't have any scenarios that led to

23 high or intermediate consequence doses to workers or

24 the public. 

25 CHAIRMAN RYAN: Did you have, put some
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1 numbers on high and intermediate?

2 MR. GREEN: I don't have those written

3 down. It's in the -- it's spelled out --

4 MEMBER SIEBER: It's in the application.

5 CHAIRMAN RYAN: Okay.

6 MR. GREEN: I don't know the precise one.

7 It's a certain radiological level and there are

8 certain -- the same thing for chemical. There are

9 certain qualities.

10 MEMBER SIEBER: The high was 100 rem. The

11 medium was 25 rem.

12 MR. GREEN: And then there's a soluble

13 uranium issue too, for that. 

14 CHAIRMAN RYAN: Maybe the staff will

15 address that when they come up here, give us those

16 values. Not right now, but when they're presenting.

17 Thank you. Go ahead.

18 MR. GREEN: Next one. The first step in

19 the process was to use a hazard identification, and

20 that's basically the what, where and how much

21 hazardous material that you have. That was primarily

22 done by the safety analysts that were on the project,

23 although we got a lot of information and feedback from

24 Jim and the other process engineers. 

25 From there, we went to a hazard screening
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1 methodology, and we would basically exclude low

2 consequence events such as skin irritants and things

3 like that. Also, we have standard industrial hazards

4 that you would have at a facility. Slips, trips,

5 falls, those type of things were excluded from further

6 analysis.

7 The first major analysis that involved the

8 entire team was the process hazards analysis. We had

9 three separate sessions that lasted multiple days. We

10 had Jim and his engineers come down for those, and we

11 had -- I was the team leader for that. We had a

12 scribe and we laid out the basic stuff and went

13 through the PFEs, and started at nodes and did our

14 methodology.

15 What we ended up using was the "what if"

16 checklist methodology. We thought about using haz op,

17 and we felt like the what if would get us the same

18 amounts. I feel more comfortable with the what if

19 when you're bringing in people that aren't familiar

20 with haz ops, like some of Jim's folks. So with a

21 more straightforward and still a robust approach,

22 especially if you use the checklist with it as an

23 oversight.

24 Let's see. Once we did that, the

25 essential purpose of the PHA is to screen out for low
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1 consequence events and identify those that could

2 potentially, accidents that could result in high or

3 intermediate consequences. This kind of what our

4 forms look like. This isn't actually one of ours.

5 It's been kind of sanitized here.

6 But what you end up having is you have a

7 scenario number, and you do your what if at the

8 process node that you're concerned about. In this

9 case, we identified a couple of causes for this event.

10 The failure frequency, we'll discuss that in a little

11 bit. But you know, that's basically how likely this

12 thing's going to occur, and it's an order of magnitude

13 type number. 

14 In this particular instance, we expect

15 that failure to occur maybe once or twice during the

16 life of the facility, maybe once every five years, ten

17 years, in that range. The consequences --

18 MEMBER ARMIJO: The units are kind of

19 funny. Minus 1 what?

20 MR. GREEN: Yes. They range, and I'll

21 talk about that later, they range from a positive 2 to

22 a minute 6, and you want a more negative number that

23 you can get on all these. That's the way you want to

24 be.

25 CHAIRMAN RYAN: Okay. So rather than --
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1 I mean what does as minus 1 mean on a likelihood, in

2 terms of probability of percent?

3 MR. GREEN: You would expect it about once

4 every few years to occur. I'll discuss that --

5 CHAIRMAN RYAN: Okay. All right, okay.

6 We'll get there.

7 MR. GREEN: And the consequence here is a

8 hazardous and radioactive gas release, and this is

9 unmitigated at this point. We don't assume we have

10 any controls on it or mitigation. The consequence

11 categories, you can see the categories down below.

12 You have low, intermediate and high. At this point,

13 we are just estimating this expert opinion at this, at

14 this time. 

15 We're not -- these are not definitive.

16 We'll confirm these later. The prevention feature is

17 what we -- we will use the PFDs and the PNIDs to just

18 look at possible controls that we may want to make

19 safety controls. We're not committed to them at this

20 point. This is just to help us in the later phases of

21 analysis.

22 Same thing with mitigation features.

23 These are just things that we have available if we

24 want to use them.

25 MEMBER ARMIJO: Which could become IROFS?
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1 MR. GREEN: Could become IROFS, if we need

2 them. But at this point, we're just listing them, and

3 we'll pick the best ones as we need them.

4 CHAIRMAN RYAN: So just so I'm clear, let

5 me state it a different way. It sounds like this

6 process is helping you systematically evaluate, you

7 know, features, events and processes in the system

8 that you really want to focus in on?

9 MR. GREEN: Exactly. It's another

10 screening tool, and it also like helps identify things

11 that we're going to need, when we start doing some

12 accident analysis.

13 CHAIRMAN RYAN: Some of these things, like

14 the failure frequency, is really a ranking rather than

15 an analytical result. Is that fair?

16 MR. GREEN: No. It's supposed to be based

17 on likelihood. It's supposed to be -- 

18 CHAIRMAN RYAN: But it's not a full kind

19 of a PRA model?

20 MR. GREEN: It's not a PRA. It's more of,

21 you know, this type of failure you would expect to

22 occur. It's being in a group of failures.

23 CHAIRMAN RYAN: Yes, but that rank is

24 based on the consequence of a 6 versus a minus 1 or

25 minus 5 or 1, right?
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1 MEMBER ARMIJO: Well, the consequences per

2 event is the way I read it.

3 MR. GREEN: Yes. Consequence is --

4 CHAIRMAN RYAN: Oh per event, okay.

5 MR. GREEN: Consequence is what happens if

6 it does occur.

7 CHAIRMAN RYAN: I got you. All right,

8 thanks.

9 MEMBER ARMIJO: But your frequency number

10 comes from experience from similar facilities?

11 MR. GREEN: It's coming up on the next

12 slide.

13 MEMBER ARMIJO: Okay. 

14 CHAIRMAN RYAN: Fire away.

15 MEMBER SIEBER: Let me ask you a quick

16 question before you leave this. As I read through the

17 application, I did not come across any high

18 consequence accidents that you could have; is that

19 correct?

20 MR. GREEN: No. There are some high

21 consequence accidents, chemical and --

22 CHAIRMAN RYAN: Is it the chemical ones?

23 There are still radiological source material-wise.

24 MR. GREEN: Not from a process upset, but

25 there are like seismic event, if we collapse a
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1 facility would, would be a high consequence event. So

2 there are some, but they're not process-type

3 accidents. They're more --

4 CHAIRMAN RYAN: Based on events? 

5 MR. GREEN: Yes.

6 CHAIRMAN RYAN: Is that your only high

7 consequence?

8 MR. GREEN: From a radiological --

9 CHAIRMAN RYAN: It's external events?

10 MR. GREEN: Yes.

11 MEMBER SIEBER: But even that occurs over

12 days, right, a radiological event from a seismic

13 event?

14 MR. GREEN: It would be based on an

15 immediate dose, yes. It's not a prolonged one. You

16 would expect the release to occur, and then it would

17 settle out. It's not like a criticality or anything

18 where --

19 MEMBER SIEBER: Well, yes. The activity

20 levels or the specific activity that's --

21 MR. GREEN: Yes, yes. So once we finish

22 with the PHA, we would move on to the first step and

23 do an accident analysis, is to figure out what the

24 initiating event frequency is. NUREG-1520 has tables

25 in there for types of events and values you can assign
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1 them.

2 If it's a frequent event, like you expect

3 it every week or so, it would be a 2. If it were

4 something that would happen maybe a couple of times a

5 year, it would be a zero. If it's every few years,

6 it's a minus 1, and from there, it just goes order of

7 magnitude.

8 So the lower the number, the less

9 likelihood the event, and we have criteria. There's

10 still a bit of judgment in there, but mostly it's

11 based on experience from facilities and the type of

12 failure you're looking at.

13 Then from there, you have those -- you

14 have to determine what your protection and prevention

15 type of controls would be. These would be your

16 potential IROFS that you would look at, given the

17 initiating event occurs.

18 Now some of your protection, you would

19 start working some of those things out there, and

20 start to group them. There's another table in 1520

21 that also gives different values for protection. Like

22 if it's a passive engineer control, it will give you

23 a range. It could be a minus 3 or a minus 4. If it's

24 an active engineer, it could be a control. It could

25 be a minus 2 or a minus 3. It's all in a range there.
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1 We always chose the more conservative

2 number. If it was an active engineer, we would use

3 the minus 2 instead of a minus 3, unless we had a

4 good, strong basis for saying it's going to be more

5 than that. If we had redundant systems and an

6 especially robust design on it, we would maybe

7 consider it at the higher value.

8 But I think we might have only done that

9 in one or two places on things. I think mostly across

10 the board, we used a conservative value on that. We

11 did not use failure duration. That's also in 1520.

12 That's used more for criticality safety.

13 If you have a glove box operation and you

14 only have one fissile can inside there, and the

15 operator brings in another fissile can, you can

16 recognize the failure. You can get it out relatively

17 quick. It helps you with your probabilities.

18 We don't really have many situations where

19 we're dealing with those type of events. So we just

20 left off the failure duration point, and it's

21 conservative to do that. So we didn't take any credit

22 for that.

23 Once we have the initiating event

24 frequency hammered down, and then also the protection

25 and prevention-type safety systems, we can determine
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1 the likelihood of an accident scenario.

2 We use this method that's also in NUREG3 1520, and really you just add them up. You have a

4 minus 1 for 1; you have an IROFS that's minus 1, and

5 you have another one that's minus 3. You add them up

6 and you're at minus 5.

7 Once you get to that point, it will go

8 into whether the scenario is likely, unlikely or

9 highly unlikely, and that's done by -- we use this T.

10 We calculate the T. So if it's T is equal to minus 5

11 or greater, it's highly unlikely. If T is equal to 4,

12 it's unlikely, and anything below 4 is a likely event.

13 After that, we do consequence, and we

14 start with a PHA again, what we came up with

15 initially. Then the chemical engineers and the

16 radiological engineers would, based on the amount of

17 flow and stuff, would determine what kind of

18 consequence that you're going to have.

19 The criteria in there in what, 10 C.F.R.

20 70.76, I think are the criteria for that, for the

21 consequence levels. They're simply a 1, 2 and a 3. 

22 Now we come to the Items Relied On For

23 Safety. These are basically the safety features that

24 we're relying on to meet our risk goals. These are

25 tabulated values. I've described them a little bit
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1 before for passive engineer control. You have a minus

2 3 or a minus 4. You can use active engineers in minus

3 2 or 3. 

4 Enhanced administrative controls are

5 typically minus 2, and for simple administrative

6 controls, we usually use the minus 1. 

7 The next thing we do from there is we

8 determine what the risk is, and that's simply

9 likelihood times the consequences. What we will use,

10 we will -- we use these risk tables, which I'll show

11 you in a little bit here, to document all this and

12 write up these scenarios. But any risk number that's

13 a 4 or less meets our performance criteria, our

14 performance goals that are spelled out in 70.61.

15 Anything that has a greater than 4, we're

16 going to have to either reduce, mitigate the

17 consequences or we're going to have to add additional

18 prevention and protection features, to get the

19 likelihood of the event down.

20 The accident sequences. These are risk

21 tables that we, and I'll show you an example here in

22 a minute. These are risk tables that we put together,

23 and we followed the methodology in 1520. But we used

24 -- the PHA was a starting point. That's where we got

25 our initiating event, and of course, we refined the
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1 probability of that initiating event with further

2 analysis, and also the consequences. 

3 So they weren't estimates at that point.

4 They were our best, our best numbers that we could

5 come up with. So we refined those event frequencies

6 and consequences, and then just we would determine

7 whether we meet the risk numbers or not from there.

8 This is what they look like. These are

9 the columns and categories. You start out with just

10 the unique identifier for the accident sequence, and

11 what the accident sequence is, and that's going to

12 match the PHA scenario down at the bottom, process gas

13 flow valve to open system. Then you have the

14 initiating event, and under that, the potential causes

15 for that event.

16 Ignore the IROFS 1, 2 and 3 at this time,

17 and let's stay up at the top here. The first thing

18 you do is you analyze the uncontrolled event, and then

19 you have no credit for any protection or mitigation of

20 any consequences. So you base the determination on

21 the likelihood on that, which in this case is a minus

22 1, which a category --

23 MEMBER BLEY: Which would always be the

24 same as the initiating event?

25 MR. GREEN: Always. Yes, always, and the
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1 only ones that end up being not controlled are some

2 very unlikely natural phenomena-type event, you know,

3 plane crash and stuff like that. Most of your process

4 accidents are all going to require IROFS, all of them

5 do.

6 So we end up with a Category 3, which is

7 likely, and then we have an evaluation reference to

8 the consequence. For this scenario, it's a 3. That

9 gives us a risk index of 9, which is 3 times the 3.

10 That gives us a 9. That means we need IROFS to

11 control this accident sequence.

12 So then if you go down to the bottom

13 column there, we added isolation valves. Really,

14 we're just taking credit for what's already there, and

15 there's a blind flange. This is a parallel system, so

16 you're going to have one system that's out maybe for

17 maintenance, for changing out traps or whatever, and

18 it's going to be a blind flange there. 

19 So in case the valve is turned the wrong

20 way, you've got to get through isolation valves and

21 then through a blind flange, in order --

22 MEMBER ARMIJO: Somebody would have to

23 install that blind flange. It would be

24 administratively controlled?

25 MR. GREEN: Yes. That's through
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1 maintenance and stuff. But maintenance isn't really

2 part of this; maintenance-type upsets are. So that

3 gives us -- that means that's controlled. That gives

4 us a minus 5. That changes the likelihood category to

5 highly unlikely, and then the 1 times 3 is now a 3,

6 and that meets acceptable risk for this scenario. 

7 Now our last thing we did as part of this

8 was to incorporate natural phenomena and external

9 events. We followed the same approach in doing this,

10 using the PHA. We documented everything in a PHA, and

11 went and assigned values and used the risk tables. So

12 everything on that aspect was pretty much the same.

13 We did have some -- a lot of these events,

14 you'll end up having either low or no consequences, or

15 you'll have that they're not credible. One was a dam

16 break burst, and there's no dams within hundreds of

17 miles. So that wasn't a credible scenario for us.

18 Plane crash. Now we did analysis to

19 demonstrate that it was highly unlikely or incredible,

20 but we had to go through that process. We just didn't

21 dismiss it.

22 MEMBER BLEY: What kind of events did you

23 have, within the process, while you still have UF6,

24 where the process might stop and the material might be

25 isolated in a segment of piping?
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1 MR. LAFLIN: I think we might want to be

2 careful, as far as this is in a public format that

3 we're in, to discuss the details of specific system

4 parameters and accident and accident analysis. That's

5 the advice that we were given, I think, by NRC staff.

6 MEMBER BLEY: Are you going to have a

7 closed any time, Mr. Chairman?

8 CHAIRMAN RYAN: We can close the session,

9 if you want to do that today. 

10 (Simultaneous speaking.)

11 MR. LAFLIN: --you know, to answer those

12 questions. But just --

13 MEMBER ARMIJO: I don't think we need to

14 go have another meeting, you know, if we're going to

15 ask these questions. You can just close the session

16 and get some answers.

17 MEMBER BLEY: We could do it some time,

18 you know, get through the slides.

19 CHAIRMAN RYAN: They'll get through this,

20 and if it's -- I'd leave to --, to maybe tell us

21 should we wait until the end of the session or at the

22 break, and come back after break and do it then.

23 That's probably a good place, but we can certainly do

24 it --

25 MR. GREEN: There's only one more slide.
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1 CHAIRMAN RYAN: Fire away.

2 MEMBER ARMIJO: Well on your initiating

3 events, did you -- what did you consider and actually

4 address a little more quantitatively? You know,

5 flooding is not impossible in New Mexico, if you're in

6 arroyo.

7 MR. GREEN: No. We looked at -- we even

8 looked at snow and stuff, snow loads.

9 MEMBER ARMIJO: Snow loads?

10 MR. GREEN: Yes. We looked at different

11 kinds of flooding; slowly flooding and then, you know,

12 a flash flood. We followed NUREG-1520 on that, and

13 Rev. 1 of 1520 has a lot of stuff on natural phenomena

14 and external events.

15 We used that as a guide on that, on

16 determining what our design basis accident, like what

17 size magnitude seismic event we needed or frequency

18 return period. We used the NUREG-1520 for that. Same

19 thing with winds and all those things.

20 MEMBER ARMIJO: Of all those external

21 events, which one was the most, the greatest concern

22 to you?

23 MR. GREEN: Well, you know, just whatever

24 one. You know, we didn't really look at it that way.

25 We didn't pick out the worse one. If it just fell
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1 into a certain bin, if it was intermediate

2 consequences, it was grouped in with intermediate

3 consequences. If it was high consequences, it was

4 high consequences. We didn't rank anything.

5 MR. THOMAS: From a design basis

6 standpoint, the governing natural phenomena hazard

7 will either be seismic or straight winds. We haven't

8 made that final determination, but it's one of those

9 two. As we get further into the engineering, that

10 will make that determination. We're analyzing both of

11 those.

12 MR. GREEN: And that's all I have. 

13 MR. LAFLIN: Well again, we appreciate the

14 chance to talk about this project. We clearly think

15 it's really an important project, that fills what

16 would be a major void in the front end of the nuclear

17 fuel cycle. We think we're an important, actually

18 it's an important business opportunity, but an

19 important operation to reduce waste and to recover

20 value from material that could become a waste.

21 Nothing is more important to us than

22 safety of our employees, protecting the environment.

23 We've kept that into paramount consideration from day

24 one on this whole plant and these operations. My

25 background, John's background, our safety philosophy
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1 driven home from our days in the nuke Navy started

2 that off in operation.

3 That philosophy is in our facility in

4 Idaho, I mean our safety performance, our license

5 performance there, and it will be part of this

6 facility as well.

7 Then, I think significantly, is that we

8 have really -- well, we've been the first to get

9 through this Part 40 licensing process in its newest

10 stage, the first facility ever to go through this kind

11 of detailed integrated safety analysis, using these

12 new regulations, to make sure that we've evaluated our

13 systems and our safety properly.

14 It's been a valuable process for us. I

15 mean it's certainly added some complexity and some

16 difficulties to it and some cost, but it's certainly

17 been worthwhile. We'll have -- at the end of the day,

18 when we're ready to be up and running and operating,

19 we'll be confident and everybody will be confident,

20 including the community, that it's been well-designed,

21 well-engineered and well-regulated as well.

22 CHAIRMAN RYAN: Thank you, Steve. I

23 appreciate all the briefings and presentations so far.

24 It's been very informative. One kind of summary

25 question. How has this process informed your start-up
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1 planning? I mean obviously it's a key part of it, I

2 think. But has your start-up plan changed, evolved,

3 or become something different than what you first

4 envisioned, now that you've been through this process?

5 MR. LAFLIN: No. You know, I mean we have

6 always planned on the licensing to essentially be the

7 long lead critical path for this project, and so I

8 think that's the same today.

9 We're maybe at a point to where we're

10 actually going to shift gears here, and actually

11 engineering work and formal design work may end up

12 becoming the critical path from this point forward,

13 based on where we think the license is progressing.

14 So it could become a funding/financing

15 issue, to raise the capital to actually start

16 construction. You know, how things progress with the

17 investment community as a result of the events in

18 Japan, you know, over the next few months and how

19 attractive the markets, or what kind of an appetite

20 they get for nuclear investments again will perhaps

21 affect the schedule, you know, more significantly.

22 CHAIRMAN RYAN: Okay, thank you. Okay.

23 I guess with that, we're pretty much right on

24 schedule. So I'd ask the staff to come on up and make

25 your presentation. I'd note that Dr. Banerjee has
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1 come to us finally, thanks to the mercy of some

2 airline that let him come here before the end of the

3 day. Welcome Sanjoy.

4 MEMBER BANERJEE: Thank you.

5 (Pause.)

6 CHAIRMAN RYAN: Tom?

7 MR. HILTZ: Thanks, Dr. Ryan. Just again,

8 thank you for inviting us. We hope to share whatever

9 information and address any questions that you may

10 have regarding our review process for proposed

11 International Isotope facilities, talk about the rule

12 of the integrated safety analysis.

13 As I did mention, this is the first Part

14 40 facility that's being licensed using that, and give

15 you an update on the review status.

16 Next slide. You probably already know

17 this, but just to be clear about our role in the

18 review process, the Office of Nuclear Material Safety

19 and Safeguards is the lead office for the review of

20 the International Isotopes application. We are the

21 project office. 

22 Matt is the single point of contact

23 between the NRC and the applicant. We do that for

24 many reasons. But all the communication from the NRC

25 staff should be at least coordinated, if not
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1 facilitated, through Matt. We oversee the safety

2 review portion of the review.

3 The review of the environmental work and

4 the environmental report is done by the Office of

5 Federal and State Materials and Environmental

6 Management Programs, FSME.

7 So we do not have any representatives from

8 FSME with us here today. So if you do have any

9 questions about the environmental review, we'll be

10 able to give you a status, but we'll likely need to

11 get back to you on some of those details.

12 And ultimately, if we can make the safety

13 conclusions in our safety evaluation report, and

14 complete the environment impact statement, we'll be in

15 a position to make a decision about whether to issue

16 a license. With that --

17 MR. BARTLETT: Good afternoon. My name's

18 Matt Bartlett. As Tom mentioned, I'm the project

19 manager for the International Isotopes license review.

20 Some of my slides will repeat some of what the

21 International Isotopes covered, and in those parts,

22 I'll try and just kind of go through it quickly.

23 I'd like to begin by just giving you kind

24 of an idea of where International Isotopes' key

25 conversion facility fits in the country's conversion
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1 and deconversion facilities. Then I'll focus in on,

2 talk about some of the hazards specifically for

3 International Isotopes.

4 I'll go over the regulatory requirements

5 that apply. I'll touch on the ISA and its impact on

6 the safety, the safety review, and then give you an

7 update on where we're at in the review, the status so

8 far.

9 Okay. There's a number of conversion and

10 deconversion facilities that operate in the country.

11 There's some that are licensed under Agreement States.

12 For example, Aerojet Ordnance in an Agreement State

13 licensee that is in Tennessee. This facility only

14 deconverts depleted UF4, and they use a process that

15 doesn't involve HF, which part of the reason it's

16 regulated under an Agreement State.

17 There's two facilities that are licensed

18 by DOE, that operate under DOE. These are the

19 deconversion plants that were already mentioned, that

20 are designed to deconvert the material that's at the

21 gaseous diffusion plants at Portsmouth and Paducah.

22 One of these facilities is already operating and one

23 is under construction.

24 That facility does deconvert UF6. So they

25 do handle large quantities of HF. Then of course
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1 there's the conversion facility. That's Honeywell,

2 Metropolis, Illinois. They are taking natural

3 uranium, uranium oxide that's been mined or milled out

4 of the ground, convert that into UF6 so that it can be

5 taken to the enrichment facilities and converted into

6 fuel.

7 This facility is regulated by the NRC.

8 It's regulated under Part 40, and obviously they

9 handle HF also.

10 MEMBER SIEBER: Is that the old Allied

11 chemical facility?

12 MR. BARTLETT: Yes.

13 MEMBER SIEBER: Okay.

14 MR. BARTLETT: Then that brings us to

15 International Isotopes. The proposed facility will

16 deconvert depleted UF6 from the commercial enrichment

17 facilities, and they'll be licensed under Part 40, and

18 they'll also be required to do ISA from Part 70.

19 This slide I'll go through really quickly.

20 So they'll be in the southeast corner of New Mexico,

21 about in the middle of Lee County. This is a picture

22 of the slide which International Isotopes showed.

23 It's a semi-arid area, not a lot of people

24 in the area. There are a couple of power plants in

25 the general area, but I think the nearest residence is
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1 over a mile away.

2 MEMBER SIEBER: Are those power plants

3 oil, gas?

4 MR. BARTLETT: They're gas, gas-fired

5 power plants, yes. As International Isotopes

6 mentioned, their process involves bringing the UF6

7 into the facility, reacting with silicon dioxide,

8 boron trioxide, in order to convert the material into

9 depleted uranium oxide for disposal, and then high

10 purity fluoride compounds for resale or sale.

11 So International Isotopes already

12 described their conversion process, two-step process.

13 But the thing I wanted to focus in on here is the

14 primary hazards for this facility, even though it's

15 regulated by the NRC, are the chemical hazards, and

16 you can see some of the chemical inventory that

17 they'll have on site. Large quantities of DUF 6, HF

18 and then the fluoride compounds.

19 MEMBER ARMIJO: What is the reaction for

20 making the boron tetrafluoride?

21 MR. LAFLIN: The trifluoride?

22 MEMBER ARMIJO: Is that a different --

23 MR. BARTLETT: So you're saying instead of

24 the DUF4 plus SIO2?

25 MEMBER ARMIJO: Is there a similar --
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1 MR. BARTLETT: I believe it's the same

2 process.

3 MR. LAFLIN: Yes. It would be, you'd just

4 substitute B2O3 in that equation for SIO2.

5 MEMBER ARMIJO: Just a separate screen --

6 (Simultaneous speaking.)

7 MR. BARTLETT: Yes, separate process

8 lines.

9 MEMBER BANERJEE: I missed this, but does

10 this -- any of this is exothermic, these reactions?

11 MR. LAFLIN: The UF6 to UF4 reaction step

12 is an exothermic reaction step.

13 MEMBER BANERJEE: And the formation of the

14 fluorides of boron and silicon, are they exothermic or

15 endothermic?

16 MR. LAFLIN: No, that's an endothermic

17 reaction.

18 MEMBER BANERJEE: Endothermic.

19 MR. THOMAS: Slightly endothermic.

20 MEMBER BANERJEE: Slightly endothermic.

21 MR. THOMAS: Yes.

22 MEMBER BANERJEE: And the final form of

23 the fluorides, are they solid basically or --

24 MR. LAFLIN: Gases.

25 MEMBER BANERJEE: Gases.
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1 MR. LAFLIN: Yes. Well, the anhydrous --

2 yes, hydrofluoric, the anhydrous hydrofluoric, silicon

3 tetrafluoride, boron trifluoride are all gases.

4 MEMBER BANERJEE: They're the gases, okay.

5 Are they poisonous?

6 MR. LAFLIN: Yes. Reactive and toxic.

7 MEMBER BANERJEE: Reactive and toxic.

8 MR. LAFLIN: Also highly in demand for

9 commercial applications all over the U.S.

10 MEMBER BANERJEE: Right.

11 MR. BARTLETT: Yes. So that's what the

12 hazards are --

13 MEMBER BANERJEE: Falling under OSHA on

14 this at all?

15 MR. LAFLIN: Yes.

16 MEMBER BANERJEE: So have you done the haz

17 ops? I haven't followed this, so I noticed you did a

18 PHA.

19 MR. LAFLIN: Yes.

20 MEMBER BANERJEE: Is that all that's

21 required?

22 MR. LAFLIN: Yes.

23 MEMBER BANERJEE: You don't need a haz ops

24 for this?

25 MR. LAFLIN: I don't think so.
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1 MR. THOMAS: No. Just a hazards analysis

2 and you could use several --.

3 MEMBER ARMIJO: You have to talk into the

4 mic.

5 MEMBER BANERJEE: Identify yourself first,

6 please.

7 MR. GREEN: Yes. You don't have use a haz

8 ops. That's just one of several techniques you can

9 use for OSHA or EPA or through the ISA methodology.

10 MEMBER BANERJEE: Do you fall under

11 Superfund Title III at all on this, with regard to the

12 amount of toxic chemicals on site?

13 MR. LAFLIN: No, I don't believe so. In

14 fact, you know, and as far as waste goes, this is not

15 a waste material. Even the UF6 coming to us has been

16 ruled as not a waste product, because we're extracting

17 fluorine.

18 MEMBER BANERJEE: So you've done a what

19 if, I noticed, and a -- I just looked -- checklist and

20 PHA. Is that what all you've done? You didn't do

21 anything more detailed than that for this?

22 MR. LAFLIN: Well no. We've done in

23 accordance with the advance recommendations and

24 requirements of the anticipated changes to Part 40, we

25 have implemented full compliance with those from the
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1 very beginning of this whole license process, which

2 includes PHA analysis, integrated safety analysis,

3 meeting all the requirements of NUREG-1520 Rev. 0 and

4 then NUREG-1520 Rev. 1. 

5 MEMBER BANERJEE: Yes. Well this is

6 pretty -- I imagine this is pretty toxic stuff, right,

7 and they're heavier than -- it's heavier than air,

8 most of this?

9 MR. LAFLIN: I believe so, yes.

10 MEMBER BANERJEE: Yes. So you looked at

11 plumes and dispersion of plumes and --

12 MR. LAFLIN: Oh yes.

13 MEMBER BANERJEE: --all this stuff?

14 MR. LAFLIN: Oh yes.

15 MEMBER BANERJEE: Okay. Sorry.

16 CHAIRMAN RYAN: Oh no, that's fine. Keep

17 going. Glad you're here.

18 MEMBER BANERJEE: All right, okay. I'm

19 sure I'll have more questions.

20 MR. BARTLETT: In addition to just the

21 inventory quantities that are on site, of course, one

22 of the main concerns is, since they're going to be

23 putting the cylinders, UF6 cylinders into an autoclave

24 and heating it up, the potential for a liquid release

25 is there, of course.
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1 If the UF6 is released in the liquid form,

2 it would react very rapidly with moisture in the

3 environment, to produce uranyl fluoride and large

4 quantities of HF. These are the hazards that we are

5 concerned about. 

6 MEMBER BANERJEE: HF will also react with

7 any moisture in the atmosphere if it's dispersed in

8 the form of a polymer, which is very heavy, heavy gas.

9 MR. BARTLETT: Okay.

10 MEMBER BANERJEE: It disperses very

11 slowly.

12 MR. BARTLETT: I know we definitely looked

13 at the plumes and the clouds that could come from a

14 release.

15 MEMBER BANERJEE: What codes did you use?

16 MR. BARTLETT: Yawar, do you want to touch

17 on there?

18 MR. THOMAS: Well, for some of the

19 dispersion modeling, we used the EPA codes.

20 MEMBER BANERJEE: Which one?

21 MR. MILLER: Well, SCREEN3 was used on one

22 of them. SCREEN3 was used. We have -- APTS ran the

23 models. 

24 MEMBER BANERJEE: APTS.

25 MR. LAFLIN: Yes, I'm sorry. You missed
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1 the introductions at the beginning, so I'm the CEO of

2 the company, and the fellow behind you that's offered

3 some comments is Jim Thomas. He's the president of

4 APTS.

5 MEMBER BANERJEE: Okay.

6 MR. LAFLIN: And then Ron Green is to his

7 right, and Jim has been involved in the nuke industry,

8 the front side of the fuel cycle. He was ops manager

9 for the Honeywell facility for the gas diffusion

10 plants for a long time, was a senior executive for

11 USEC. 

12 Ron Green works with him, and they have

13 worked as a contractor for us for all of our

14 licensing, safety analysis review, initial engineering

15 design for the facility and the plant. So Ron is our

16 integrated safety analysis expert on the facility.

17 MEMBER BANERJEE: So your nearest

18 habitation is a mile away, is it?

19 MR. LAFLIN: Yes, roughly. The facility

20 itself will take up about 40 acres, and we've located

21 this facility so that that 40 acre footprint will be

22 roughly in the middle of a 640 acre section of

23 property. Then outside of that, from the fence line

24 to the nearest neighbor is roughly six-tenths of a

25 mile, I think, away.
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1 MEMBER BANERJEE: And the largest storage

2 vessel, if it fails or leaks or whatever, you've

3 looked at the plume?

4 MR. LAFLIN: Has been evaluated, yes.

5 MEMBER BANERJEE: And using an EPA code

6 for heavier than air gas, I presume? Is that true?

7 MR. LAFLIN: Yes. Ron, do you know which

8 code that was used specifically for the air releases?

9 MR. GREEN: I'm sorry, I don't. I did it

10 one time, but it's been a while and I didn't run it.

11 It was -- our chem processing engineer did that.

12 CHAIRMAN RYAN: Maybe we can just take a

13 follow-up though. That will be helpful for us to

14 learn what codes were used.

15 MR. THOMAS: We can provide.

16 MEMBER BANERJEE: That would be in your

17 safety evaluation.

18 (Simultaneous speaking.)

19 MR. THOMAS: We did the dispersion

20 modeling for two reasons. One, for the environmental

21 report that will come in, the environmental impact

22 statement, which was done for what we call the routine

23 emissions. Then we looked at the accident emissions

24 with various codes, based on the largest-sized vessel

25 of any particular chemical.
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1 Like if we have 8,000 pounds, let's say.

2 I'll just pick a number. We had 8,000 pounds of HF,

3 we would have run the code for release of that entire

4 amount in that vessel. We did that for all the

5 hazardous chemicals, including the powders.

6 MEMBER BANERJEE: Okay. So you did a

7 postulated release basically, correct? Just the

8 failure of the tank?

9 MR. THOMAS: We did a postulated release,

10 yes, for each vessel, knowing the inventories in that

11 vessel, the actual inventory in that vessel.

12 MEMBER BANERJEE: You assumed the list,

13 whether -- or something?

14 MR. THOMAS: Yes. The meteorological

15 conditions were taken in consideration as part of the

16 worse case, as well as, you know, wind directions,

17 that type of thing.

18 MEMBER BANERJEE: Going towards

19 habitation?

20 MR. THOMAS: Yes.

21 MEMBER BANERJEE: And you were below toxic

22 levels before you got the habitation?

23 MR. THOMAS: Not always, but if it was

24 unmitigated, we were not. So that caused us -- when

25 we do those analyses, it caused us to put in
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1 preventive measures, to make sure we were below it.

2 But on the unmitigated cases which we did the models,

3 we would have had some chemical toxicity off site.

4 MEMBER BANERJEE: Right.

5 MR. THOMAS: And so then to the worker.

6 MEMBER BANERJEE: Yes, of course, and what

7 was the mitigation?

8 MR. GREEN: Well, we actually used

9 prevention. We didn't mitigate anything. We took

10 credit for the building in our releases. But we

11 didn't mitigate, we didn't plan on evacuations or

12 anything.

13 What we did to meet risk criteria on those

14 scenarios would make it, we would add controls

15 prevention, and protection controls, such that it was

16 highly unlikely for the event to occur.

17 MEMBER BANERJEE: And were these storage

18 vessels in buildings, or were there some outside?

19 MR. THOMAS: Both cases. Most of the

20 vessels are in buildings. For example, the anhydrous

21 storage would be in a containment-type building, with

22 a deluge system. That was what I was talking about in

23 mitigation.

24 But prior to the mitigation processes,

25 when we found the consequence of a chemical, as well
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1 as, you know, if it were radiological to be above our

2 risk level, we placed Items Relied On For Safety

3 within those systems, to prevent that release.

4 MEMBER BANERJEE: Sorry, I missed that.

5 MR. THOMAS: We used Items Relied On For

6 Safety, the IROFS, as preventers, to bring the

7 accident consequence or likelihood, to bring that risk

8 to an acceptable risk. So we used those models, and

9 the results of those models to help us identify those

10 systems that needed prevention techniques to avoid

11 that release.

12 MEMBER BANERJEE: Well, let me just

13 understand, going back to it. You have fairly large

14 storage vessels, I presume, and --

15 MR. THOMAS: Relatively small, compared to

16 most chemical industry. But yes large, in terms of

17 concern.

18 MEMBER BANERJEE: Well yes, in terms of --

19 if there was no form of mitigation, and if this vessel

20 failed, either catastrophically or developed a jet

21 release, both are possible. The question is that you

22 would get a plume, then, which potentially could be

23 toxic, given different weather conditions at your

24 nearest habitation.

25 MR. THOMAS: That's correct, if you did
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1 not have prevention techniques or mitigation

2 techniques to prevent that.

3 MEMBER BANERJEE: Well, the usual

4 prevention technique in the chemical industry is to

5 subdivide the tanks, and to put barriers between them,

6 so that they don't propagate failures. That's the

7 ones I know of.

8 MR. THOMAS: Well, you're correct, and we

9 use that technique, for example, instead of storing

10 all the anhydrous HF in one or two tanks, we stored it

11 in separate tanks, smaller separate tanks to reduce

12 the consequence. 

13 MEMBER BANERJEE: With the barriers?

14 MR. THOMAS: Yes, with actual separate

15 tanks.

16 MEMBER BANERJEE: Right. Separate tanks,

17 but one tank failure can -- catastrophic failure can

18 propagate to other tanks?

19 MR. THOMAS: That's correct. In the HF

20 tanks, we did that. That's correct.

21 MEMBER BANERJEE: So you have to put some

22 barriers?

23 MR. THOMAS: Right, yes.

24 MEMBER BANERJEE: We'd better take a quick

25 look at the safety report.
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1 CHAIRMAN RYAN: Okay.

2 MEMBER BANERJEE: Do we need a letter on

3 this?

4 CHAIRMAN RYAN: No. We're not planning a

5 letter from this meeting. This is really just the

6 first meeting we've had, so it's kind of an

7 introduction, and kind of an overview of the

8 applicant's status, and also the staff's status on

9 reviewing the applicant's materials.

10 MEMBER BANERJEE: They're coming to the

11 full Committee at some point?

12 CHAIRMAN RYAN: At this point, this was

13 planned as a subcommittee-only briefing, and then we

14 could take it up, and I think after we hear it all,

15 decide what the next steps might be as a subcommittee.

16 MEMBER SIEBER: We can do that with any

17 issue.

18 MEMBER BANERJEE: Yes, okay.

19 CHAIRMAN RYAN: Okay. Thanks, Sanjoy.

20 MR. BARTLETT: Okay. Let me talk a little

21 bit about the regulatory requirements. So

22 International Isotopes, this application will be

23 licensed under Part 40. The key requirements in Part

24 40 are summarized in 4031 and 4032. These would be

25 the standard requirements which you would expect for
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1 any facility, any fuel cycle facility.

2 The applicant needs to protect the

3 environment. They need to have a decommissioning

4 plan, an emergency plan. They have to have qualified

5 staff in the appropriate facilities and procedures.

6 They have to protect health and safety, and then they

7 have to have a physical security plan.

8 This would be fairly similar to what would

9 be required for Part 70 facility, which most of the

10 fuel cycle facilities are licensed under. The one big

11 difference between Part 40 and Part 70, just as it's

12 written right now, is Part 40 doesn't have any ISA

13 requirements in it. 

14 Back in 2007, the Commission and the staff

15 took a close look at conversion and deconversion

16 facilities, and the chemical hazards that are at the

17 facilities, and decided that these facilities should

18 meet some kind of integrated safety analysis.

19 So the Commission, in SRM to SECY-07-146,

20 directed the staff to undertake rulemaking to Part 40,

21 to incorporate ISA requirements, very similar to Part

22 70 into Part 40. That rulemaking is ongoing.

23 In addition, in that same SECY paper, I

24 mean that same SRM, the Commission also directed that

25 any new facilities that come in during the rulemaking
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1 should be required to meet the ISA requirements in

2 Part 70. That's what International Isotopes is

3 meeting.

4 Let me just give you a real quick overview

5 of the proposed rule. The proposed rule will

6 basically incorporate the ISA requirements that are in

7 Part 70, essentially into Part 40. There's a few

8 minor changes, because Part 40 facilities don't have

9 criticality concerns. So that piece of the ISA has

10 been taken out for the Part 40 facilities.

11 There's also a large number of source

12 material facilities in the country. We didn't want

13 ISA to apply to all of those. The intent was to

14 capture facilities that have large quantities of UF6.

15 So the rule establishes a threshold, that

16 if you have 2,000 kilograms or more, then the rule

17 would apply to you. Then we wanted these facilities

18 to be licensed by the NRC, as opposed to an Agreement

19 State. 

20 The rule, the Commission in SRM to SECY21 10-128 approved the staff's proposed rule. It was

22 just recently published in the Federal Register for

23 comment May 17th. We anticipate they rule will be

24 finalized in 2012. 

25 Okay. So let me just give you a little
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1 bit of the staff's perspective on the ISA summary. So

2 the applicant has to develop an ISA that they keep on

3 site. What they submit to the NRC is a summary, and

4 in the summary they have to list the intermediate and

5 high consequence events that they've identified.

6 International Isotopes has identified over 100.

7 MEMBER BLEY: Do they have to show you the

8 ones that were high and intermediate before IROFS?

9 MR. BARTLETT: Yes, yes, yes. That's

10 correct, unmitigated.

11 MEMBER BLEY: Unmitigated.

12 MR. BARTLETT: Yes, and then in -- because

13 eventually they all have to be mitigated, right? If

14 it was the other way, there wouldn't be any. Then in

15 addition in the ISA summary, they have to list the

16 IROFS that they're going to apply to mitigate the

17 accident sequences.

18 They have around 40, and you may say well,

19 why are there less IROFS than there are accident

20 sequences, and that's because several of the IROFS are

21 applied multiple, to multiple accident sequences.

22 These numbers should give you some feel

23 for the safety concerns for the facility. If you

24 compare it to a facility like MOX, which has several

25 thousands of IROFS, this kind of gives you a scale of
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1 the hazard. In addition, they also have to

2 incorporate --

3 CHAIRMAN RYAN: But you just must admit

4 that several thousands IROFSs kind of raises other

5 interesting questions.

6 MR. BARTLETT: Okay. 

7 MEMBER BANERJEE: But this is pretty

8 hazardous stuff in gaseous form.

9 CHAIRMAN RYAN: Chemically.

10 MR. BARTLETT: The chemicals, yes.

11 MEMBER SIEBER: Right.

12 MR. BARTLETT: Yes.

13 MEMBER ARMIJO: Just a quick question.

14 They have -- NRC has a right to audit the actual ISA?

15 MEMBER SIEBER: Right.

16 MEMBER ARMIJO: Is the staff planning to

17 do that, or have you done that?

18 MR. BARTLETT: Yes. So typically, and

19 this will be touched on in another slide, but I can

20 touch on it here. As part of our review, you know, we

21 begin by reviewing the application and the ISA.

22 Once we're into that, we go out and do a

23 site visit. So the ISA team, several of the technical

24 reviewers go out to the facility. We do an on site

25 vertical slice of the ISA that's on site.
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1 We look at accidents that were, you know,

2 screened out. We make sure that the approach was

3 correct. If there are questions that come up, we ask

4 more questions and they stay longer.

5 MEMBER ARMIJO: When a site, when a

6 facility actually (noise in mic) or things like that,

7 or would you just do a -- if it doesn't exist, right?

8 MR. BARTLETT: Well, yes. In this case,

9 the facility doesn't exist, right. That picture you

10 saw of the barren land, that's the site.

11 So when I say a site visit, what we

12 actually did was we went to Oak Ridge, which is where

13 the people who designed the ISA are based, and they

14 have the detailed documentation on site there.

15 So yes, you're actually talking to the

16 people that are doing the review, and doing detailed

17 review of documents that don't typically get submitted

18 to the NRC.

19 MEMBER ARMIJO: But when the facility's

20 built, and it's getting ready to operate, will the

21 staff go and inspect that facility, and assure that

22 the design is what was addressed in the ISA and that

23 the IROFS are really there, things haven't changed?

24 MR. HILTZ: Absolutely. There will be,

25 once we reach a decision to license the facility,
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1 there will be a construction inspection plan

2 developed, along with an operational readiness review,

3 which will in fact go over to make sure that the

4 facility was constructed as designed and approved.

5 It will focus on those Items Relied On For

6 Safety as part of the construction program, and will

7 make an assessment that the facility is ready to --

8 MEMBER ARMIJO: Well inevitably, there

9 will be some changes.

10 MR. HILTZ: Inevitably, there are some

11 changes.

12 MEMBER ARMIJO: I've never seen one that

13 hasn't changed.

14 MR. HILTZ: And we've had lessons learned

15 from the ongoing review of LES. We'll probably have

16 some ongoing lessons learned from the potentially

17 Eagle Rock facility that we'll be able to look at.

18 CHAIRMAN RYAN: I can imagine that at

19 least for maybe the, not the exact start of

20 construction, but somewhere as construction tends to

21 take shape, there will be a pretty regular, if not

22 continuous presence by NRC staff in an oversight role?

23 MR. HILTZ: Yes. I can tell you that for

24 the new enrichment facility, we're considering a

25 resident inspector. 
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1 CHAIRMAN RYAN: Yes.

2 MR. HILTZ: For the facility near Hobbs,

3 New Mexico, I don't think a final decision has been

4 made. But there is proximity to LES, so there will be

5 a constant sort of NRC presence.

6 CHAIRMAN RYAN: But not two, but it's not

7 one.

8 MR. HILTZ: Right.

9 MR. BARTLETT: Okay. In addition to the

10 IROFS that they submit in their ISA summary, they're

11 also required to submit a list of management measures

12 in their license application. Management measures are

13 just safety functions and items that they put in

14 place, to make sure that the IROFS remain available

15 and are operating correctly.

16 MEMBER BLEY: Before you the ISAs, when

17 the applicant described the ISA, they talked about

18 using the method of 1520 precisely. It's most

19 qualitative. The appendix shows you some semi20 quantitative stuff. This business of calling it the

21 risk by multiplying the consequence category number

22 index by the likelihood category index number, has

23 some things that trouble me a little bit, especially

24 the simplest case is the number three.

25 If you multiply a consequence category No.
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1 1 times a likelihood Category 3, you get a 3, and

2 that's something that has no long-term effects or

3 immediate severe effects, and it's not unlikely.

4 That's the same pseudo-risk number that you get if you

5 multiply something that could kill lots of people, and

6 it's ten to the minus 5th of that order.

7 Those two things don't seem remotely the

8 same risk to me, and having them lumped together by

9 this process just doesn't feel right. Accepting as

10 acceptable the number 3 for a risk number, when it's

11 one of potentially high consequence, because it's

12 without rigorous quantification, highly unlikely,

13 seems like it deserves a little more investigation.

14 Can you say anything about that?

15 MR. BARTLETT: I think I would like my ISA

16 expert to respond, if that's all right. Yawar, do you

17 want to --

18 MEMBER BLEY: And I don't even think it's

19 so much an ISA question, as a prudence issue. But go

20 ahead.

21 MR. FARAZ: As I understood your question,

22 I believe you're referring to the binning (ph) chart

23 that's in NUREG-1520?

24 MEMBER BLEY: In the appendix, yes.

25 MR. FARAZ: In the appendix, yes. There
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1 is --

2 MEMBER BLEY: Yes, the example, and they

3 showed us that in their presentation a moment ago.

4 But they didn't show us the matrix. But they took a

5 Category 3, and so they would multiply these things

6 before and after the IROFS, and if we get a 3 or less,

7 it's hunkey-dorey, and that's what that chart in the

8 appendix to 1520 has.

9 It's that case where you get a 3 by

10 getting in a high consequence with a highly unlikely,

11 that makes me say don't you need to look at that a

12 little more closely? It doesn't seem at all the same

13 kind of risk as the other pairing that gives you the

14 same index number, a 3, when it's something that can't

15 really hurt anybody badly, and it's not unlikely.

16 Those two things don't seem like they're

17 remotely in the same category, to me, and I'm just --

18 that first piece of that is the one that troubles me,

19 that I hope you look a little more deeply. If they

20 just miss one because they get a 3, when it's a high

21 consequence kind of event.

22 MR. FARAZ: Yes, and we do, even though on

23 the matrix, it might appear equal, we would tend to

24 spend more time on and more rigorous review for the

25 sequences, where the consequences are higher.
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1 MEMBER BLEY: Okay. When we get in the

2 closed session, I want to ask some about those things

3 that were high consequence events, that are okay now,

4 and about what you guys looked at there.

5 CHAIRMAN RYAN: Dennis, I agree, and I

6 think exploring the point that was just made that, you

7 know, you can end up with the same number but perhaps

8 different real levels of --

9 (Simultaneous speaking.)

10 MEMBER BLEY: It's a very different risk

11 for those two things.

12 MR. GREEN: Can I point something out? We

13 don't treat them the same way, because the ones that

14 --

15 MEMBER BLEY: How do I know that?

16 MR. GREEN: Well because if it's low

17 consequence to begin with, we don't even evaluate

18 them. We don't have any controls on those. There's

19 nothing there.

20 MEMBER BLEY: Okay.

21 MR. GREEN: On the high consequences ones,

22 we establish IROFS to prevent those things.

23 MEMBER BLEY: Okay. But when you -- after

24 the IROFS, you still end up a high consequence. 

25 MR. GREEN: It still meets the risk
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1 criteria, yes.

2 MEMBER BLEY: Well, then I'm questioning

3 the risk criteria. It doesn't seem like a risk

4 criteria if those two things are of the same order of

5 risk.

6 MR. GREEN: I think that's the way PRE

7 works too. So I think it's used the same way. I mean

8 you do risk consequences times the likelihood of risk.

9 MEMBER BLEY: But these numbers, these are

10 pseudo-risks, these numbers we're multiplying. They

11 aren't like multiplying real health effects times

12 frequencies.

13 MR. GREEN: Well, it's real health

14 effects. I mean we do detailed consequence analysis.

15 So they are real health effects.

16 MEMBER BLEY: When you get the same answer

17 for two things that are as dramatically different as

18 the ones we've discussed, they aren't the same kinds

19 of things that would be equated if you did a PRA.

20 I'll just tell you that flat-out. They're not.

21 MR. GREEN: All right.

22 CHAIRMAN RYAN: So there's a point for

23 discussion in the closed session.

24 MEMBER BLEY: Well, I'd like to see some

25 examples of those, to talk about how with the IROFS
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1 they get there.

2 CHAIRMAN RYAN: Okay.

3 MEMBER SIEBER: That's more a question for

4 the rulemaking in this application.

5 CHAIRMAN RYAN: Right, right.

6 MEMBER BANERJEE: But they have done some

7 detailed consequence models, right?

8 MEMBER SIEBER: Yes, yes.

9 MEMBER BLEY: I don't agree, Jack. How

10 they interpret and use these things, I think, is

11 perfectly appropriate here, and it's not a rulemaking

12 issue. I mean you have something that's semi13 quantitative, you must be doing some real engineering

14 considerations and engineering judgment, and not just

15 following the rule or we're a bit in trouble.

16 MEMBER BANERJEE: I assume that they have

17 done detailed consequence modeling, and also have

18 evaluations of the likelihood of probability of these

19 sequences. Is that, which we can speak about --

20 MR. GREEN: Yes. Every scenario, even the

21 low consequence ones, we did a study to determine the

22 actual, you know, exposure limits for each one of

23 those. Even if they were dismissed as low

24 consequences, we have all that stuff documented.

25 CHAIRMAN RYAN: Let me suggest that we're
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1 about ten minutes away from a short break, and if we

2 let the staff finish this first briefing, and then

3 we'll take a break, 3:30 to 3:45, and then I think

4 we'll close the session for maybe 25 minutes, and we

5 can maybe get into the details of some of these

6 discussions with specific examples.

7 It might help, the fact that we're not

8 talking about the details and specifics here. It

9 would be helpful -- 

10 MEMBER BANERJEE: May I just ask a general

11 question, though? Obviously, there is a large

12 overlapping of jurisdictions between various agencies

13 on stuff like this. We have to be sure that nothing

14 goes between the cracks here. Where does NRC's

15 jurisdiction sort of -- what does it encompass? Does

16 it encompass the chemical hazards as well?

17 MR. BARTLETT: Yes. There's actually an

18 MOU, Memorandum of Understanding between OSHA and the

19 NRC, that kind of spells out where that dividing line

20 is, and there's -- NRC obviously has authority for

21 radiological things.

22 But they also have -- that agreement also

23 spells out that they have oversight for chemicals

24 produced from, that would be produced from

25 radiological material. 
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1 For example, if you had a release of UF6,

2 the HF that comes off would be NRC's concern, and then

3 we also have regulatory oversight for chemicals that

4 could impact the safety of licensed material.

5 So if there was an HF tank that ruptured,

6 and that could go into a control room and impact the

7 safety of license material, that would be evaluated

8 and considered by the NRC.

9 MEMBER BANERJEE: What about the SIF4 and

10 boron fluoride? Do you have jurisdiction over what

11 happens to that?

12 MR. BARTLETT: Once they're separated from

13 license material, and as long as they could not impact

14 the licensed material, no.

15 MEMBER SIEBER: No.

16 MEMBER ARMIJO: So who does have concerns

17 about --

18 MR. BARTLETT: OSHA, as far as I know.

19 MR. HILTZ: As Matt said, we have a

20 memorandum of agreement, memorandum of understanding

21 with OSHA. In the Commission SRM, that came down on

22 SECY-10, on the proposed rulemaking. They actually

23 asked us to go back and look at that, and make sure

24 that there was some clarity in that.

25 In the proposed rulemaking, there's a
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1 question that we asked and answered about what the

2 roles and responsibilities are. In that MOU, there

3 are four criteria, and we are responsible for four of

4 those criteria: the radiological risk by radiological

5 materials, chemical risk produced by radiological

6 materials, and plant conditions which affect the

7 safety of radioactive materials, and thus present an

8 increased radiation risk to workers.

9 The fourth criteria, plant conditions

10 which result in an occupational risk, but do not

11 affect the safety of licensed radioactive material,

12 are the responsibility of OSHA. That's not a clear

13 bright line. I mean there are some -- a lot of

14 discussion and clarity, we're in the process now of

15 beginning to work with OSHA, to make sure that we

16 revise that.

17 There have been some changes to the Atomic

18 Energy Act and some recent legislation regarding

19 byproduct material, which caused us to go back and

20 look at that. 

21 MEMBER BANERJEE: But you have a joint

22 team looking at this or something?

23 MR. HILTZ: We do not have a joint team.

24 MEMBER BANERJEE: Okay.

25 MEMBER SIEBER: You also have one
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1 additional category that falls outside of OSHA, that

2 doesn't affect the worker, that a release of non3 radioactive material, chemical material, that impacts

4 the environment. I think that belongs to EPA.

5 MR. HILTZ: Yes, I think you're right.

6 MEMBER SIEBER: For the state.

7 MR. HILTZ: But those things are not

8 ignored in our review. I mean we consider them both

9 in the environmental report and International Isotopes

10 will consider those and will review those as part of

11 the ISA, to the extent that they relate to the safety

12 of the nuclear material on site.

13 MEMBER SIEBER: Yes, but there are places

14 where that condition doesn't bound you, doesn't bound

15 the process, where a straight chemical release could

16 occur, not affecting an employee but affecting

17 offsite.

18 MR. HILTZ: The reality is that if it

19 occurs at an NRC-licensed facility, we're going to

20 respond, and worry about, you know, was that really an

21 EPA lead or was that really an NRC lead. If it's one

22 of our licensed facilities and there's an event, we're

23 going to respond to make sure, to the extent that we

24 can, that the public is protected.

25 MR. LAFLIN: And as the licensee, if we
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1 have a chemical release from the facility, we're

2 concerned about the safety of the employees and the

3 public and the environment, regardless of who the

4 regulatory agency is.

5 MEMBER SIEBER: That's right.

6 MR. LAFLIN: I mean and that's been our

7 attitude throughout, through this process for safety.

8 Regardless of who the regulating agency is, we

9 recognize these chemicals are toxic and reactive, and

10 they've got to be handled safely.

11 But the advantage we have is that even

12 though this is a new facility, the chemical industry

13 has been producing these gases and transporting these

14 gases and safely handling these gases for decades in

15 the U.S.

16 MEMBER BANERJEE: Well, not so safely.

17 MR. LAFLIN: Safely. I think if you look

18 at the industry records for these, you know, it's a

19 phenomenally safe record nationwide for transporting,

20 manufacturing and producing HF and these other

21 fluoride compounds. It has to be. We're partnering

22 with chemical companies that will actually work with

23 us to take our product.

24 So the industry standards, the best

25 practices, the OSHA requirements for packaging, for
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1 shipping, for containing, for dealing with all of

2 these materials, we're not going to invent that.

3 We're not experienced with that. Our commercial

4 partners that handle these gases are, and we're going

5 to rely on that part of it.

6 MEMBER SIEBER: Well, there's a lot of

7 agencies involved. 

8 MR. LAFLIN: Absolutely. I mean the only

9 thing which is difficult in transporting radioactive

10 material is transporting fluoride products. 

11 MEMBER SIEBER: That's right.

12 MR. LAFLIN: I mean it's actually harder.

13 The requirements are tougher, and the carriers are

14 fewer and farther between.

15 MEMBER SIEBER: Right. That comes under

16 --

17 MR. LAFLIN: You know, it takes a great

18 deal of thought.

19 CHAIRMAN RYAN: Thank you. That's

20 helpful. Matt, press on. Let's see if we can get

21 through your slides.

22 MR. BARTLETT: Right. In addition to the

23 ISA summary, they also have to design the facility to

24 meet the baseline design criteria, which is kind of a

25 minimum level of quality that they have to incorporate
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1 in their design. It includes defense indepth, which

2 is multiple layers of protection against accidents. 

3 MEMBER BLEY: In your area, do you have

4 more specific definition of what defense indepth

5 means, for the staff in this area?

6 MR. BARTLETT: There's definitely a

7 definition in the regulations.

8 MEMBER BLEY: Okay.

9 MR. BARTLETT: Of defense indepth. It's

10 actually in the regulations.

11 MEMBER BLEY: Is it?

12 MR. BARTLETT: Yes, yes.

13 MR. FLACK: Part 70 says it, defines

14 defense indepth.

15 MR. BARTLETT: It is defined in Part 70?

16 I don't have it.

17 MEMBER BLEY: The more general one.

18 MR. FLACK: Well, it has to do with less

19 reliance on human actions, and more reliance on

20 hardware, I guess, technology provides the extra

21 defense indepth, and it's defined in that regard.

22 It's almost like a degraded definition. I forget the

23 exact words, but it's less reliance on administrative

24 control; more reliance on hardware and technology.

25 MEMBER BLEY: Two things. Where did you
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1 say it is in the regulation, Part 70?

2 MR. FLACK: Part 70.

3 MEMBER BLEY: And is there a way you guys

4 interpret this within NMSS, or the way you try to

5 enforce defense indepth? On the reactor side, they do

6 it a couple of different ways, depending on who you're

7 talking to. I wonder in the materials area if there's

8 a --

9 MR. BARTLETT: Yawar, do you want to touch

10 on that at all?

11 MEMBER BLEY: Or do you just say Part 70?

12 MR. FARAZ: Well, I think John is

13 absolutely correct. Part 70, I don't have the regs

14 with me, but it does talk about defense indepth as a

15 requirement, and then that's immediately followed by

16 giving preference to passive design features, and then

17 next would be active, and then followed by

18 administrative.

19 MEMBER BLEY: So I guess what I'm asking

20 is when you get an application like this one, and

21 you're reading some part of it, and you say are we

22 meeting our defense indepth criteria, what do you look

23 for? What makes you say yes or no?

24 MR. FARAZ: As I interpret the

25 regulations, there should not be a single failure that
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1 separates a significant consequence from the material.

2 So the material should not --

3 MEMBER BLEY: So that's kind of the

4 operational definition?

5 MR. FARAZ: Yes, and when you have layers

6 of protection, like for instance you have the UF6,

7 which is a very toxic material. It's in a cylinder.

8 The cylinder, while the UF 6 is liquefied and in a

9 liquid state, it has to be in an autoclave, which is

10 like a secondary containment. 

11 Then beyond that, the workers need to be

12 trained, and if there is a release, then they need to

13 leave, evacuate, get away. So these are these

14 multiple layers of protection, which essentially feed

15 into the defense indepth definition. 

16 MEMBER BLEY: Okay. But operationally,

17 you kind of look at it for no single failure?

18 MR. FARAZ: That's exactly right, yes.

19 MR. FLACK: Yes. If I could just follow

20 that up a little bit. I know in the MOX review, they

21 said they didn't give credit for defense indepth, when

22 they look at the sequence. In other words, they

23 credit the IROFS.

24 Then you look at what else is there beyond

25 the IROFS, but you don't credit that as part of the
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1 reduction in sequence. So that it's an extra sort of

2 defense against whatever that sequence might be.

3 MEMBER BLEY: I was looking for how they

4 interpret that.

5 MR. FLACK: Oh, I'm sorry. I just --

6 MEMBER BLEY: That's what I'm after, not

7 a philosophical answer.

8 MR. BARTLETT: Okay. Let me just touch on

9 this slide briefly. So International Isotopes. NRC

10 is developing an EIS for this review. We did publish

11 an opportunity to request a hearing. There weren't

12 any requests for a hearing. International Isotopes

13 and the NRC are both using guidance on NUREG-1513,

14 which basically tells the applicant how to develop an

15 ISA, and the NUREG-1520 is our standard view plan, and

16 we've already talked about that a lot.

17 Let me just flip through this. So the

18 NUREG-1520 was originally written for Part 70. It

19 applies to Part 40, because the requirements are

20 similar, and they're doing an ISA. It has, covers

21 multiple areas of review, and it's got a list of

22 acceptance criteria, which basically spell out the

23 commitments that the application should have.

24 The review team, you know, looks at the

25 application, to make sure that the International
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1 Isotopes has met those acceptance criteria. 

2 I just want to emphasize that the safety

3 review, the quality of the safety review really is

4 dependent on the safety review team. We've got 18

5 technical areas with at least one, sometimes multiple

6 individuals who are focused in on that area, and

7 reviewing the application in that area.

8 The review team develops, if they run into

9 places where they need more information, they develop

10 Items Relied On For -- they develop requests for

11 additional information. We've had about 174 that

12 we've submitted to International Isotopes. It

13 provided fairly quality responses for all of those.

14 It was mentioned earlier that the RAIs are

15 done. That's true. The first set of RAIs are

16 completed. We have a few follow-up questions, maybe

17 in the range of 20-25, where we need additional

18 clarification. Okay. Let me just touch on the

19 status. So we received the application December 31st,

20 2009. We accepted it for formal review on February

21 24th, 2010.

22 Shortly after that, we published the

23 opportunity to request a hearing and didn't receive

24 any requests.

25 MEMBER BLEY: I'm just curious. Is that
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1 unusual or --

2 MR. BARTLETT: It's a good sign. It's a

3 good sign that the people in the area are comfortable

4 with the application.

5 CHAIRMAN RYAN: Right, and other

6 regulators also?

7 MR. BARTLETT: Yes.

8 MR. HILTZ: I can also tell you that for

9 the AREVA Eagle Rock, there's a mandatory thing about

10 that. But we published a request, and we got no

11 requests for it.

12 MEMBER BLEY: No requests.

13 MR. HILTZ: So I don't know whether it's

14 typical or not. It probably depends on the area.

15 MEMBER BLEY: I'm just curious. Why is

16 there a mandatory hearing?

17

18 MR. HILTZ: It's required by regulation.

19 MEMBER BLEY: Because of the --

20 MR. HILTZ: Because it's an enrichment

21 facility.

22 MEMBER BLEY: Oh, okay.

23 MR. BARTLETT: Yes. The Part 40 doesn't

24 have a mandatory hearing, just this opportunity to

25 request one.
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1 MEMBER BLEY: Okay.

2 MR. BARTLETT: Okay. From that time until

3 just recently, we've been working on RAIs, RAI

4 responses. As I said, they submitted their last RAIs

5 just recently here in May. So now we're going into

6 the development of the SER phase, the safety

7 evaluation report. I think we're on schedule to

8 complete that in the September time frame.

9 CHAIRMAN RYAN: And Matt, just for the

10 Subcommittee's benefit, let me interject here. That

11 September time frame is the time frame where I think

12 the Subcommittee could reengage on, you know, getting

13 close to the end of the safety evaluation report,

14 moving into the EIS. That's probably a productive

15 place for us to say how we're doing at this point, and

16 then consider a full committee briefing and perhaps a

17 letter at that point.

18 MEMBER BANERJEE: Are we required to write

19 a letter on the SER?

20 MR. FLACK: No, you're not. This is sort

21 of outside the scope of ACRS activities.

22 CHAIRMAN RYAN: Yes, it is. So you know,

23 if the committee chose to, you know, I could make that

24 decision for the committee. But I think just

25 reengaging at that point is not a bad place to think
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1 about it. It's not mandatory.

2 MR. HILTZ: It's probably important to

3 point out, though, that if we have to engage you and

4 if we have to wait until a letter, then it's going to

5 impact our review schedule.

6 CHAIRMAN RYAN: I understand that. But

7 you know, recognizing that I cannot make the decision

8 for the committee to write or not write one. 

9 MR. HILTZ: I understand. I just wanted

10 --

11 CHAIRMAN RYAN: But certainly, I think,

12 reengaging on where you are and what your findings

13 are, at the point of where the SER is coming to

14 closure would be a good point to revisit.

15 MEMBER BLEY: On that, you listed

16 categories of RAIs. So are there any of the RAIs --

17 MR. BARTLETT: Should we go back?

18 MEMBER BLEY: I don't think you need to,

19 that you think might end up being contentious or

20 difficult, or are they pretty much information items?

21 MR. BARTLETT: The Round 1 of RAIs and the

22 responses have been very, very detailed and good

23 quality.

24 MEMBER BLEY: Okay.

25 MR. BARTLETT: You know, I mean for
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1 example, we might have sent them 20 RAIs and they sent

2 back an 80 page response --

3 MEMBER BLEY: They covered it pretty well?

4 MR. BARTLETT: Yes, they covered it pretty

5 well, and they provide not only, you know, a

6 discussion on what the plan to do, but changes they're

7 going to make to the application, to address our

8 concerns. So pretty good.

9 The seismic structural area, you know,

10 they're still working on that piece of that. The

11 detail design isn't done. So some of those questions

12 are more a time issue, and that's why we have a couple

13 of follow-up questions where we're requesting

14 additional detail that just haven't been available so

15 far. 

16 MEMBER BLEY: With respect to the seismic

17 one, I'm assuming that under any of these scenarios,

18 the biggest hazard is always HF?

19 MR. BARTLETT: Yes.

20 MEMBER BLEY: Right. I don't know the

21 process well enough. Do they have substantial volumes

22 that are still in the UF6 state within the system, or

23 is that pretty much goes in and begins the chemical

24 change very quickly? Are there large volumes, within

25 the system, of HF?
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1 MR. BARTLETT: They can probably answer it

2 better, but I think our concern would be if you had

3 a cylinder that's partially liquefied in an autoclave,

4 and then you had a seismic event that would cause --

5 MEMBER BLEY: The front end of the

6 process, okay. Good enough. Thanks.

7 MEMBER BANERJEE: Well, you can get into

8 the process a little bit under closed session. You

9 can tell us about the reactor, potential runaways and

10 all this stuff. 

11 MEMBER SIEBER: It's exothermic, but you

12 still have to add heat to it to make, to bring it to

13 completion. 

14 (Simultaneous speaking.)

15 CHAIRMAN RYAN: Let's wait until we get in

16 a closed session, please.

17 MEMBER BANERJEE: We don't know the

18 details of the process yet.

19 MEMBER SIEBER: It's all in the

20 application.

21 MR. HILTZ: I just want -- Dr. Ryan, I

22 just want to be clear that, you know, we said the RAIs

23 are completed, International Isotopes did. There will

24 likely be some supplemental RAIs that go out, based on

25 their responses.
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1 CHAIRMAN RYAN: I wouldn't expect it to be

2 anything less.

3 MR. HILTZ: So we may have another --

4 CHAIRMAN RYAN: That's fine. I'm going to

5 guess that's going to be a narrower set of questions,

6 definitely more specific.

7 MR. HILTZ: It's going to be narrower,

8 yes.

9 MEMBER SIEBER: We were sent a disk, just

10 for the member information, that's got a lot of

11 hotlinks in it that Derek provided, and you have to be

12 on the Agency website for the hotlinks to work. They

13 have all the RAIs and the answers and the application.

14 So all that detail is available.

15 CHAIRMAN RYAN: Thank you.

16 MEMBER BLEY: It is, given infinite time.

17 (Simultaneous speaking; laughter.)

18 MR. BARTLETT: I just wanted to also

19 mention, keep in mind that there's an EIS review

20 that's also ongoing, empaneled by a different review

21 team that the environmental folks. That's projected

22 to have the draft EIS completed in November, the final

23 in May, and then if we decide to issue the license,

24 the license would be issued some time in the June 2012

25 time frame.
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1 Just in conclusion, keep in mind that this

2 is a facility that will be regulated under Part 40.

3 They are also meeting the Part 70 ISA requirements,

4 and they are meeting the acceptance criteria in NUREG5 1520. That concludes my portion.

6 MR. FLACK: Mike, can I give more

7 clarification?

8 CHAIRMAN RYAN: Please, yes.

9 MR. FLACK: Yes. Back to the scope of the

10 ACRS activities, it's within the scope of the ACRS to

11 look at Part 40 facilities. It's not required for the

12 licensee to come through the ACRS to get their license

13 approved. I guess that was the difference. 

14 MEMBER BANERJEE: Explain it, John.

15 MR. FLACK: Okay. So the regulations

16 require for certain facilities that they have to come

17 to the ACRS, before they get their license approved.

18 Part 40 facilities, as well as Part 70 facilities

19 actually do not have to, by law, come through the

20 ACRS.

21 But I think Tom came to the ACRS, wanting

22 to show what was done as a matter of interest on the

23 Committee's part, and that's why a letter was not

24 envisioned to be required. But it's up to the

25 Committee, of course, to write a letter at their own
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1 discretion.

2 CHAIRMAN RYAN: And I think at this point,

3 this meeting is certainly an introductory, I think,

4 Subcommittee briefing, where we're learning and of

5 course asking the usual 10,000 questions the

6 Subcommittee has asked and learning.

7 And, you know, as you get to your next

8 step and as we digest all the materials and learn all

9 that, then we'll be in a position, as a Subcommittee,

10 perhaps meet with you again down in that EIS time

11 frame, September-ish or so or maybe a little before

12 that comes in or as it comes in or a little after, and

13 then be in a position to recommend to the full

14 Committee a briefing, and whatever action the full

15 Committee takes from there is the full Committee's

16 decision. But I guess I'm just trying to get our --

17 MR. WIDMAYER: Could we address the

18 scheduling item again?

19 CHAIRMAN RYAN: Why don't we do that --

20 MR. WIDMAYER: Well, I was thinking that

21 we have some folks, I think, that showed up for the

22 research presentation. Could we do that at the

23 scheduled time, and then do the closed session after?

24 CHAIRMAN RYAN: We certainly could.

25 MEMBER BANERJEE: What is the research
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1 presentation?

2 CHAIRMAN RYAN: The last part of the

3 briefing, on number three. Okay, fair enough. Fair

4 comment, and we'll do that. We will take a break at

5 five minutes of 4:00. We'll then pick up with our

6 Item 3 on the agenda, the qualitative HRA for cask

7 drops. Is that what you're talking about?

8 MR. WIDMAYER: Yes sir.

9 CHAIRMAN RYAN: And we'll get that done

10 and then go on in closed session from there.

11 (Simultaneous speaking.)

12 CHAIRMAN RYAN: Order, please. 

13 MEMBER ARMIJO: Sorry. I thought we were

14 --

15 CHAIRMAN RYAN: No, we're not.

16 MR. WIDMAYER: Before 4:45?

17 CHAIRMAN RYAN: I hope to get our break

18 done, and then hopefully get through about on time or

19 a few minutes thereafter at 4:45, so we can move into

20 the closed session therein.

21 MEMBER BANERJEE: When are we expecting to

22 finish?

23 MEMBER BLEY: Right after that.

24 CHAIRMAN RYAN: Right after the closed

25 session. Depends on how many questions you ask.
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1 MR. WIDMAYER: Yes. It's all up to you.

2 CHAIRMAN RYAN: You're in control. That

3 fate is in your hands. Thank you. We'll take our

4 break. The record's closed for the moment. We'll

5 resume about five minutes to 4:00.

6 (Whereupon, a short recess was taken.)

7 CHAIRMAN RYAN: All right. We'll continue

8 our briefing portion with the briefing from Research,

9 and Susan, are you leading us off?

10 DR. COOPER: I am. 

11 CHAIRMAN RYAN: Susan Cooper, take it away

12 please.

13 DR. COOPER: Thank you very much,

14 Chairman. Dr. Susan Cooper from the Office of

15 Research, Division of Risk Analysis, Human Factors and

16 Reliability Branch. Thank you very much for having me

17 here, and I very much appreciate you accommodating the

18 presentation at this time, as opposed to later in the

19 day, after your closed session. Very much appreciate

20 it. 

21 CHAIRMAN RYAN: Fair enough.

22 DR. COOPER: Just to let you know, I'm

23 joined by my colleague in the Human Factors and

24 Research Branch Julie Marble here, Dr. Julie Marble,

25 who's one of the now co-managers of the medical work,
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1 and also we have Dr. Bill Brown from Brookhaven

2 National Laboratory. He's one of our contractors on

3 the medical work.

4 Dr. Jeff Brewer from Sandia National

5 Laboratories was at the more or less last minute not

6 able to join us, and he is supporting research on the

7 spent fuel handling work that you'll be hearing about

8 today.

9 So there, as you may already sense, there

10 are two broad projects that are captured under the

11 umbrella here of risk-informing nuclear materials.

12 We'll get more into that as we get into the

13 presentation. Thanks. So I'm going to try to do

14 three things today in the hour that I have.

15 I'm going to give you some background on

16 these projects for risk-informing nuclear materials.

17 I'm going to try to summarize the efforts to date,

18 including the early efforts, and then provide some

19 excerpts of this work, and I want to emphasize

20 excerpts, because you might have noticed that there

21 are quite a number of slides. I know I can't present

22 them as you might ordinarily present those slides in

23 the time I have.

24 So in many cases, I'm going to, you know,

25 treat those slides as illustrations of the work that
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1 we've done. Of course, if you have detailed or more

2 probing questions, please go ahead and ask them, and

3 then we can try to explain.

4 Those excerpts will be divided between our

5 work on the qualitative HRA for cask drops, which has

6 been performed by Sandia National Laboratories, and

7 then the work on risk-informed tools for medical

8 applications, which has been done largely by

9 Brookhaven National Laboratory and more recently by

10 commercial contract under the WreathWood Group.

11 So going back in time, there was a user

12 need from NMSS in 2003, asking the Office of Research

13 to develop HRA capability across NMSS, as part of an

14 overall effort to risk-inform NMSS. The user need

15 identified two different phases to be addressed by

16 research, and those phases were first for a

17 feasibility assessment, for developing HRA capability,

18 and then Phase 2, which was called implementation, but

19 in actuality means go ahead and develop that

20 capability that you identified.

21 Right off the batt, the Office of Research

22 divided these efforts into two part, one part looking

23 at high level waste, spent fuel handling, fuel cycle

24 and so on, and another part to looking at medical and

25 industrial applications of byproduct materials.
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1 Feasibility studies were done for each of

2 those efforts, those parts. Brookhaven performed the

3 feasibility study for byproduct materials. That was

4 completed in 2003.

5 Research did an in-house feasibility study

6 on the high level waste fuel cycle, spent fuel

7 handling so on and so forth, partly because the high

8 level waste part had to be done in-house. Although

9 maybe Dennis doesn't remember, but he did provide

10 input to that feasibility report.

11 Part of the materials that were provided

12 to you ahead of time through John Flack included the

13 feasibility study from Brookhaven that was tasked 1

14 through 4 in the larger document of letter reports.

15 Phase 2 development then followed from

16 those initial studies. Brookhaven continued to work

17 on the medical applications of byproduct materials,

18 and I'll talk a little bit about how that was chosen,

19 and then Sandia National Labs began the work on spent

20 fuel handling. Again, I'll talk a little bit about

21 that.

22 So first, spent fuel handling. The

23 feasibility study didn't identify an initial focus for

24 efforts and for developing HRA capability. You know,

25 as you can see from perhaps looking at the letter
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1 reports from Brookhaven, there were specific tasks

2 identified as part of the feasibility study;

3 literature reviews, interviews with staff, so on and

4 so forth.

5 And there just wasn't a conclusive answer

6 out of the feasibility study partly, I guess, because

7 it was quite broad. But as a follow-up to the

8 feasibility study, staff from NMSS requested that

9 Research focus in on the possibility of misloads in

10 fuel handling, and cask drops. 

11 We did some work on that. You have, we

12 provided you with ADAMS ML numbers for two different

13 reports, one of which is on the misloads and cask

14 drops work, and then another one, later than where we

15 focused even more on cask drops and developing some

16 insights on potential human performance

17 vulnerabilities.

18 So there are two different reports that

19 are right now in research management review. Sean

20 Peters, my branch chief, who is also here to support

21 me, just finished up his review on those reports, so

22 actually since Sandia's not here, maybe he can answer

23 the questions, because he just read them in detail.

24 So there are those two reports representing that work.

25 I will say though, as another follow-on,
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1 the Division of High Level Waste, provided research

2 with another user need. I don't have it here. It was

3 in 2005, I believe. I have it in one of my folders,

4 if you're interested in the user need number,

5 requesting Research support to help them prepare for

6 reviewing DOE's application for the Yucca Mountain

7 Waste Repository, and also doing that review, and

8 Research did do that, did do that work.

9 Moving on to medical applications then,

10 the feasibility study, which again involved literature

11 review, interviews of staff and management, did

12 provide some direction for the Office of Research for

13 follow-on work in Phase 2. The first recommendation

14 was to start with medical applications, leave

15 industrial applications for a later job.

16 The other thing was that while there were

17 a number of different things, products, if you will,

18 that were of interest, the consensus was that the top

19 priorities were training and the development of some

20 sort of job aid to help staff.

21 Follow-up interactions with staff also

22 helped to identify, then, a list of initial human

23 performance topics that we should focus on, and also

24 to look at the Gamma Knife treatment as a test bed

25 for, you know, developing this follow-on work and this
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1 HRA capability. 

2 I should say in both cases, both the spent

3 fuel handling and the medical applications, the user

4 offices were interested in principally qualitative

5 support, as opposed to quantitative support at HRA for

6 PRA. They were more interested in HRA qualitative

7 insights and so that's been our focus from the

8 beginning.

9 So let's look a little bit at some of the

10 excerpts from the qualitative HRA for cask drops. I

11 think almost all -- I think all of these slides come

12 from a presentation that was also provided to you

13 ahead of time, a presentation that was made at PSA

14 2011 in March of this year in Wilmington, North

15 Carolina. It's mostly based on the more recent work,

16 but there is at least one slide that talks a little

17 bit about the early work.

18 Next slide. So the analysis approach for

19 the spent fuel handling work, building on what was

20 done in the feasibility study, gathered a lot of

21 information about the spent fuel handling process,

22 talking to subject matter experts, reviewing reports

23 and previous analyses. I would like to point out the

24 subject matter experts included not only folks from

25 NMSS but also some folks from our regional offices,
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1 especially Region IV.

2 Then following that work, we then started

3 to develop some scenarios, accident scenarios or

4 scenarios that would develop into a potential cask

5 drop. The approach that we used is an approach that

6 comes from the ATHEANA HRA method. ATHEANA is an NRC7 developed method that both Dennis and I are authors

8 on, and we're using a principally a haz ops sort of

9 approach, to try to develop how something could

10 happen, how something could happen starting with, you

11 know, this is what you expect to happen and then how

12 could things go wrong.

13 This is based on our understanding of

14 human performance from some of these subject matter

15 experts, the process as a whole and what we understand

16 about human behavior in general. So we identified

17 unsafe actions, things that you might model in the PRA

18 if you had a PRA, which we call human failure events,

19 and the context in which these sorts of things happen.

20 I should say that these scenarios have

21 been reviewed not only by folks in NMSS and Region IV,

22 but also Sandia National Laboratory had some of their

23 structural engineers review them also for, you know,

24 whether or not they're credible scenarios. So there

25 is quite a number of layers of review, to try and make
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1 sure that these scenarios were credible scenarios.

2 MEMBER BANERJEE: How do you use haz op3 type methodology for a scenario like a cask drop?

4 DR. COOPER: Well, if you start off with

5 how you expect the operation to occur, and one of the

6 appendices in the reports talks about the overall

7 steps in the process. So that's what you expect. Now

8 you start to use key words in haz op processes, to see

9 if you make changes to how things are happening, how

10 could that result in a negative consequence.

11 MEMBER BANERJEE: You would normally have

12 to divide any batch operation into sort of its

13 constituent actions, like load this, move that, and so

14 on.

15 DR. COOPER: Yes.

16 MEMBER BANERJEE: So you can actually do

17 that with --

18 DR. COOPER: Well, we did. I mean partly,

19 I mean because we did have the subject matter experts.

20 We also, I guess I should say, we started this work

21 not long after the NRC's -- I'm going to get it

22 confused with the EPRI report. One is the dry cask

23 storage PRA and the other one is the other one.

24 But the bottom line is that we had

25 videotape from one of the plants, to see how the
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1 operations were performed, and then Jim Pearson, who

2 is my contact over in NMSS, provided us with some

3 other videotapes from utilities, so we can observe

4 them.

5 Unfortunately, we never were able to match

6 up with a particular plant to go there and observe

7 things in real time.

8 MEMBER BANERJEE: But you were able to

9 divide them into constituent actions, step by step?

10 DR. COOPER: Yes, yes.

11 MEMBER BANERJEE: And then look at, use

12 the guide words on each of those?

13 DR. COOPER: Yes.

14 MEMBER ARMIJO: Did you have access to the

15 procedures that they used for these cask drops, what

16 the plant's procedures are?

17 DR. COOPER: Not plant procedures, no, we

18 did not.

19 MEMBER BANERJEE: But do they have

20 detailed procedures which takes it step by step?

21 MEMBER ARMIJO: Oh yes.

22 DR. COOPER: They have procedures --

23 MEMBER BANERJEE: Well, if they do, then

24 that's what you use.

25 MEMBER ARMIJO: That's what I was asking
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1 why, yes.

2 DR. COOPER: Well -- 

3 MEMBER ARMIJO: Rather than having to

4 infer --

5 DR. COOPER: Unfortunately, we're going so

6 far back in time that I don't remember, and --

7 MEMBER ARMIJO: It puts you at a

8 disadvantage if you're trying to infer from a

9 videotape what they're actually doing.

10 DR. COOPER: Well, no. We did have some

11 support on that, and we were able to interact with

12 NMSS and regional staff to get some sort of guidance.

13 They do have procedures, but the nature of

14 the tasks they do are different than what we would

15 imagine, or what I'm more familiar with in nuclear

16 power plant control rooms, in that many of the tasks

17 that they do are what you might call loosely skill18 based, in the sense if you don't have detailed step19 by-step, you know, everything that you do

20 prescriptions.

21 For example, the operation of a crane. In

22 fact, you really wouldn't want to have a crane

23 operator having a book open in front of him while he's

24 manipulating the crane.

25 There are a number of disadvantages that
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1 you can easily think about that, space being one of

2 the limitations. Plus he really needs to be looking

3 at what he's doing, in order to make the crane operate

4 the way it should.

5 CHAIRMAN RYAN: Dr. Cooper, remember at

6 the recent used fuels meeting in Baltimore, there was

7 some discussion of that, that you know, procedures

8 might be prescriptive in some areas and not so

9 prescriptive in another. There was some conversation

10 that was very helpful, to understand that plant to

11 plant, cask type to cask type, you know, there were

12 lots of variations in how things got done.

13 The good news is, I think, the staff and

14 the licensees were talking that, you know, that's

15 seemingly coming to a centerline, where they're

16 beginning to have a more common understanding of what

17 the regulator's expecting and what, you know, when

18 they say "move the crane," this is what we really

19 mean, as opposed to what you think we might mean.

20 DR. COOPER: Yes.

21 CHAIRMAN RYAN: So that was an interesting

22 conversation. So I just offer that to you as an

23 example of it seems to me that there's effort to close

24 that gap.

25 DR. COOPER: Right, okay, and I guess
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1 you'll see in a later slide, or if you've looked at

2 the material in advance, that one of the insights that

3 we got was, you know, exactly that, that they don't

4 rely on procedures to -- for every step that they

5 take, because some of the behaviors that they, or the

6 reactions that they take, are such that it just really

7 wouldn't sense to do so. Yes.

8 MEMBER SIEBER: I think the kind of

9 procedures that you would have in the power plant

10 would say "lift the dry cask and place it in the spent

11 fuel pool," one step.

12 DR. COOPER: It might be a little bit more

13 detailed than that.

14 (Simultaneous speaking.)

15 MEMBER ARMIJO: I don't think so, Jack.

16 I think that's a disservice to what they do.

17 CHAIRMAN RYAN: That's the problem, yes.

18 MEMBER ARMIJO: No. I think they do quite

19 a bit more for something that important.

20 MEMBER SIEBER: Well, when we drop the

21 hook, that's all that was in the procedure.

22 MEMBER BLEY: That was some time ago,

23 Jack.

24 MEMBER ARMIJO: That's pre-TMI.

25 MEMBER SIEBER: It was, and we haven't
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1 used dry cask since.

2 (Laughter.)

3 DR. COOPER: Okay. Let's move on to the

4 next slide, in the interest of time. Over the course

5 of the two different reports, we've looked at two

6 different cask types, and I just want to point that

7 out.

8 In the earlier work, where Sandia looked

9 at both misloads and cask drops, only one of these

10 particular cask types was looked at, and then the --

11 and the second report, which was focused on cask

12 drops, we looked at both.

13 I don't want to get into the details

14 unless someone wants to bring it up, in which case I

15 might have to look at this report. But one of the

16 casks is different, and has fewer scenarios, partly

17 because of its design and in the rigging that limits

18 the number of cask drops or the types of cask drops

19 that can occur. So that's the main reason for this

20 particular --.

21 So in the more recent report, which is

22 destined to be NUREG CR 7016, we looked, as I said, at

23 two different cask types. We're looking at cask

24 movement from the spent fuel pool to a preparation

25 area, and for one of them from the preparation area to
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1 the transfer pit, and then for the other -- also

2 movement from the transfer cask to the storage cask.

3 In the earlier report, which strangely

4 enough has a higher number destined to be new NUREG

5 CR-7017, more phases in the handling of fuel are

6 addressed, but only one of the cask types is included.

7 Next slide. So these two slides, this one

8 and the next one, present a table of insights that we

9 developed, and this was developed at the request of

10 the user office. It's not, we haven't communicated

11 recently, but at one point in time, the idea was that

12 this could be useful input to inspection guidance for

13 NMSS and the regions.

14 So far as things that we found, based on

15 not only the events, but also how we developed the

16 scenarios, that things could actually be called

17 performance vulnerabilities.

18 You'll see that the first one, the first

19 two are related to procedures, and the second is

20 directly related to the conversation we just had about

21 limited reliance on procedures, which has sort of a

22 negative connotation.

23 But at the same time, as I pointed out and

24 it's in the far right column there, that many of the

25 operations are skill-based and don't lend themselves
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1 well to being guided by written procedures.

2 MEMBER BLEY: If I understand what you've

3 said, and if I understand this table, these aren't

4 necessarily things that one would say are

5 deficiencies; these are just, because of their nature,

6 places you think a review should take a good look.

7 DR. COOPER: I would agree with that. I

8 mean basically is, this is what it is, and you could

9 say that if there is a negative context, it basically

10 has to do with the fact that it's different than we

11 might expect for operations that are directed from the

12 control room. For example, like the limited reliance

13 on procedures. 

14 For control room operations, we have a

15 pretty strong focus in making sure that they've got a

16 formal procedure that they're using, for almost

17 everything they do, except for field operators. There

18 again, there may be some things that they're doing

19 that are not, you know, not every motion or every

20 action is going to be governed by procedures.

21 And there are other things like the visual

22 challenges, number seven. That's the nature of many

23 of the things that are being done, as part of cask

24 handling or fuel handling. Large distances, viewing

25 the cask under water, obstructions. The crane
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1 operator is often relying on people on the ground to

2 give them hand motions or use radios or whatever.

3 So there's a link, then, to number five,

4 the communication difficulties, because you know, he

5 just can't see. He doesn't have the viewpoint that's

6 needed to understand exactly where the cask is at any

7 point in time.

8 So this a collection of things that we

9 discovered as a result of, as I said, not only looking

10 at the events and talking with people, but also

11 developing the scenarios. Let me skip over then.

12 So in conclusion on this particular work,

13 we did introduce and use a process for developing cask

14 drop scenarios, also misload scenarios in the earlier

15 work, and we identified these human performance

16 vulnerabilities. We have some illustrated guidance.

17 I wouldn't say it's complete, but some

18 ideas of how you might mitigate or avoid some of the

19 negative connotations or negative outcomes that could

20 come from some of these vulnerabilities.

21 In doing the work, we did use the

22 qualitative guidance for HRA, coming out of the

23 ATHEANA HRA method and NRC's good practices HRA, for

24 HRA NUREG-1792. Both of those were used and were

25 proved to be helpful and valuable in being able to
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1 develop the scenarios and develop the insights that

2 were of use.

3 And the last item, the Office of Research

4 at this point in time used this work as a useful

5 basis for any potential future work, for HRA and PRA.

6 For example, the contemplated levels, Level 3 site7 wide PRA studies that might include spent fuel

8 handling in their scope. I don't remember what the

9 schedule is for the SECY paper that's going out to the

10 Commission, but I think it's some time this summer.

11 We'll see what happens with that.

12 But if that does go forward, I'm the

13 identified HRA lead for anything that's going in that

14 Level 3. So I look at this work and other people are,

15 as being a good useful step, everything short of just

16 the quantification and what are the numbers. So

17 that's all I have, want to just -- had prepared to say

18 about the spent fuel handling. So I'll move on to the

19 medical, unless you wanted to ask any more questions.

20 CHAIRMAN RYAN: Any specific questions at

21 this point? 

22 (No response.)

23 CHAIRMAN RYAN: Proceed on. 

24 DR. COOPER: Okay. 

25 MR. FLACK: I just have one question, if
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1 I may.

2 DR. COOPER: Yes.

3 CHAIRMAN RYAN: Please.

4 MR. FLACK: It seems like safety culture

5 cross all of these vulnerabilities, right? I mean if

6 you look at it from that perspective, that would kind

7 of influence any one of those. Has that been looked

8 at at all, the connection between safety culture and

9 the vulnerabilities?

10 DR. COOPER: There is a section on safety

11 culture in the more recent of the two reports on spent

12 fuel handling, one that's specific to cask drops. We

13 are -- that was developed some time ago, and there has

14 been more work done on safety culture. We'll be

15 looking at that, to see if that section needs to be

16 updated.

17 I'm not personally an expert in that, and

18 when we've talked about the influence of safety

19 culture on risk in a general sense, me being an

20 HRA/PRA person and an engineer, I like to look at an

21 observable basis.

22 So I'm not sure exactly how to make those

23 connections. But certainly looking at, having looked

24 at, in my career, a variety of different technologies,

25 and trying to evaluate human performance, there
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1 certainly is an influence. There's no question about

2 it.

3 How to measure it or how direct, or how

4 you would reflect it, is a question that I don't know,

5 I don't think anyone has addressed adequately at this

6 point in time.

7 I will say that one thing that we're

8 contemplating or kicking around right now in the

9 Office of Research is the notion of changing our

10 treatment of dependencies, especially things like

11 latent failures, undiscovered equipment failures that

12 might be the result of restoration failures that

13 operators would do, maybe looking at doing sensitivity

14 studies on the dependencies of that, and that might be

15 -- 

16 You might call that as coming from a

17 safety culture sort of origin, you know, changing how

18 you would look at those dependencies, or how many

19 dependencies you might have, how many undiscovered or

20 latent failures you might have in a scenario. We

21 might do. But that's not this work. This is, I guess

22 you could say that. 

23 But I mean we're mostly looking more at

24 the control room operations for that.

25 MR. FLACK: Specific to PRA.
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1 DR. COOPER: Yes. I haven't thought about

2 it for this.

3 MEMBER SIEBER: Did you mention that

4 there's two NUREGs that were just published on this

5 subject in February?

6 DR. COOPER: No. What I said is that

7 there are two reports, these two, that are currently

8 in research management review.

9 MEMBER SIEBER: Okay.

10 DR. COOPER: And they're destined to be

11 NUREGs, assuming that they don't get stopped in their

12 tracks somewhere.

13 MEMBER SIEBER: Is that the 7016 and --

14 DR. COOPER: Yes, 7016 and 7017.

15 MEMBER SIEBER: And 7017.

16 DR. COOPER: That's right. 

17 MEMBER SIEBER: Okay. I have -- I take it

18 it was published for comment?

19 DR. COOPER: No. 

20 MEMBER SIEBER: As final?

21 DR. COOPER: They were simply put into --

22 in order to be put into the concurrence process for

23 research management review, they had to be put into

24 ADAMS, in order --

25 MEMBER SIEBER: Right.
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1 DR. COOPER: So I think that probably

2 would be -- I don't know if it was February, but in

3 any case --

4 MEMBER SIEBER: But they're in ADAMS and

5 we have them.

6 (Simultaneous speaking.)

7 DR. COOPER: Yes, you have them because --

8 MR. PETERS: --time frame we could share

9 them with the ACRS, yes, the draft versions.

10 DR. COOPER: They're draft versions, but

11 they have not been published for public comment or

12 anything like that. 

13 MEMBER SIEBER: I just thought I'd mention

14 to the other members that we have them on that disk.

15 MR. FLACK: On the disk.

16 MEMBER SIEBER: That you provided us.

17 CHAIRMAN RYAN: Thank you.

18 DR. COOPER: Okay. All right. Let's move

19 on to medical. Again excerpts, and this time, I've

20 more prepared, because I've got Bill and Julie here,

21 handling the detailed questions, so go on, first

22 slide. 

23 All right. Aims and approach for this

24 particular project. First of all, obviously we're

25 trying to risk-inform again, as we were in the other
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1 case, but -- and we went to use HRA qualitatively or

2 incorporate the HRA perspective, to help NRC staff,

3 and principally to help provide a technical basis for

4 decision-making.

5 So the approach that we've taken for how

6 to provide this perspective is first of all, basic

7 information on human performance and error is

8 something that was identified as a useful product,

9 including the resources, literature that's relevant

10 and so on and so forth, to help understand human

11 performance and error in the medical context.

12 Specifically how we would get this across

13 is through two different products, which were

14 identified in the feasibility study, training

15 materials and what's called a job aid, which is a

16 structured knowledge base, and we'll try to show you

17 a little bit of that in a little bit.

18 I see some symbol came out funny in the

19 typing. But anyway, the training materials, and you

20 have these, it was in one of the ADAMS numbers that we

21 gave you, is representing what was in place in 2008.

22 The last time it was given in 2008, it was a two, two

23 and a half day course. We have a book which has the

24 slides and some notes in it, that was used there.

25
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1 Again, the job aid, we don't exactly have

2 it, because it's in our software, but cannot be put

3 into ADAMS. So there is a memo in the package that's

4 in the ADAMS, that says where you can get it. It's on

5 a disk.

6 Again, what we submitted is based on 2008.

7 There have been some updates made since then to the

8 job aid, including a change in software. So the

9 slides I'm going to present are principally based on

10 the 2008 version, but there are a couple that are a

11 little bit updated for 2010.

12 Training first. Basic topics, you know,

13 human error and medical applications, what are they;

14 what kinds of things are happening; what is human

15 error; what are the mechanisms and contexts in which

16 you could expect this human error; what's the current

17 thinking about how to understand human error; and then

18 a little bit about some of the retrospective events,

19 and how to understand them.

20 So those are some of the basic topics.

21 Like I said, I just sort of picked, cherry-picked some

22 specific slides out of the training, give you an idea

23 what's in them. This slide was put together by John

24 Reithall, who's one of our contractors, to try to give

25 a sense for where medical errors, you know, compare to
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1 other things that the NRC regulates and so on and so

2 forth. 

3 So if you look at this slide, you can see

4 where nuclear reactor risk is imagined to be, versus

5 where some of the other things are. So it's just kind

6 of basically to sort of sensitize people to what's

7 important.

8 Next slide. This slide, which has been

9 updated in the new material, but I just gave you

10 what's -- I show here what you've been given. It

11 shows you a little bit about what types of medical

12 events have occurred, as reported in NMED, which is

13 the database of medical events.

14 CHAIRMAN RYAN: I've got to ask, just out

15 of curiosity. The deaths, where are they in this

16 crap? Is it --

17 DR. COOPER: We have some folks, excuse

18 me, in the back. I'm not aware of NMED actually

19 specifically culling out different consequences, and

20 then capturing that as a data category. I've not

21 heard of that being talked about. I mean I guess

22 Bill, you've looked at the NMED database quite a bit

23 as well.

24 MR. BROWN: I agree with what you just

25 said. I don't recall that. We haven't used that
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1 split. I don't know whether it exists.

2 CHAIRMAN RYAN: No. I'm just curious.

3 You know, this administration is kind of what

4 happened, but the consequence part of that, is it a

5 no, never mind or is it significant or any of this

6 administration is significant because it's an error.

7 DR. COOPER: I'm certain that's important

8 to FSME, but I don't know that that's captured by

9 NMED.

10 CHAIRMAN RYAN: That's fine. Well, let's

11 move on.

12 MEMBER SIEBER: There was a case study

13 done that resulted in a Notice of Violation to an NRC

14 licensed hospital, where there were 180 cases of

15 misadministration over a ten year period, and they did

16 make the relationship between what the

17 misadministration was and what eventually happened.

18 DR. COOPER: Yes.

19 MEMBER SIEBER: And as I remember that

20 data, that looked pretty much like the chart that you

21 have on the screen right now, if you're going to be

22 consistent.

23 DR. COOPER: I guess if someone in the

24 back from FSME wants to correct it, I think that

25 perhaps part of the issue is that the NMED database
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1 captures information, as reported by the licensees

2 when they discover things, and that may or may not be.

3 But there's some delay time, I think, between where

4 they might discover that and when there may be a

5 consequence that they care about.

6 So that, and I don't know that they're

7 updated later with that kind of information. I guess

8 I don't particularly care.

9 MEMBER SIEBER: But my point is that what

10 you're showing us is consistent with what I've seen,

11 in a different context.

12 DR. COOPER: Okay. That's good. This is

13 just another one. Again, that's from 2007, but this

14 picture has not changed, as far as I know. Largely,

15 it's --

16 CHAIRMAN RYAN: I think you have an event

17 that you've listed, but you haven't reported it.

18 That's a funny one.

19 DR. COOPER: Well, this is a cause. They

20 just haven't reported the cause of the failure, of the

21 event. 

22 CHAIRMAN RYAN: They had an event and

23 we're not going to tell you what it was.

24 DR. COOPER: We're not going to tell you

25 the cause, that's all.
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1 (Simultaneous speaking.)

2 DR. COOPER: Or we don't know how to

3 define it or describe it, or it could even be that

4 there's no category provided by NMED that matches up.

5 CHAIRMAN RYAN: Ahh, maybe that's it.

6 Cause undetermined would be, I understand that.

7 DR. COOPER: So the next few slides are

8 trying to illustrate some of the ways, the material

9 that's in the training, to help people understand why

10 people make errors. This is Bill's stuff. If you can

11 -- I didn't realize there was animation in this.

12 Knowledge and error. Go ahead, Bill. This is your

13 slide.

14 MR. BROWN: Well, we just make some points

15 about what's called the new view of human error, and

16 the new view of human error goes back this from Mach

17 a century ago. We try to make the point that the

18 things that allow an organization or an activity to

19 succeed under normal circumstances is the very same

20 things that cause it to fail under circumstances that

21 aren't exactly what is expected. 

22 It's that we tried to key just a small

23 number of those sorts of insights to sort of pepper

24 our audience with, since on the material side you

25 don't have a group of human factors people working on
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1 it, as you do on the power side. This is -- these are

2 concepts --

3 MEMBER BLEY: Well, when we talk about

4 software things, we might have very similar things

5 going on. They were using a software system.

6 DR. COOPER: Yes, yes. At least within

7 Research, we are recognizing that and trying to marry

8 or exchange information, collaborate on the issue of

9 automation and software. The next slide, also Bill's.

10 Oh. 

11 MEMBER BLEY: Are you coming to our

12 meeting on Friday?

13 DR. COOPER: This, no.

14 MEMBER BLEY: The Subcommittee. It's not

15 the same subcommittee. It's another one on the same

16 contracting agency, contractor agencies, reporting on

17 modeling failures in software systems.

18 DR. COOPER: Oh. I think --

19 MEMBER BLEY: Even on that kind of stuff,

20 you might want to -- you might get something useful to

21 tell us. But go ahead. I'm sorry. That's not what

22 we're about here.

23 DR. COOPER: All right. That's okay. It

24 sounds like Julie's going to be here.

25 DR. MARBLE: I think that's the one I'm
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1 planning to attend.

2 MEMBER BLEY: Good.

3 DR. COOPER: Okay. I'm not going to go

4 through all of this. It goes into a little bit more

5 detail of what Bill just said, in that people's

6 behavior is almost always rational and practical and

7 economical, and conserves resources, and that works

8 most of the time. But every once in a while, it

9 doesn't work in the wrong context.

10 Another thing is that people follow

11 familiar paths, the pattern-matching --

12 MEMBER BANERJEE: I thought Plato said the

13 opposite.

14 DR. COOPER: Sorry?

15 MEMBER BANERJEE: I thought Plato said the

16 opposite.

17 DR. COOPER: He did, but no. When we talk

18 about people being rational, you make the best choice

19 based on the amount, the way you have synthesized the

20 information. But the problem is, is that can't

21 process all the information or hold all the

22 information in their active memory at one time. So

23 you can't sit there and weigh the balances. You don't

24 have the capability of doing it. 

25 Perhaps, you know, Big Blue, the computer,
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1 could do it. So people are rational, in that they try

2 to maximize and follow the heuristic. But they aren't

3 capable of holding al the information capable. So

4 they use heuristics and --

5 MR. BROWN: People refer to it as local

6 rationality, since you can't --

7 MEMBER ARMIJO: Well, yes.

8 MR. BROWN: It's not optimality.

9 MEMBER ARMIJO: Doing irrational things in

10 a rational way or what? Given --

11 (Simultaneous speaking.)

12 MEMBER BANERJEE: In an emotional way.

13 MEMBER ARMIJO: You know, you have

14 distractions.

15 DR. COOPER: Well, it's not just --

16 MEMBER ARMIJO: Let me ask a question.

17 But it just sounds like everybody doing a good, trying

18 to do a good job and everything else, and still make

19 most of the human errors.

20 But what about the people who are

21 distracted, talking on the cell phone, driving, trying

22 to multi-tasking when they shouldn't be multi-tasking,

23 human stress, alcohol, drugs, all these things. I'll

24 bet there are a lot of human errors in those events,

25 and they're not on the list.
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1 DR. COOPER: That's true. But let's just

2 think about the context, first of all, that we're

3 thinking about. We're thinking about the context of

4 a licensee that's regulated by the NRC, and so there

5 are certain things that we know aren't going to

6 happen. Okay. We have constraints.

7 MEMBER ARMIJO: That's kind of a certain

8 population data.

9 DR. COOPER: We have certain constraints.

10 Some of them have to do with the fact that they have

11 to be certified. They have to be inspected and so on

12 and so forth, so -- and the other thing is that there

13 are consequences, you know. You could argue that some

14 people probably shouldn't be talking on their cell

15 phone while they're driving, because there certainly

16 are consequences.

17 But on the other hand they've done them so

18 many times that they forget or they discount the

19 consequences. Now there are certainly times when

20 distraction or inattention can be an issue, and we're

21 going to talk a little -- we're going to give one

22 example here in a minute on the medical side.

23 Not so much of an issue when we're talking

24 about our licensees in the control rooms of nuclear

25 power plants, mostly they're pretty focused on what's
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1 going on and we've got their attention.

2 But when we're talking about maintenance

3 in nuclear power plants or even essential handling,

4 which can be a very, very long process, then we can

5 worry about attention and distractions and stuff like

6 that.

7 So different types of activities,

8 different contexts, different constraints. I mean

9 that's a really big thing, constraints on behavior,

10 requirements all these layers of constraint really do

11 allow us to focus in on certain behaviors, and

12 separate them from some of our normal every day things

13 that don't have large consequences.

14 Anyway, let's go to the next slide, and

15 this one's Bill's also, that has to do with

16 conditioning. So Bill, why don't you go ahead and

17 talk us through this one a little bit?

18 MR. BROWN: Well, I always said I put this

19 in here for two reasons. One is so that when people

20 read my slides over my shoulder on the airplane, they

21 think I'm a real doctor. The other reason is that

22 it's meant to show that when an activity's repeated

23 often enough, it becomes in some sense automatic.

24 It's not that you decide to pay less

25 attention to it. It just does, and that's what the
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1 brain scans are meant to show, before training and

2 after training. That activity gets reorganized

3 somewhat, and if I was a neurologist, I could tell you

4 what tasks those were and how the brain focus of them

5 is shifting. Basically, the color indicates brain

6 activity.

7 The point of this is that it's going to

8 happen, whether you want it to or not. So if the

9 nature of the task is reorganize the brain, due to

10 repetition, there's not much you can do about it, and

11 it happens because it's helpful.

12 In other words, if it can be made

13 automatic in some sense, that frees resources to do

14 more demanding activities. The downside is that

15 because it's less conscious, less consciously

16 governed, it's subject to distraction and it can go

17 wrong. There's something off normal in the

18 environment. That's why that's in there.

19 Again, another one of those insights we

20 hope people would take away, because we're not

21 interested in teaching a course in human factors or

22 design of medical devices. We're just trying to give

23 people an appreciation of certain small things that

24 might help them think about an event that they're

25 investigating, or a licensee request that they're
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1 evaluating.

2 CHAIRMAN RYAN: But I mean that's exactly

3 on this point is well, are they trained, you know? I

4 mean training's something we always look at and

5 inspectors always look at. What's the training record

6 look like? Now that you've given it some thought on

7 what to tie into. 

8 I mean it's, you know, have they been

9 trained in a way that's been locked in, and if they do

10 have a post-training behavior that's different than a

11 pre-training behavior, that kind of thing, that's very

12 helpful.

13 MEMBER BANERJEE: It's like hitting at

14 tennis ball, right. 

15 MR. BROWN: Yes. Playing a musical

16 instrument, driving a car --

17 (Simultaneous speaking.)

18 DR. COOPER: I guess the thing is that

19 when you're talking about something that's a little

20 bit less constrained like driving your car or

21 something like that, there are some subtleties that

22 change. Now some things may stay very much the same,

23 and those may become so practiced as to be automatic

24 and you don't pay attention to them.

25 Other things, you get used to dealing with
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1 certain slight contextual changes, and therefore then

2 you might be more prepared to deal with some

3 differences in the context, if you will. 

4 That can be important, and as a matter of

5 fact, I'm aware, at least, on our nuclear power plant,

6 side when we're training -- when trainers are now

7 training operators and simulators, they are trying to

8 not do the same thing every time. They're trying to

9 add in, you know, distracting, other equipment

10 failures or changing the timing of things and so

11 forth.

12 So the operators don't get locked into,

13 you know, the response is always going to be this way.

14 Whenever I see this pattern of alarms, it's always

15 going to be this way. Now, there's some differences

16 across plants as to how effective they are at doing

17 that. But that is the notion behind that kind of

18 variation in training.

19 But if you have a job that is quite

20 repetitive, you're doing most of the time the same

21 kinds of things, this kind of effect can be important.

22 As a matter of fact, the next slide is one example, at

23 least I think oh, it's got automation. Good. Keep on

24 going.

25 All right. So the notion here is we've
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1 got two different lines, and this is supposed to be

2 some very grossly defined steps in performing a Gamma

3 Knife treatment, where the basic steps, most of the

4 time are you enter the room where the patient is, and

5 you set coordinates, and then really you're cue then

6 to leave is that you're done with that task of setting

7 the coordinates, and you're done and you leave, and

8 treatment can proceed.

9 So if you have a different kind of

10 treatment, where you have change out the helmet, and

11 there are, have been events in the past where this has

12 been an issue. So you enter the room, you set the

13 coordinates. If you're more frequently used to just

14 leaving at that point in time, you might forget to

15 swap out the helmet, because you don't have a specific

16 cue to do that.

17 Now as I understand, there have been some

18 changes, even with the existing Gamma Knife devices,

19 where maybe they put very distinctive or noticeable

20 lettering on the helmet, so you know which one. So

21 there is some kind of cue to tell you, know, what are

22 you about to do. 

23 Obviously, you have to put that together

24 with okay, this is the helmet that needs to be there,

25 not that other one, in order for that cue to be
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1 useful. But you know, at a certain point in time

2 there were some events where they just simply forgot,

3 partly because they were more accustomed to leaving

4 right after that step of setting coordinates --.

5 MEMBER ARMIJO: I don't know anything

6 about Gamma Knife, but I presume this is a pretty

7 dangerous process if it's not done right, and it

8 wouldn't surprise me that if we were doing something

9 similar in nuclear work, there would be somebody who

10 would confirm that the coordinates were set right,

11 before somebody turned on the machine. Is this a

12 different, a different culture?

13 MR. BROWN: Double-checks are written into

14 the procedure. However, as the HRA people will tell

15 you, there are independent verifications and then

16 there are independent verifications. If the

17 verification is done right, it's very effective. If

18 it's just I read the prescription, I set the

19 coordinates, then you look at the prescription. 

20 Say you ask -- well, this activity is done

21 hundreds of times a day. Just doing the verification

22 the way I just said, sometimes isn't effective,

23 because it's always right and the effectiveness, the

24 independence goes away. 

25 MEMBER BLEY: If you don't think that
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1 happens in a power plant or even one of your old fuel

2 facilities, you're not right.

3 MEMBER ARMIJO: No. I know people make

4 mistakes, but I think there's --

5 MEMBER BLEY: And double-checks make

6 mistakes.

7 CHAIRMAN RYAN: Now, I think the point,

8 Sam, that I take away, and I agree with the point, is

9 that people get -- maybe complacent is one word to

10 use, but they're so used to doing it over and over

11 again, they sometimes see the answer they think is the

12 right answer, and not the answer that's right in front

13 of them.

14 DR. COOPER: That's exactly it.

15 MEMBER BLEY: If I always follow you and

16 you always do it right, no matter how good I am, I

17 starting well, this is Mike. If I'm following

18 somebody else, I'd look a lot more closely.

19 (Simultaneous speaking.)

20 CHAIRMAN RYAN: Yes. So I mean that's --

21 MR. BROWN: The example we use is instead

22 of doing it that way --

23 CHAIRMAN RYAN: Check my own coordinates,

24 maybe get a Gamma Knife.

25 (Simultaneous speaking.)
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1 MR. BROWN: --especially what you see, and

2 I'll see if it matches. That slight difference makes

3 a huge amount of difference in the joint probability

4 of failure.

5 CHAIRMAN RYAN: Well, they just -- you

6 know, the ACRS just had a tour of the Naval Training

7 Facility in Charleston, South Carolina, and they have

8 a very rigid process, just like you described, for

9 steps and procedures.

10 There's two people, you know. The first

11 one says it out loud; the second one repeats it

12 exactly out loud. Then the first one is observing the

13 second one doing it, and then they actually touch it

14 and verify it and --

15 MEMBER BANERJEE: That's a little bit like

16 the control room, right.

17 MEMBER BLEY: Yes. That was a control

18 room.

19 MEMBER BANERJEE: No, no. I'm saying even

20 in a nuclear plant.

21 MEMBER BLEY: They do something similar.

22 They don't quite do it --

23 (Simultaneous speaking.)

24 CHAIRMAN RYAN: Well they were dealing on

25 simple measurements and other things. It's pretty
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1 interesting to watch. But it was the kind of thing

2 you're saying, that if it's done with rigor, it really

3 does work. But if it's oh, you know, okay, looks

4 good. See you later. Coffee break or whatever it is.

5 DR. COOPER: Yes, and just in contrast, on

6 the misload work that was in the earlier spent fuel

7 handling study, we noticed that there were similar

8 sorts of things happening with the misloading.

9 I mean you've got one person on a crane

10 lifting, you know, rods out, and they're supposed to

11 be grabbing the right one, based on a list of certain

12 serial numbers, and they're looking at it with

13 binoculars and stuff like that.

14 Then there's somebody off to the side

15 that's supposed to be checking their work. Well, it

16 doesn't always work exactly that way. Then there have

17 been definitely some --

18 (Simultaneous speaking.)

19 DR. COOPER: Yes, and then, you know, this

20 is taking a long time and there are a lot of them and,

21 you know, something happened over here and boy, that's

22 real interesting. Yes, okay. You got that one too.

23 So you know, it's happened, and as a

24 matter of fact in the misloading cases, they don't

25 even necessarily know, because there's really no way
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1 to detect if you've just misloaded a single rod or

2 something like that, because the radiation detection

3 that they use can't pick that up.

4 So it's really, you know, they could have

5 things that have happened that they don't even know

6 about. The ones that they self-corrected, you know.

7 But anyway, let's go ahead and proceed, since I know

8 you want to wrap up soon.

9 So you know, one of the things that we

10 were asked to do was to take a lot at what NRC and

11 FSME in particular was doing with respect to root

12 cause analysis, because really what we were trying to

13 do was to try to help them take a step further. The

14 unknown database stops with, you know, human error.

15 We want to take it a little bit further to

16 what the causes are, because if you find the right

17 ones, you're going to be a little bit more effective

18 in either deciding what to do, or deciding what to

19 accept as a corrective action and so forth.

20 And this slide was just simply trying to

21 stress the idea that, you know, you look for what you

22 find. What you look for is what you find, and what

23 you find is what you fix. So if you're not looking

24 for the right things, then you're not going to end up

25 fixing the right things.
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1 You know, so some of the things, for

2 example, NMED looks at, you know, inattention to

3 detail, failure to follow procedures and stuff like

4 that. It doesn't really give you a complete

5 understanding of why that happened or what would be a

6 useful thing to do. That doesn't fully explain, you

7 know. 

8 There's an example on the backup slides

9 for an event in Beatson, which is in the U.K., which

10 is interesting and it explains a little more detail on

11 the --

12 CHAIRMAN RYAN: 74 percent of the most

13 common errors cited are basically inattention to

14 detail, and failure to follow procedures is

15 inattention to detail too. So that's amazing.

16 DR. COOPER: Next. Okay. So now we're

17 going to just give you some excerpts, give you an idea

18 of what the job aid is. Next. So the notion behind

19 the job aid is that once you've had the training, then

20 you can use a structured, filtered knowledge base on

21 what human performance issues ought to matter in

22 medical context, and specifically looking at Gamma

23 Knife.

24 And the way we tried to structure this

25 information is to -- with the aim of trying to find
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1 causes and look for effective fixes, and basically

2 just kind of make sense of what might be going on in

3 like an event, or what you might be looking for that

4 would be important.

5 So what's in the job aid? We've got

6 several different things. We've got summaries of

7 human performance topics, and I want to emphasize

8 that, you know, from if you looked at one of the

9 tasks, letter reports that Brookhaven developed,

10 there's a pretty long bibliography on different human

11 performance topics.

12 So what NRC's contractors have done is

13 take, you know, distill that information, that large

14 body of information, into something that more layman

15 types can understand, and then also focusing on those

16 issues, or those aspects of those human performance

17 issues that are important in medicine.

18 MEMBER BANERJEE: Can I ask you a question

19 on this?

20 DR. COOPER: Sure.

21 MEMBER BANERJEE: At least anecdotally, it

22 appears that if you're under stress, a high level of

23 stress, you perform better.

24 For example, a surgeon who does surgery,

25 brain surgery, he may have done it a thousand times,
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1 does a much better job than a nurse, for example,

2 attending a patient who she sees or he sees

3 sporadically, because they're watching the heartbeat

4 or something, and they forget. They're in the

5 intensive care unit or maybe whatever.

6 So stress actually seems to be a positive

7 factor. In fact, in chemical plants, this is very

8 well understood, that people in the control room, who

9 basically only will be needed to do some very few

10 actions, become bored and they don't do them. But if

11 they're continuously having to do something under

12 stress, they do them rather well. I mean it seems

13 inversely correlated. 

14 DR. COOPER: So first of all, yes, you are

15 correct. There are cases, and there's literature and

16 research to support the fact that there is an optimal

17 level of stress, and it's not zero. I mean you can --

18 anecdotally you know that, you know, people that can

19 perform in, you know, in basketball games or sporting

20 events, you know, there's a certain level of

21 excitement and stress, and they perform better than,

22 you know, against an anniversary, you know, a highly

23 competitive game, as opposed to one that maybe isn't

24 quite as competitive.

25 Operators I've talked to or former
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1 operators I've talked to say that, you know, the

2 adrenalin level goes up and you're in the groove and

3 you're responding to things and so on and so forth.

4 As a matter of fact, some of the

5 literature that we looked at recently actually

6 indicates that a more likely time, perhaps, when you

7 might have an error would be after that stress level

8 drops, after sort of the high is stopped. You think

9 that everything's under control.

10 That might actually be the time when it

11 might be more likely that you would make some, you

12 know, like slip or inattention, because now you think

13 things are under control, and you don't have to worry

14 so much. So I would agree that that's the case.

15 Now we don't have that necessarily

16 reflected in everything that we've done, especially in

17 HRA. Some of the newer work that we're doing, that we

18 hope to factor into like our HRA methods to support

19 PRA, we hope that that will be happening. What we're

20 doing, we're very much aware of that. We're just

21 trying to use the psychological literature to

22 understand that.

23 MEMBER BANERJEE: That's the reasons I'm

24 asking you, is that on another front I'm chairing

25 something which has to do with the next generation
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1 safety analysis code, which is not an NRC activity.

2 It's a DOE activity.

3 DR. COOPER: Okay.

4 MEMBER BANERJEE: And they're trying to

5 factor in a lot of things, but it's going to be risk6 informed safety management characterization, margins

7 characterization. So they have human factors, PRA,

8 all this stuff going with neutronics and other things.

9 What is really difficult is the human factors aspect,

10 and how you have a sequence of events, many of them

11 which are unexpected, and how you factor that in, into

12 the safety margins characterization.

13 But it needs a history. It's not like

14 each action can be called off in isolation. You have

15 to, you know --

16 DR. COOPER: Yes, absolutely. We actually

17 just heard a seminar from one of the larger figures in

18 human factors in psychology, Dave Woods, talking

19 about this very same notion, in the sense that you

20 really need to think about the equipment, the

21 interface and the operator as a system, and you need

22 to think about them addressing a variety of different

23 contexts.

24 If you have automation or a design that

25 keeps the operator out of action and basically kind of
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1 bored sitting there for a lot of time, and you don't

2 think carefully about the handoff, when you get into

3 a more exciting situation, and the operator seems to

4 suddenly wake up and understand what's going on and

5 take over, if you don't think about that handoff very

6 carefully and plan for it, you can end up in some bad

7 situations.

8 MEMBER BANERJEE: But will you be

9 developing sort of databases and other things which,

10 I mean I can see this, which has records. But you

11 know, how do you use these things to --

12 DR. COOPER: How we use those ideas?

13 MEMBER BANERJEE: Yes. How can we sort of

14 validate ideas of --

15 DR. COOPER: Well, validating that basis

16 --

17 MEMBER BANERJEE: Or develop even ideas.

18 DR. COOPER: For the specifics of the

19 medical context, I'm not sure how far we will go. But

20 that certainly is the intent of treating this area

21 with HRA, which even though it's separated from a PRA,

22 is still supposed to be providing, first of all, a

23 significance focus, even if it's not a risk focus, and

24 also sort of a systems focus. 

25 Not to just look at the human in isolation
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1 of, you know, the interface they're working with and

2 the equipment they're working with, and the larger

3 context, how that might change. That is the benefit,

4 if you will, of using HRA, as opposed to human factors

5 alone, because HRA will bring that in, as well as

6 these other things.

7 Now that's the idea. Now we're still, to

8 the extent that we're able to do that, we haven't

9 demonstrated this. We developed it. We're talking

10 about right now is a follow-on task for the

11 development team, to try to develop some illustrative

12 examples of how you would use this structured

13 knowledge base for some kind of task. So you could

14 see how we would use it.

15 So I'm not sure what we will be doing

16 beyond that. So I don't know --

17 (Simultaneous speaking.)

18 MEMBER BANERJEE: We've seen your

19 database. I mean if you've got a large database, it

20 seems useful to have.

21 DR. COOPER: What do you mean by

22 "database"?

23 MEMBER BANERJEE: Well, all of this you're

24 seeing in the medical applications area, right?

25 You've got apparently are you developing this
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1 structured knowledge base --

2 DR. COOPER: We have a version, a

3 prototype right now, and it has these elements, and

4 they're all linked. I mean you have, first of all,

5 there are little captured bits of knowledge about

6 human performance, the one-page summaries. Then you

7 have task breakdowns. Why don't you go to the -- yes.

8 So this is sort of the structure, and this

9 is a screen shot, if you will, of the current version

10 of the knowledge base, right? I think this is the

11 current version, which is in the prior software. This

12 is not one that you have. But I've given you

13 electronic, like this is a newer version.

14 So the purple highlighted things are

15 active links. So you can go to any of these things,

16 and then you -- also when you go to say, for example,

17 a task breakdown, which is the specific steps in doing

18 a Gamma Knife treatment, you can also then link to

19 human performance topics or discussions about errors,

20 or narratives from specific NMED events.

21 So this is a picture of the breakdown, and

22 on this particular screenshot you can see the specific

23 NMED events that have been captured for specific

24 steps. You can then go to those events and see what

25 happened there, and how it relates to that particular
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1 step in the procedure.

2 So this tells you a little bit -- first of

3 all, just visually looking at it, you can see setting

4 the shot coordinates has more failures than the other

5 ones. You can see just in the summary what some of

6 those, what happened there. Then if you go to one of

7 the events, then this is what you see.

8 Everything there is actually directly out

9 of the NMED database. But what's been added by our

10 team is the highlighting that helps you understand or

11 focus in on the issues that we think are important to

12 the human failure. I think Bill, correct me if I'm

13 wrong, there's some things that we've also added at

14 the bottom. Is there more to this screen?

15 I thought there was -- I thought there was

16 another, something cut off from here. Oh, the human

17 performance topics, which this one, for some reason,

18 really doesn't have any listed. But we would identify

19 human performance issues or topics that are then

20 related to this particular event, and that's also

21 added by us.

22 CHAIRMAN RYAN: That's good, because

23 that's what I was thinking. You really, I mean fail

24 to verify. Okay. That's a big, broad spectrum of

25 things that can go wrong, failure to verify.
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1 DR. COOPER: If you go to the next thing.

2 This is an example, then, of what we call a one-pager,

3 which is a very small, you know, five minute read on

4 what's important in this topic. So for example for

5 that NMED event, on the last page, there is one-pager

6 on, is it independent verification or verification or

7 checking or whatever?

8 So there's a discussion about it, you

9 know, generally what the issues are. This particular

10 one happens to be on team performance.

11 CHAIRMAN RYAN: I believe that's really

12 good, because failure to verify. All team members

13 must verify treatment coordinates. Okay. What does

14 that mean? Does that mean I wave my hand around and

15 say "yes, those two are looked at. Seems good to me"?

16 You know, you just really don't, until you

17 really say what does verify treatment coordinates

18 mean? How are you going to do that? Are you going to

19 write it down?

20 MR. BROWN: Those words on that record

21 point to a discussion like this one, that basically is

22 the discussion we had earlier, about what is

23 independent verification. 

24 CHAIRMAN RYAN: Right.

25 MR. BROWN: How does it make it --
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1 CHAIRMAN RYAN: You know, I know you go

2 into much broader areas like, you know, there's a

3 famous old case where a patient was crushed by a

4 gantry and a table that moved up into a treatment

5 head, and the technician ran down the hall to go to

6 the kill switch, instead of just yanking the patient

7 off the bed, and the patient was killed.

8 So you know, that's -- so that's a whole

9 different thing. But it's interesting. That's kind

10 of an equipment problem, because every treatment room

11 in the world now has a kill switch right in the room.

12 MEMBER BANERJEE: I guess this tells you

13 what the error was and perhaps something about its

14 frequency and so on. But it doesn't really tell you

15 about what led up to there, right?

16 CHAIRMAN RYAN: Yes. That's kind of what

17 I'm saying.

18 DR. COOPER: That's true, and then

19 unfortunately there, we're sort of hampered by what

20 information was provided by the licensee. 

21 MR. BROWN: What's in there are the

22 verbatim narratives from the licensee's report.

23 Sometimes an investigation is done, and you get a good

24 sense of what happened. Other times, it's just a

25 couple of lines, and you really have to stretch it to
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1 try to draw a lesson from it.

2 MEMBER BANERJEE: How many records like

3 this do you have?

4 MR. BROWN: For this, this is sort of a

5 proof of concept. So we just took the Gamma Knife,

6 which is a particular radiotherapy treatment, and

7 culled the, for lack of a better word, human error

8 misadministrations that were reported from NMED. I

9 don't know. There are a probably a couple of dozen

10 events.

11 MEMBER BANERJEE: Is that so?

12 MR. BROWN: Yes. So they're not that

13 frequent. Again, for a given type of device for a

14 given period of time, they're not -- there aren't

15 hundreds of them. There would be hundreds of them if

16 you consider HDR, teletherapies, just that.

17 MEMBER SIEBER: I think it would be better

18 to say that ignore how many events there were, if

19 there's not hundreds of records. 

20 DR. COOPER: Yes.

21 MEMBER SIEBER: Because there are events

22 that occur that somebody thinks I had the X-ray film

23 in backwards, and so I gave it on the wrong side of

24 the human being. A lot of those go unreported.

25 MR. BROWN: They go undiscovered.
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1 MEMBER SIEBER: Right.

2 MR. BROWN: If they're undiscovered,

3 they're not reported, right. 

4 CHAIRMAN RYAN: All right. Our time is

5 getting a little short, so we need to --

6 DR. COOPER: Okay, yes. This is the last

7 slide. Just two comments. I didn't go over how we

8 picked the Gamma Knife, but that was actually an

9 exercise that we went through, and that's documented

10 in one of the task reports that we went through with

11 staff and management on, you know, looking at

12 representativeness, if you will, of the human

13 performance issues that they're concerned about.

14 That's what we decided as a test bed.

15 Moving forward, we're going to be working

16 on a NUREG, to try to capture the basic understanding

17 of human performance and human error in medical

18 events, and that's what the team is working on right

19 now.

20 And we're also going to be, I think we're

21 talking about documenting the training materials also

22 in a report, that can be more widely available. But

23 anyway, that's where we're at right now.

24 CHAIRMAN RYAN: Sounds great. Thank you

25 very much. Anyone have questions, comments?
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1 MEMBER SIEBER: I do have a question.

2 When we were talking about periods of boredom and then

3 an event occurs, and how people sometimes miss steps

4 and so forth because of attention levels, I look at

5 that as having a peak, where you get to a point where

6 events are occurring, you fully understand them, and

7 you're reacting to them.

8 If they're occurring faster than you can

9 understand them, you go down into the error range

10 again --

11 DR. COOPER: That's exactly right, that's

12 exactly right.

13 MEMBER SIEBER: Is that really the case?

14 DR. COOPER: Yes.

15 MEMBER SIEBER: And does anybody attempt

16 to measure that --

17 DR. COOPER: Yes.

18 MEMBER SIEBER: Let me give you a power

19 plant example. I once worked in a coal-fired plant

20 where you had six boilers, three turbines, one control

21 room, two operators.

22 Something would happen to one unit. Both

23 operators were rushed to that unit; the other ones

24 would go sailing on their merry way. Anything could

25 happen with the alarms going off; they wouldn't know
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1 it.

2 Is there a way to analyze that, because

3 there is a probability that that kind of overload

4 situation can occur, and I suspect it's different for

5 different people.

6 DR. COOPER: Yes. Well, I'm going to let

7 Julie answer first, since she's the cognitive

8 psychologist -- well these two both. They can answer

9 from the literature first. Why don't you do that?

10 DR. MARBLE: Yes. There's been a lot of

11 research on stress, and you're exactly right. What

12 you do see is basically a bell curve. There's an

13 optimal level. Below it, your performance is

14 suboptimal; above it, your performance is super15 optimal.

16 When human factors in cognitive

17 psychology, when we try to measure that, you can take

18 a number of physiological measures as an indicator of

19 stress levels.

20 You can get heart rate variability; you

21 can get galvanic skin response, etcetera. So they do

22 measure those, and then they can correlate it on

23 simplified tasks. There has been some work on stress

24 in nuclear power plant simulators and aviation

25 scenarios, etcetera. 
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1 To some degree, they're artificial,

2 because you're using students. But in fact there is

3 work that goes on on stress and how performance

4 decrements with that stress level and distraction.

5 MEMBER SIEBER: I don't see that issue,

6 though, modeled anyplace, in any of these HRA kinds of

7 things.

8 DR. COOPER: Not in this. Now having said

9 that --

10 MEMBER SIEBER: Or even power plant stuff.

11 DR. COOPER: Well, if we do the Level 3,

12 I will.

13 MEMBER SIEBER: Okay.

14 DR. COOPER: I'm going to have to. I

15 don't know how I'm going to, but I will.

16 MEMBER SIEBER: I'd be interested when you

17 find the answer.

18 DR. COOPER: Me too.

19 CHAIRMAN RYAN: It's really interesting.

20 Thank you all very much for coming. We appreciate

21 your insights.

22 DR. COOPER: Thank you.

23 DR. MARBLE: Thank you.

24 CHAIRMAN RYAN: John, maybe we can get --

25 and close the meeting. 
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1 MR. FLACK: Want to take a couple of

2 minutes?

3 CHAIRMAN RYAN: Yes, a couple of minutes.

4 MR. FLACK: I'm wondering if -- we're

5 going to have another subcommittee, right?

6 CHAIRMAN RYAN: Yes. I mean this is just

7 kind of a getting started.

8 MR. FLACK: I think we ought to say we

9 want to dig into some of the ISA issues in a lot more

10 detail at the next meeting. We've been just going

11 through --

12 CHAIRMAN RYAN: No, I'm sorry. No, I'm

13 sorry. We closed the record when we said break a few

14 minutes. So Dennis and I are off the record.

15 (Whereupon, at 5:04 p.m., the meeting was

16 adjourned to closed session.)

17

18

19

20

21

22

23

24

25
Making Clean Power Cleaner

Depleted Uranium De-Conversion Project 

Presentation

May 2011
2

INIS Company History / Vision

Our History

 International Isotopes (“INIS”) is headquartered in Idaho Falls, Idaho

 Incorporated in 1995, IPO in 1996

 Licensed by US NRC

Initial NRC Part 30 License - September 2000 - Renewed September 2010

NRC Approved QA Program (Part 71) - October 2004 - Renewed November 2008 

NRC Part 40 License - October 2005

NRC Part 30 Exempt Distribution License - November 2007 

Our Vision

o To license, construct and operate the first commercial depleted uranium hexafluoride deconversion facility and offer these services to commercial fuel enrichment companies

o To produce high purity/high value fluoride products during de-conversion

o To manufacture these fluoride products using patented energy and resource savings 

technology
3

INIS Uranium Enrichment in the U.S.

• Currently 4 companies evaluating, planning, or building enrichment capacity in the U.S.

Facility: Eagle Rock Enrichment

Location: Idaho Falls, ID

Opening Date: 2014

Full Production Date: 2019

Capacity: 6.6 million SWU/yr

Facility: American Centrifuge

Location: Piketon, OH

Opening Date: 2014

Full Production Date: 2017

Capacity: 3.5 million SWU/yr

Facility: Global Laser Enrichment

Location: Wilmington, NC

Opening Date: 2012

Full Production Date: 2017

Capacity: 3.5 – 6.0 million SWU/yr

Facility: Louisiana Energy Services

Location: Eunice, NM

Opening Date: June 2010

Full Production Date: 2015

Capacity: 5.7 million SWU/yr
4

INIS Depleted Uranium Already Stockpiled

• DUF6 has historically been 

stored – not de-converted

• There has never been an 

economic solution for 

managing final disposition of 

this material
5

INIS Need

Historic controls for DUF6 - Storage – no economic incentives to de-conversion

Current DOE Inventory:

Paducah: 39,000 Cylinders - 4 lines (~1,500 cylinders/yr) = 26 years

Portsmouth: 25,000 Cylinders – 3 Lines (~1,125 cylinders/yr) = 22.2 years

In Addition:

Fuel enrichment companies have announced capacity of >15 million SWU per annum and are 

expected to generate over 80 million pounds of DUF6 annually

89.4 85.7 

82.1 78.4 

67.7 

57.2 

44.4 

26.6 

11.7 

7.6 

4.1 

0.6 

0

10

20

30

40

50

60

70

80

90

100

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

Annual Depleted Uranium Generation

(mm lbs DUF6)

USEC

GE

AREVA

URENCO

555.4 

466.0 

380.3 

298.3 

219.9 

152.1 

94.9 

50.5 

23.9 4.7 12.3 0.6 

0

100

200

300

400

500

600

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021

Cumulative Depleted Uranium Generation

(mm lbs DUF6)

Annual DUF6 Generation in U.S. Cumulative DUF6 Generation in U.S.
6

INIS Process

Receipt: DUF6 from enrichment facilities

Processing: Chemical De-conversion of DUF6

DUO2

SiF4

BF3

IIFP

B2O3

(or DU3O8)

DUF6

SiO2

Sold 

Commercially

Disposal

UF6 →UF4 → FEP

AHF
7

INIS Site Selection - Hobbs, NM

• Site Selection Criteria

o Extensive review process

o Broad regulatory, political, environmental 

considerations

• Public Acceptance

o Over 40 meetings held

o No negative reaction, no intervention

o Successful outcome of NRC public 

meetings in the license process

Site Summary 

o 640 Acre Total/ 40 Acre Facility

o ≈15 miles west of Hobbs, NM

o ≈35 miles west of URENCO

o Nearest resident ≈ 1 mile northwest
8

INIS IIFP Footprint

IIFP Site within 

640 Acre 

Section 27
9

INIS Impacts 

Public Dose

ˉ Uranium – Estimated Dose Modeling 3.1E-6 rem/year to MEI

Air Emissions

ˉ Fluorine – Estimated Release Modeling ≈ 238 lb per year HF after 

treatment

ˉ Compares to 222,000 lb in State of NM (2009 US EPA Toxic 

Release Inventory)

Water Usage

ˉ Minimized by using process water recycling – estimate usage at 

less than 10,000 gallon per day.

Ground Water Protection

ˉ Zero Discharge of Process Waters
10

INIS Depleted Uranium Oxide Waste Disposal

Rocky Mountain LLW Compact issued a declaratory order exempting DUF6 as 

“waste” provided it is shipped to INIS for fluorine extraction

Uranium oxide waste is shipped to licensed disposal site(s) 

Utah – Energy Solutions

Texas – WCS 

0

50

100

150

200

250

300

350

400

450

500

2013 2014 2015 2016 2017 2018 2019 2020

N

u

m

b

e

r

o

f

S

h

i

p

m

e

n

t

s

Annual Waste Shipments

0

10000

20000

30000

40000

50000

60000

70000

80000

2013 2014 2015 2016 2017 2018 2019 2020

C

u

b

i

c

F

e

e

t

Annual DU Waste Volume (Ft3)
11

INIS NRC Licensing Process

Part 40 Source Material Facility

• Letter of Intent to license facility submitted April 2009

• License Application and Environmental Report Submitted 

December 30, 2009.

 License prepared in accordance with Part 70 using the 

guidance from NUREG 1520 Rev 0. 

 Environmental Report prepared in accordance with NUREG1748 Environmental Review Guidance for Licensing Actions 

Associated with NMSS Programs

• NRC accepts License Application February 2010

• NRC Request For Additional Information (RAI) provided September 

and November 2010

• Responses to RAIs are complete
12

INIS NMED Permitting

New Mexico Environmental Department

• Ground Water Discharge Permit – (storm water basins)

• Air Emissions Permit.

• Waste Water Treatment and Land Application Permits

• Hazardous Waste Generator Permit.

• Storm Water Discharge Permit (EPA)

Several face-to-face meetings with the various NMED Bureaus

Agreement with NMED:

• Limit quantity of uranium possessed on-site

• Limit time DUF6 cylinders and full DU Oxide disposal containers 

remain on-site. 

• Reporting and access to information agreements.
13

INIS ISA Methodology

• Follows methodology specified in 10 CFR Part 70, Subpart H

– Uses NUREG-1520 and NUREG-1513 as guides for format and content

– FEP/DUF6 De-conversion plant is considered a low-hazard nuclear

facility

• Primary hazards are from HF or HF reaction product resulting in

chemical dose to workers and the public

• No process related scenarios lead to intermediate or high radiological

consequences to workers or the public
14

INIS Key ISA Elements

• Hazard Identification

– Identification, location, and inventory of hazards

• Hazard Screening

– Identifies hazards that exceed low consequences

– Excludes standard industrial hazards

• Process Hazards Analysis (PHA)

– What if/checklist methodology

– Identifies scenarios that can lead to intermediate or high

consequences to workers and the public
15

INIS PHA Example

Consequence Types: Consequence Receptors: Consequence Severity Level:

RD = Radiological dose W = Worker 1 = Low Consequences

CD = Chemical dose P = Public 2 = Intermediate Consequences

Sol U = Soluble uranium uptake Env = Environment 3 = High Consequences

Scenario 

Number What If... Causes 

Failure 

Frequency Consequences

Consequence 

Category

Prevention 

Features

Mitigation 

Features Comments

ID_xyz Process 

gas flow 

valved to 

open 

system

Valve 

misalignment

Valve leak

-1 Hazardous and 

radioactive gas 

released from 

containment

CD(W) = 3

CD(P) = 2

RD(W) = 1

RD(P) = 1

RD(E) = 1

Isolation valves 

prior to open 

system

Blind flange on 

open system 

prior to 

maintenance

Purge and 

evacuation 

pressure checks 

prior to 

maintenance

Facility structure 

limits offsite 

consequences

Area hazardous 

gas and/or 

airborne radiation 

detection system 

and alarms

None
16

INIS Likelihood Analysis

• Frequency of the initiating event

– Frequency assignment is based on NUREG-1520 criteria

• Failure probability of prevention/protection features

– Failure probability assignment is based on NUREG-1520 criteria (used

conservative side of the numbers unless a basis otherwise)

• Failure duration was not used to determine likelihood

– Nature of the process did not provide a need for duration credit
17

INIS Likelihood Determination

• Used the Qualitative Likelihood Index method to determine likelihood

category

– Order of magnitude method as described in NUREG-1520, Rev 1 (page

3-AA-1 “Likelihood Definitions”)

• Likelihood index value is determined by summing the Frequency Index and

Failure Probability Index to get an overall likelihood index number “T”
18

INIS Consequence Analysis

• Consequence Receptors

– Worker, public, and environment

• Consequence Severity Levels

– Low Consequences = 1

– Intermediate Consequences = 2

– High Consequences = 3

• Consequence level criteria is from 10 CFR 70.76
19

INIS Items Relied On For Safety (IROFS)

• IROFS are the credited prevention/protection features or mitigation

features that are relied upon to meet acceptable risk levels for accident

scenarios

– IROFS are identified and assigned as needed during the risk analysis

– Credit for IROFS as prevention or mitigation is based on the type of

IROFS (passive, active engineered, etc.) as described in NUREG-1520
20

INIS Risk Determination

• Risk is determined by multiplying the likelihood category number by

consequence category number to get a total risk index value

– Risk index values of 4 or less meet the performance criteria in 10 CFR

70.61 and are acceptable

– Risk index values greater that 4 require additional prevention/protection

features and/or mitigation features to reduce the risk to an acceptable

level
21

INIS Risk Tables (Accident Sequences)

• Risk Tables were compiled to evaluate accidents that could result in

intermediate or high consequences

– Used the PHA as the starting point (initiating event, consequences,

potential IROFS, etc.)

• Refined initiating event frequencies and consequences prior to

completing the risk tables

– Consistent with the example in NUREG-1520 and implemented as

applicable to the IIFP facility

• NUREG-1520 example is more geared toward criticality safety

scenarios
22

INIS Risk Table Example

Accident 

Identifier Initiating Event Prevention IROFS 1

Prevention 

IROFS 2

Mitigation 

IROFS 3 U/C

Likelihood Consequence

Risk 

Index

Comments and 

Recommendations

Index Category Evaluation 

Number Category

XYZ -1 XYZ-1 XYZ-2 U -1 3 XYZ-EV-1 3 9 IROFS required

Process gas 

flow valved to 

open system

Isolation 

valves

Blind 

flange on 

open 

system

Valve 

misalignment

Valve leaks 

through

-2 -2 C -5 1 3 3 Acceptable Risk
23

INIS NPH and External Events

• Some initiating events have low or no consequences

• Some initiating events are highly unlikely or not credible

• Design Basis Events

– Followed guidance in NUREG-1520, Rev 1, Annex to 

Appendix A
24

INIS Conclusions

• Project is important to the nuclear Industry as it fills a “Void” 

in the Nuclear Fuel Cycle

• Environmental and Safety considerations have been given 

high priority

• Licensing process – Ahead of the curve for a Part 40 facility

- Integrated Safety Analysis

- Used NUREG 1520 Revision 1
1

INIS Fluorine Extraction 

and Depleted Uranium 

Deconversion Plant

May 25, 2010
2

NRC Participants

• Tom Hiltz –FCSS Deputy Division Director

• Dennis Morey – Licensing Branch Chief

• Matt Bartlett – Licensing Project Manager

• Yawar Faraz – Senior ISA Reviewer
3

Staff’s Objectives

• Information Briefing

• Discuss Review Process

• Role of Integrated Safety Analysis

• Review Status
4

Role of the Office of NMSS

• Fuel Cycle Safety and Safeguards

• Single Contact with Applicant

• Oversee Safety Review 

• Issue License
5

Licensing Process 

Matt Bartlett, NRC 

Licensing Project Manager
6

Topics

• Overview of Source Material Facilities

• Facility Hazards

• Regulatory Requirements

• ISA and Safety

• Status of the Review
7

Regulation of Conversion and 

Deconversion

Conversion

Agreement States Department of Energy

Deconversion
8

Proposed Facility

• Deconversion Facility near Hobbs, New Mexico

Lea Co. NM Site

Name: International Isotopes Fluorine Products Inc.

Technology: Chemical Deconversion

DUO2

SiF4

BF3

IIFP

UF6

SiO2

B2O3

(or DU3O8)

DUF6

SiO2

B2O3

Sold 

commercially

Disposal

AHF
9

Hazards

Inventory of Chemicals

HF 31,000-80,000 lbs

SiF4 8,000-14,400 lbs

BF3 7,200-54,800 lbs

UF6+ 2H2O → UO2F2+ 4HF

Chemicals from a Release

Process Tails from Enrichment Facilities

DUF6 + H2 DUF4 + 2HF

+ SiO2 DUO2 + SiF4

DUF4

DUF4

DUF6 1.65 Mlbs

DUF4
10

Decommissioning 

Qualified Staff

Protect Environment 70.21(f)

Emergency Plan 

Facilities and Procedures

Health and Safety 

Physical Security 

70.22(a)(9)

70.22(i)

70.22(a)(6)

70.22(a)(8)

70.22(a)(7)

70.22(h)

Integrated Safety Analysis 

40.32(d)

40.32(c)

40.32(b)

40.31(j)

40.31(i)

40.31(f)

40.32(d)

Similarities

Key Regulatory Requirements

SRM to SECY-07-0146 – Part 70, Subpart H 
11

Integrated Safety Analysis

• Part 40 Proposed Rulemaking

Incorporates ISA Similar to Part 70, Subpart H

2000 kg or more of UF6

Licensed by the NRC

Final rule by late 2012 

• Approved for Publication

SRM to SECY-010-0128

Published May 17, 2011
12

Integrated Safety Analysis 

(continued)

• ISA Summary

Identify Accident Sequences – over 100

Implement IROFS – around 40

Incorporate Management Measures

• Baseline Design Criteria

Minimum design requirements

Defense in Depth 
13

Additional Requirements

Part 51.20(a)(1) ... major federal action...

Part 2.105(d)(2) ...request a hearing... 

• Environmental Impact Statement

• Opportunity Hearing

• Guidance/Standard Review Plan

NUREG-1520 – Review an application

NUREG-1513 – Develop an ISA
14

“The reviewer should find the applicant's general information acceptable if 

it provides reasonable assurance that the acceptance criteria presented 

below are adequately addressed and satisfied.”

Standard Review Plan

• Areas of Review

• Acceptance Criteria

General Information

Organization and Administration Emergency Management

ISA and Summary Environmental Protection

Radiation Protection Decommissioning

Chemical Process Safety Management Measures

Fire Safety Appendixes

• Applicability

Written for Part 70 Applied to Part 40
15

Licensing – Review

Safety Review Team

ISA

Radiation protection

Chemical safety

Fire protection

Emergency preparedness

Environmental protection

Decommissioning

Financial assurance

Quality assurance

Management measures

MC&A

Financial qualification

Seismic

Structural

Security

Human factors

Digital I&C

Electrical

• Conducting the Review

• Requests for Additional 

Information – 174 RAIs

• Onsite Vertical Slice

• Updated Application
16

Licensing – Status

Application

Acceptance Review

Close Hearing Request 

Safety Evaluation Report

Draft EIS

Final EIS

RAI Responses

License

December 31, 2009

February 24, 2010

June 4, 2010

September 2011

November 2011

May 2012

May, 2011

June 2012

........................

...................

....................................

................................

.................

.............................................

.......................................

.......................................

Completed

Under

Development
17

Conclusions

• Regulations In Part 40

• Implement Part 70, Subpart H (ISA)

• Reviewed against Acceptance Criteria 

in NUREG-1520
RISK-INFORMING NUCLEAR 

MATERIALS

Dr. Susan E. Cooper & Dr. Julie Marble (RES/DRA/HFRB)

Dr. Bill Brown (Brookhaven National Laboratory)

Dr. Jeff Brewer (Sandia National Laboratory)

ACRS Radiation Protection and Nuclear Materials Subcommittee

May 25, 2011
1

Presentation Outline

• Background on risk-informing nuclear 

materials

• Summary of early efforts to develop HRA 

capability

• Excerpts of recent work on:

– Qualitative HRA for cask drops

– HRA-informed tools for medical applications
Background on risk-informing 

nuclear materials

• User Need (2003-003) from NMSS:

– This User Need was provided to RES in order to develop HRA 

capability across NMSS as part of an overall effort to risk- inform NMSS.

– Two Phases were identified:

• Phase 1: Feasibility assessment for HRA capability

• Phase 2: Development of HRA capability

• RES split the efforts into two parts:

1. High-level waste, spent fuel handling, fuel cycle, etc.

2. Medical and industrial applications of byproduct materials

• Phase 1 feasibility studies to identify NMSS needs were 

completed:

1. BNL performed study for byproduct materials (2003)

2. Study for high-level waste, fuel cycle, SFPO, & decommissioning 

was performed in-house by RES (2005)

• Phase 2 development:

– BNL continued work on medical applications of byproduct materials

– SNL began work on spent fuel handling

2
Summary of efforts to develop 

HRA capability

• Spent fuel handling

– Because the feasibility study did not identify an initial 

focus, interactions with staff identified priorities, e.g.,

• Qualitative HRA for misloads and cask drops as initial priorities

• Cask drops and HRA insights on potential human performance 

vulnerabilities in later investigations

• Medical applications of nuclear materials

– Based on results of Phase 1 feasibility study and 

additional interactions with staff, the following was 

agreed upon:

• Medical applications as an initial focus

• While a variety of different HRA-informed products were identified, 

development of job aids and training are the top priorities

– Staff interactions also helped to identify:

• a list of human performance topics to focus on 

• Gamma Knife as “test bed”

3
Excerpts: 

Qualitative HRA for cask drops

4
Analysis Approach

• Gathered information

– Subject matter experts

– Reviewed reports and previous analyses

• Generated cask drop scenarios (using 

ATHEANA HRA method)

– Hypothetical scenarios describing how and why 

cask drops may occur given current 

understandings of human performance

– Identified unsafe actions, human failure events, 

contexts

• Generated recommendations for avoiding or 

mitigating cask drop human failure events

5
Cask Types

• HI-STORM 100 System at Mark I Boiling Water 

Reactor

– Uses the canister as the confinement boundary and 

uses a separate structure to provide shielding and 

thermal protection

– Loaded canister must be transferred to the storage 

structure/container

• Transnuclear (TN)-40 at Pressurized Water 

Reactor

– Uses a directly loaded, bolted-closure storage cask 

to provide confinement, shielding, and thermal 

protection

– May be placed directly on the independent spent fuel 

storage installation

6
Cask Drop Scenarios

• Scenarios constructed within NUREG/CR-7016 (TBD) 

for the following movements:

– Cask movement from spent fuel pool to preparation area 

(HI-STORM 100 & TN-40)

– Cask movement from preparation area to transfer pit (HI- STORM 100)

– Multipurpose canister (MPC) movement from transfer cask 

down to storage cask (HI-STORM 100)

• Scenarios constructed within NUREG/CR-7017 (TBD) 

for additional movements

– Before and during fuel loading

– During MPC and transfer cask sealing operations

– During storage cask movement from the transfer pit to the 

ISFSI pad

– During cask monitoring and storage at the ISFSI

7
Human Performance 

Vulnerabilities

1 Inadequate 

procedures 

Omission of detail in procedures

2 Limited reliance on 

procedures

Many operations are skill-based and may not be 

guided by written procedures

3 Inapplicable 

procedures

Procedures don’t apply to a unique or unusual 

situation (off-normal; emergency)

4 Inadequate 

training/experience

Individual & team factors (e.g., between plant 

personnel and temporary contractor personnel)

5 Communication 

difficulties

Noise, hand signals, confusion using RF headsets 

with many people

6 Limited indicators 

and job aids

Lack of engineered reference tools or administrative 

controls (variable execution of skills)

7 Visual challenges Large distances, viewing casks in water, obstructions

8 Unchallenging 

activities

Slow-paced tasks, monotonous, easy to get 

distracted

9 Time pressure Approaching outage can increase pressure 8
Human Performance 

Vulnerabilities

10 Time of day & shift 

work challenges 

Double shifts, variable shift schedules, filling in for 

sick colleagues 

11 Inadequate 

verification

Incorrect “redundant” checking: common-mode 

failures, social shirking, overcompensation

12 Quality assurance 

problems

Structures, systems, components, materials, etc.

13 Decision making 

bias error

In particular: confirmation bias, loss aversion, 

overconfidence

14 Inadequate team 

coordination

Undesirable variability within and between teams, 

e.g., different assumptions for task execution

15 Improper or uneven 

task distribution

Missed opportunities for checking, workload 

imbalance 

16 Large number of 

manual operations

More opportunities for unsafe actions and human 

failure events

17 Other ergonomic 

issues

Cramped work spaces, noise, hot or cold 

conditions, cumbersome clothing

9
Conclusions

• Introduced the analysis process allowing development of:

– Cask drop scenarios including unsafe actions and error-forcing 

contexts

– Human performance vulnerabilities representing performance 

shaping factors and plant conditions that generate a condition 

that may contribute to human failure events

– Illustrative guidance for avoiding or mitigating human 

performance vulnerabilities

• ATHEANA & Good Practices for HRA have proven valuable 

for uncovering the dynamic, contextual conditions influencing 

human performance in cask handling.

• It is possible to build a technical basis for potential 

improvements to procedures and practices involving Dry 

Cask Storage Operations (e.g., to avoid cask drops).

• This work forms a useful basis for potential future HRA/PRA 

Level 3 site-wide studies that include spent fuel handling in 

their scope.

10
Excerpts: 

HRA-informed tools for medical 

applications

11
13

Aims and Approach

• Risk-inform byproduct-related tasks by:

– Applying HRA perspective to materials issues

– Focusing on qualitative insights from HRA

– Providing technical basis for staff decisions

• How to provide this perspective?

– Provide basic information on human performance and error

– Provide relevant resources (i.e., filter literature and 

understanding in psychology, cognitive science, etc.)

• Specific implementation

– Training (2008 materials are for 2 – 21/2 days)

– Job Aid (mostly represents 2008 version; 1-2 slides based on 

upgrades to software and content made in 2010)
HRA-INFORMED TRAINING

12
14

General topics in HRAInformed Training 

Human Error in Medical Applications

What is Human Error

Error Mechanisms/Contexts

Current Thinking on Human Error

Event Analysis/Corrective Actions
16

Preventable medical 

Injuries injuries*

1 out of 32 Deaths

1 out of 300

*Based on IOM report of up to 90,000 deaths in 32 million hospital stays 

(2002)

Close call

~1 in 5 to 1 in 15

Risks in Medical 

Processes* are Real

*Note: not specifically radiation therapy
16

Types of Medical 

Events

Source: NMED 2nd Quarter Report FY2007 (last 16 quarters)
17

NMED Medical Event 

Causes

Source: NMED 2nd Quarter Report FY2007 (last 16 quarters
18

Why do people make errors?

Ernst Mach

“Knowledge and error 

flow from the same 

mental sources, only 

success can tell the one 

from the other."

Enrst Mach, Knowledge and Error 

(1905)
Human error can be 

predicted because...

• People’s behavior is almost always rational:

– adaptive – i.e., goals are achieved

– satisficing – i.e., adequate under the circumstances

• People’s actions will tend to be:

– practical

– people do what “works”

– economical

– people act so as to conserve resources (physical & 

cognitive)

19
Human error can be 

predicted because...

• People follow familiar paths

– Maximize use of habits (good and bad)

– Minimize ‘cognitive strain’

• People use ‘rapid pattern-matching’ to detect 

and interpret faults and errors

– Very effective at detecting most problems, but

– Not very effective at detecting our own errors

• People also use...

– shortcuts, heuristics, and expectation-driven actions

– efficiency-thoroughness trade-offs

20
21

Practiced actions 

become ‘automatic’...

...whether we want them to or not.
22

Failure to Change 

Collimator Helmet

Enter Room Set Coords Leave Room

Enter Room Set Coords Swap Helmet Leave Room
23

The Search for Root 

Causes

• The purpose of the root cause evaluation is to ensure fixes are put 

in place to eliminate or reduce the risks of repeat events

– “What you look for is what you find” - WYLFIWYF

– “What you find is what you fix” - WYFIWYF

• Anticipating problems in license reviews & modifications

• Reviewing corrective actions

• Changes in regulations

• Most commonly cited causes in NMED:

– Inattention to detail (~48%)

– Failure to follow procedures (~26%)

• There are reasons for this

– The nature of tasks

– The nature of human behavior

• But these do not fully explain the events

– The analysis is superficial

– Corrective actions may be ineffective

• Example in backup slides
HRA-INFORMED JOB AID

24
Purpose of HRA-informed job 

aid for license reviewers

• To provide a basis for improving the understanding 

of human reliability issues in medical uses:

– the human-related causes of risk-significant events

– the effectiveness of proposed fixes 

• To provide a basis for evaluating the potential for 

significant risks associated with human performance 

in new license applications or modifications

• In general, this can be termed ‘sensemaking’ of 

events

– ‘Sensemaking’ is a $64,000 term for simply making sense of 

things

– But it includes some specific activities
Develop “sensemaking” aids

• One-page summaries of human performance topics

– Compact reference based on training material

• Prompt items to guide discovery of issues

– Questions to ask about circumstances, characteristics

• Task breakdowns (annotated)

– Detailed action sequences

– Notes re: relevant events or human performance aspects

• Error discussions

– Brief treatment of types of errors

– Examples from events

• Error narratives

– Excerpted from NMED records & human performance issues highlighted 

Job aid is essentially a structured knowledge base of prioritized human

performance issues, with multiple entry points & linkage to events 

(to illustrate importance of human performance issues with respect to 

frequency, recency, etc.) 
Creation of Job Aids and 

Knowledge Sources

Human Performance Knowledge

One-Pagers Prompts Event 

Narratives

Task 

Breakdowns

Error 

Discussions

Byproduct Uses

Information/Analyses
29
Example of an Annotated Task 

Breakdown
Example of an Event Narrative
Example of a ‘One Pager’ – team 

performance
BACKUP SLIDES

32
33

Example:

Beatson Oncology Centre, 2006

• Beatson Oncology Centre (BOC) major oncology treatment 

centre in Scotland

• Teletherapy event, but could happen with any modality controlled 

by computer

– Varian Varis software (commonly used in rad therapy)

• 15 year old patient dosed in 19 fractions (20 prescribed) each 

with 58% overdose in January 2006

– Died October 2006

• Step omitted from planning calculational process

– Normalization step missed

• Inattention to detail?

– Step omitted from procedure

• Inadequate procedure?

– Not detected by checker

• Inattention to detail?

– Planner not qualified to perform this planning process

• Violation of rules?
34

However...

• Software newly upgraded for planning and treatment tools, 

to allow automatic transfer of data from planning to 

treatment program

– Reduction in human errors expected because potential failure 

mode eliminated 

• Removed manual transcription of data from planning form to treatment 

software

• Also expected to reduce costs by eliminating manual actions

– Reduced treatment prep time estimated to save $35k for avg facility

• No safety review of impact of changes

– However because of complexity with this type of tumor, manual 

calculation of plan was required 

• Only ~6 out of ~5,000 new plans per year

– Treatment planner omitted new unit conversion step

• Not identified in procedures

– Procedure not updated in many years

• Not detected in reviews by senior planners

– Planner was more familiar with overall plans like this
35

And more... 

• Beatson had ~40% shortage in treatment planning positions

– Chronic shortage over many years

– Not just funds

• Few Med School graduates want to enter field

– (US average estimated to be 18.9% shortage for typical Rad Onc Dept)

• Pressure from public for reducing waiting times for treatment

– Oncology services being consolidated at BOC 

– Reported delays of up to13 weeks for lung cancer treatment

• 20% avoidable death rate due to delay alleged

• No staff available to maintain infrastructure

– Procedures

– Training

– Reviews of new software

• So “human error” causes (bad procedures, inattention, etc.) were 

symptoms of a bigger problem

– “Fixing” them (e.g., discipline) would not improve things in reality

• WYLFIWYF

• WYFIWYF