Intmonadonul Isotopu Inc.

March 07, 2011

ATTN: Document-Control Desk

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

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

TAC L32739.

To Whom it May Concern,

The following document is provided as a response to the US Nuclear Regulatory Commission

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

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

process facility.

(1) General Information

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

questions regarding this letter or require additional information. Sincerely,

JJM-2011-15

Enclosure as Stated

cc: Dr. Matthew Bartlett

U.S. Nuclear Regulatory Commission

Mail Stop E2C40M 6003 Executive

Blvd. Rockville, MID 20852

4137 Commerce Circle, Idaho Falls, Idaho 83401 Phone:

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

www.intisoid.com VP tAS5 D
General Information

GI-1 Comparison between the topographical features in License Application (LA) Figures 1-3 and 1-4

gives the impression that the 640-acre plot would extend beyond the county sections represented in Figure

1-4. Consistent with NUREG-1520, Section 1.1.4.3(2), trace out the 640-acre property on LA Figure 1-4,

similar to LA Figure 1-3, to clarify how county Sections 26, 27, 34 and 35 overlap with the 640-acre

property.

RESPONSE: The site proposed by the Lea County Economic Development Council consisted of

four (4) 640-acre Sections from which INIS would select one section on which to build the IIFP

Facility. The intent of the original Figure 1-3 in Chapter 1 of the IIFP License Application was to

show the general area in relation to Highways 62/180 and 483. At the time that Figure 1-3 was

developed, the exact boundaries had not been clearly defined. The Figure 1-3 outline boundaries

shown on the map should have been updated to be correct and consistent with the later

information used in the updated correct Figure 1-4.

License Documentation Impact: Figure 1-3 in the License Application Revision A, Chapter 1,

Section 1.1.1 will be replaced with the revised Figure 1-3 below. Also, paragraph three of the

Section 1.1.1 will be revised to read as follows:

The area surrounding the site consists of vacant land and industrial properties. The general area

.. nsi÷ting ef fur- (4) approximate 640 a.re SctionA is delinemaed in Figure 1 3, 1lFDP Site Mapwith Surrounding industrial Pro-peries. of the site location consisting of four (4) approximate

640-acre Sections is shown in Figure 1-3 in relation to New Mexico (NM) Highway 483 and U.S.

Highway 62/180.
General Information

Source: Natural Resources Conservation Service. U.S. Department of Agriculture

4Kip-nr-- 1- .4 1**V bile AIvia witn ?urr-Ounginig fnaumna: teronerticei. Figure 1-3 IIFP General Site

Location in Relation to NM Hiiihwav 483 and U.S. Highway 62/180
General Information

GI-2 Consistent with the acceptance requirements presented in NUREG 1.2.4.3(4), provide a specific

request for a license period such as 10 to 40 years.

RESPONSE: A specific request for a license period of 40 years is being made in a separate letter

and will be described in the license application below.

License Documentation Impact: Chapter 1, "General Information of the License Application,

Revision A will be revised with additional paragraphs regarding a basis for granting a 40 year

license. New paragraphs will be inserted between former paragraphs 5 and 6. The changes shown

below are relevant to RAI GI-2 and Follow-up to RAI GI-2. Other changes to Chapter 1,

"General Information" will be made in response to RAI GI-6A and GI-7A.

This facility will be licensed under Title 10 of the Code of Federal Regulations (CFR) Part 40,

Domestic Licensing of Source Material (CFR, 2008a). The format and content, however, of this

License Application (LA) follows the criteria specified in 10 CFR 70, Domestic Licensing of

Special Nuclear Material (CFR, 2008d), and particularly the methodology set forth in NUREG1520, Standard Review Plan for the Review of a License Application for a Fuel Cycle Facility

(USNRC, 2002). This was done in the IIFP LA in anticipation that U.S. Nuclear Regulatory

Commissioon NRC)_will through rulemaking establish ISA requirements for conversion and

de-conversion facilities that will be similar to those in 10 CFR 70 Subpart H.

IIFP believes the request for a 40-year license term is reasonable and appropriate notwithstanding

the IIFP Facility will be licensed as a Part 40 facility. This longer license term request is

consistent with Part 70 Subpart H Fuel Cycle facility and, in addition to meeting the part 40

licensing requirements the IIFP license application and review is being done in accordance with

the 10 CFR Part 70 Subpart H and NUREG-1520 requirements.

After the license is issued, IIFP will maintain the ISA in accordance with requirements of 10 CFR

Subpart H including the facility 70.72 change process and the change documentation submittals

required by 70.72 paragraphs d(1), d(2) and d(3). The IIFP management measure commitments in

the IIFP License Application Chapter 11 will further ensure configuration management and

structured maintenance measures for safety related structures, systems and components. The

management measures and change processes will systematically manage the aging phenomena

such as not to pose technical issues that preclude longer license terms of 40 years. Through this

change process and updates, the NRC will be kept informed of changes due to material

degradation and aging throughout the lifetime of the IIFP Facility. Thus, material degradation and

aging do not affect the duration of the license term. Therefore, these Subpart H requirements

permit the NRC to continue to support safe operations of licensed facilities on an ongoing basis,

regardless of the duration of the license.

IIFP will update the cost estimates for decommissioning every 3 years. These updates provide

sufficiently frequent reviews such that NRC does not have to rely on the license renewal review

to perform a time evaluation of the adequacy of financial assurance. Thus, decommissioning

funding requirements would be satisfied regardless of the duration of the license term.

The IIFP Environmental Report (ER) addresses cumulative effects from the combination of

individually actions for the proposed license action (a Phase 1 facility) and for a future expansion

action resulting in a Phase 2 Facility. The ER is the basis on which NRC will prepare an

Environmental Assessment (EA) or Environmental Impact Statement (EIS). The current License
General Information

Application addresses only the Phase I Facility, and HFP will issue an amendment to the License

for the Phase 2 Facility. For any facility expansions beyond Phase 2 IIFP will issue an ER. Based

on the new ER, the NRC would write an EA or EIS at that time. If the EA reveals that the

licensing action could have significant environmental impacts, an EIS is prepared. NRC will

continue to evaluate environmental impacts and cumulative effects occurring over a period of

time. Thus, NEPA requirements would be satisfied regardless of the duration of the license term.

Allowing the maximum license term for IIFP whose License Application meets Part 70, Subpart

H requirements is consistent with NRC's Strategic Plan that will allow the NRC to continue to

support safe operations of the IIFP Facility, to reduce regulatory burden, to enhance effectiveness

and efficiency, and is based on the NRC experiences with those licensees in the recent past after

the addition of Subpart H requirements to 10 CFR Part 70.

A formal letter requesting the 40 year licensing term will be submitted separate from this license

application.

nd

License Documentation Impact: New wording will be added to the 2 sentence of former

paragraph six of the IIFP License Application, Revision A, Chapter 1, "General Information".

The changes shown below are relevant to RAI GI-2. Note: Further modification of the final

sentence of the paragraph will be made in response to RAI GI-7A. Other changes to Chapter 1,

"General Information" will be made in response to RAI GI-6A and GI-7A.

IIFP is requesting a license authorizing up to 750,000 kilograms of depleted uranium (kgU) to be

maintained at any one time in the facility inventory. IIFP is requesting the license authorization

for up to 40 years and is plansning_to operate the facility indefinitely and continue to renew the

licenses as needed. IIFP also has a written agreement with the State of New Mexico on the

maximum inventories of MajOFrahemiealsdepleted uranium oxides and total depleted uranium that

can be maintained on site.

License Documentation Impact: Section 1.4 of the IIFP License Application, Chapter lwill st

be revised by adding a new 1 paragraph and a minor change in the 2nd the revised text will read

as follows. The changes below are relevant to RAI GI-2. Other changes to Section 1.4 will be

made in response to RAIs GI-7C, GI-7D and ISA-14.

1.4 Requested Licenses and Authorized Uses

The Source Material license for the material described in Table 1-4 of Section 1.3 above is

requested to be authorized for up to 40 years. IIFP plans to operate the facility indefinitely and

continue to renew the license as needed.

IIFP will not store or process Special Nuclear Material (SNM) at the FEP/DUP Facility.

Therefore, no licenses and authorized uses for SNM are requested. SNM is defined in 10 CFR

70.4, "Definitions," (2008d)..
General Information

GI-3 Ensure that the page numbering in the electronic version of the Environmental Report (ER)

matches the hard copy submitted to the US. Nuclear Regulatory Commission (NRC).

RESPONSE: It is unclear why there would be differences in the page numbering with the

electronic version of the submitted Environmental Report with the hard copy submitted to the

NRC. The electronic copy submitted matches the paging of the Environmental Report in the NRC

Agency Document Access and Management System (ADAMS) Web database. In any new

revisions, the page numbering of the electronic submittals will be reviewed to ensure that those

match hard copy submittals.

License Documentation Impact: None.
General Information

GI-4 Integrated Safety Analysis (ISA) Summary Table 4-3 references release scenario evaluation

number DUF-O0. This term does not appear to be defined in the ISA Summary. Provide a definition for

DUF-O0 in ISA Summary Table 4-2 or some other appropriate location.

RESPONSE: DUF-00 is not an IROFS. It is defined as "No IROFS Required." This identifier

was used as a placeholder in our Excel spreadsheet. A unique identifier and value was needed in

this location to avoid an error in the spreadsheet calculations.

License Documentation Impact: The term DUF-00 is being defined and added in the IIFP

Integrated Safety Analysis Summary, Section 4.1 to read as follows:

Table 4-1 indicates the definitions for the contents of each column in the accident summary

tabulations. Table 4-2 is a reference list of identified IROFS that includes a brief functional

description of each item. The term DUF-00 is used as a special identifier in the ISA Summary

tables and is defined as "No IROFS required". More detailed descriptions of IROFS are provided

in Section 6. It should be noted that these items are shown in numerical order with the exception

of numbered items that were originally identified as potential IROFS but were not required after

the final risk analysis was completed, Table 4-3, Table 4-4, Table 4-5 and Table 4-15-6_list the

potential accident sequences that were identified that could have consequences that are Category

2 or 3 based on the performance criteria of 10 CFR 70.61 (CFR, 2009a). The likelihood,

consequence, and risk ratings are also provided. Environmental levels are all determined to be

Category 1. The measures to reduce the risk to acceptable levels (IROFS) by either reducing the

frequency of occurrence of the events or mitigating the consequences of the events are also

identified. Descriptions of the accident sequences are shown in Section 3.
General Information

GI-5 Verify that the LA section break 1.6. 3.4 is placed in the proper location or whether it should be

moved up one paragraph, next to Hydrology.

RESPONSE: Hydrology was incorrectly identified as a subheading under Section 1.6.3.3,

"Severe Weather." Hydrology should have been labeled as Section 1.6.3.4 with the incorrectly

labeled Section 1.6.3.4, "Characteristics of Nearby Rivers, Streams, and Other Bodies of Water,"

as a subheading to Hydrology. The License Application will be revised to correctly label the

Sections.

License Documentation Impact: The License Application former Section 1.6.3.3 (now Section

1.7.3.3 in response to RAI RP-13), subsection "Hydrology" will be revised as follows (No change

has occurred in the text for the section due to this RAI.):

Hydrolog•,

1.7.3.4 Hydrology

License Documentation Impact: The License Application, Revision A, Sections 1.6.3.4-1.6.3.8

will be revised as a subheading to new 1.7.3.4 "Hydrology". Subsequent Sections and subsections

of the Chapter 1 of the License Application will be renumbered accordingly. (No changes will

occur in the text for these sections due to this RAI.):

1.6.3.4i Char-acteristics of Ncar-bv Rivcr-S. StrFea-ms. and- Obthpr- Radies Af Wantp

Characteristics of Nearby Rivers, Streams, and Other Bodies of Water

4 [4/wltzL z--•L -

4.6.6 De pth the to G roounwdt T r r aabl

Depth to the Groundwater Table

• ro-W teF MyCrolo•gy

Groundwater Hydrology

1.6.3.7 Characteristics of the Uppermost Aquifer

Characteristics of the Uppermost Aquifer

TT !

1.6.3.8 Design 1asis f-ood i~cnts use" 10F Acciaenu AnaHysis

Design Basis Flood Events Used for Accident Analysis
General Information

GI-6 The application should provide a clear understanding of the site operations. Consistent

with NUREG-1520, Section 1.1.4.3, provide the following information:

A. The application refers to Phase 1 and 2 of the facility in LA Section 1.2.2, LA Table 7-3,

LA Chapter 9, LA Chapter 10, and multiple locations in the ER and other documents. The words

"Phase 1" and "Phase 2" gives the impression that the license application covers both Phases.

From a licensing review perspective, the only operation under consideration is "Phase 1. "

"Phase 2" will be evaluated under a completely separate licensing action. This is further

obscured by the use of the terms "design/build phase " and "operations phase, " both of which are

included in the review of the current application. Consistent with NUREG1520 , Section

1.1.4.3(1), provide the following information: Consider modifying the phrases "Phase 1" and

"Phase 2" to refer to separate licensing actions. Make a clear distinction between current

application activities and future application activities. Provide an explanation early in Chapter

1 which clearly explains the difference between the current application activities and future

application activities. Ensure that this explanation clearly distinguishes between current

requested activities and future, non-requested activities.

RESPONSE: In the license application that was submitted in December 2009, the term Phase I

Facility is used to identify the near-term construction of the IIFP Facility and the associated

licensing action.

The current license application is only for the near term facility (referred to as Phase 1 Facility)

and requested activities within the current license applications is only for Phase 1.

A future expansion is planned (referred to as Phase 2 Facility) that includes additional capacity

and a process for direct de-conversion of depleted uranium hexafluoride to depleted uranium

oxide. Phase 2 construction and operation will require a separate and future licensing action.

The only part of the current IIFP License Application (LA) where there is a need to identify the

separate Phase 2 future licensing action and construction is the Chapter 9, "Environmental

Protection." All other references to Phase 2 will be removed from the License Application other

than where it is being defined and explained in LA Chapter 1, "General Information."

The referral to a future Phase 2 expansion is briefly discussed in the LA Chapter 9 owing to links

and references in the LA Chapter 9 to the IIFP "Environmental Report" (ER). IIFP decided to

prepare and submit the ER for the IIFP Site for both the facility being covered under the current

license application and for the planned expansion later. The future Phase 2 Facility is evaluated in

the current ER submittal owing to the plans to add a Phase 2 expansion within approximately 3-4

years of the facility operation. However, that Phase 2 expansion would require a separate and

future licensing action.

Additionally, the word "Phase" in relation to design/build, construction and operation of the

facility will be removed during the next License Application revision.

License Documentation Impact: An explanation beginning with a new third paragraph will be

added to the UIFP License Application Chapter 1, "General Information" introductory section,
General Information

former paragraph three will also be revised. The information in the new paragraphs clarifies the

differences between the Phase I and Phase 2 Facilities relative to their different construction time

periods and separate licensing actions. The first three paragraphs of the introductory section will

be revised. The changes shown below are relevant to RAI GI-6A. Other changes to the Chapter 1

introductory section will be made in response to RAIs GI-2, and GI-7A.

International Isotopes Fluorine Products (IMP), Inc., a wholly owned subsidiary of International

Isotopes Inc. (INIS), intends to build and operate a new uranium processing facility (plant) near

Hobbs in Lea County, New Mexico (referred to as the Hobbs site). IWFP will provide services to

the uranium enrichment industry for converting (de-conversion) depleted uranium hexafluoride

(DUF6) into uranium oxide for long-term stable disposal. The company will also include a

commercial plant to produce specialty fluoride gas products for sale. High-purity silicon

tetrafluoride (SiF4) and boron trifluoride (BF3) will be manufactured in the IIFP Ffacility by

utilizing the fluorine derived from the de-conversion of DUF6. The fluoride gas products are

highly valuable for applications in the electronic, solar, and semi-conductor markets. In addition,

anhydrous hydrogen fluoride (AHF) is a product of the de-conversion and is sold as a chemical in

high demand for various industrial applications.

Depleted uranium hexafluoride referred to as "tails" is the by-product of uranium enrichment.

Enrichment is required as a vital step in the nuclear fuel cycle to produce fuel for nuclear reactors.

All of the existing and planned commercial uranium enrichment processes use uranium

hexafluoride (UF6) as the process gas to produce isotopic enriched UF6. Upon further processing,

the enriched uranium material results in the desired nuclear fuel product. The depleted tails may

have some residual value but will ultimately require disposal. A commercial service is needed in

the U.S. to convert the DUF6 into the more stable uranium oxide for long term disposal. This

process is generally referred to as "de-conversion". IIFP is proposing to design, engineer and

license the nation's first privately-owned commercial facility for de-conversion of DUF6.

IIFP is applying for a license to construct and operate a facility for commercial de-conversion

services and production of high-purity products as discussed above. This current license

application and requested licensing activities considers only the near term facility construction

and operation and is referred to as the Phase I Facility and licensing action.

A future expansion is planned (referred to as Phase 2) but it is not part of the current licensing

activity or application. Any such new expansions (or facility phases) would be licensed and

constructed in different time periods under separate licensed actions.

The only part of the current license application where there is a need to identify the future and

separate Phase 2 licensing action and construction is the Chapter 9, "Environmental Protection."

The referral to a future Phase 2 expansion is briefly discussed in the LA Chapter 9 owing to links

and references in the LA Chapter 9 to the IIFP "Environmental Report" (ER). IIFP decided to

prepare and submit the ER for the IIFP Site for both the facility being covered under the current

license application and for the planned later expansion. The future Phase 2 Facility is evaluated in

the current ER submittal because of plans to add a Phase 2 expansion within approximately 3-4

years of the facility operation. However, that Phase 2 expansion would require a separate and

future licensing action.

This Chapter provides an overview of the IIFP Facility; specifically named the Fluorine Extraction

Process/Depleted Uranium De-Conversion Plant (FEP/DUP) commercial facility along with a

description of the facility and various processes and a description of the FEP/DUP site.
General Information

Institutional information is provided to identify the applicant, describe the applicant's financial

qualifications, and describe the proposed license activities.

License Documentation Impact: Section 1.2.2 of the IIFP License Application will be revised

to read as follows:

1.2.2 Financial Qualifications

I1FP estimates the total initial-capital and startup cost of the IIFP Facility FEPDLP commercia!

fae4ity-to be approximately $75-90 million dollars (estimated in 2009 US dollars), excluding

escalation, interest, waste disposition, decommissioning, and any replacement equipment required

during the life of the facility.Plans are to finan.e the facility m.tl ÷thrHugh I capital fu.ding

IIFP presently intends to utilize a surety bond and Standby Trust Fund method to provide

reasonable financial assurance e--that decommissioning funding will be available at the time of

decommissioning the facility. At least six months prior to startup of the Phae IlFP Ffacility

described in the current license application, IIFP will provide NRC the financial assurance

instrument that IlFP intends to execute. Upon finalization of the specific funding instrument to be

used and at least 21 days prior to the commencement of operations, IIFP will supplement its

application to include the signed, executed documentation. The surety bond and fund will provide

assurance that decommissioning costs will be paid in the unexpected event IIFP is unable to meet

its decommissioning obligations at the time of decommissioning. In this case, funds drawn from

the surety bond will be placed directly into a standby trust fund naming the U.S. Nuclear

Regulatory Commission as the beneficiary.

A Decommission Funding Plan (DFP) for the facility is developed and provided as Chapter 10 of

the IIFP NRC Licensing Application.

License Documentation Impact: The third paragraph of the IIFP License Application, Chapter 9

introductory section will be revised to read as follows:

it also should be noted, that in In addition to the proposed facility requested in the current

licensing activity and License Applicationof this submitted LA, the ER evaluates the

environmental effects of au-a future add-on DUF6 process for direct de-conversion to depleted

uranium oxide, referred to as Phase 2. The DUF6-to-oxide de-conversion future expansion is not

part of the current License Application or requested activities. The future Phase 2 process was

evaluated in the current ER submittal owing to the plans to begin adding this process to the

original facility within approximately 3-4 years of the first facility operation. The Phase 2

expansion would require a separate and future licensing activity at the appropriate time to its

construction. Plans are to amend the LA for the future Phase 2 pro.ess at the apprpriAte tim.e.

License Documentation Impact: The first paragraph (split to create a new second paragraph) of

Section 9.1 of the IWP License Application will be revised to read as follows:

9.1 Environmental Report

The ER (IIFP, 2009) constitutes one portion of an application to be submitted by IIFP to construct

and operate a facility that offers de-conversion services of DUF6 and extracts the fluoride from the

DUF 6 to produce high-purity fluoride gas products and anhydrous hydrofluoric acid (AHF).
General Information

During this Phase 1 process the DUF6 uranium will be de-converted into depleted uranium (DU)

tetrafluoride (DUF4) and then into DU oxide in the fluorine extraction process. In the future Phase

2 Ffacility, that will be licensed and constructed as a separate activity, an additional process will

be used for direct de-conversion of DUF6 to AHF and depleted uranium oxide. In both processes,

the fluorine products and AHF are sold, and the depleted uranium oxide is sent for off-site

disposal to a licensed low-level radioactive waste disposal facility. -I

The PFePe4IIFP Ffacility, and planned phase 2 expansion-, will be located near Hobbs, New

Mexico (Figure 9-1). The ER for the propose IIFP Ffacility serves two primary purposes. First, it

provides information that is specifically required by the Nuclear Regulatory Commission (NRC)

to assist it in meeting its obligations under the National Environmental Policy Act (NEPA) of

1969 (NEPA, 1969) and the Environmental Protection Agency's (EPA) NEPA-implementing

regulations. Second, it demonstrates that the environmental protection measures proposed by IIFP

are adequate to protect both the environment and the health and safety of the public.

License Documentation Impact: The introductory section of IIFP Chapter 10,

"Decommissioning" will be revised to eliminate references to a Phase 2 facility and will read

(changes in red text) as follows:

10 Decommissioning

This chapter presents the International Isotopes Fluorine Products, Inc. (IIFP) Plant ini•iaDecommissioning Funding Plan for its Fluorine Extraction Process and Uranium De-conversion

Plant (FEPIDUJP). This Decommissioning Funding Plan (DFP) has been developed following the

guidance provided in NUREG- 1757 (NRC, 2006). The DFP is for only the current IIFP License

Application and licensing activities. Any future facility expansions of licensing actions would

require an amended or separate DFP.

The IIFP facility v.ill be constructed in two phases, with Phase 1 completing the DUF640 DUF4-

proceSS and the DUF-4te fluer-ine proeducts proeesses and the supporting infrastruciture of the plant.

IIFP plans to expand the facility, de cnerse caaity by conistructing a Phase 2 plant

apprOXimately 4 years laer. The current licenin apliato, integrated Safet Analysis (1SA)

and Decommission Funding Plan submittal arc 4c1 Phae Instruction and Operaitionl onlly.

Separate or- amended licensing and a revised DFP will be developed and submfitted at anl

appropriate time during the licensing proess% of the Phase 2 project. The Phase 2 Will consist ofthe atdditionlal pFroessing equipmfenit to oneriet DUES directly int uraniu oxide.

IIFP, Inc., as a wholly owned subsidiary of International Isotopes, Inc. (INIS), commits to

decontaminate and decommission the facility at the end of its operation so that the facility and

grounds can be released for unrestricted use. The Decommissioning Funding Plan will be

reviewed and updated as necessary at least once every three years starting from the time of the

start of operations. Prior to facility decommissioning, a Decommissioning Plan will be prepared

in accordance with 10 CFR 40.42 (CFR, 2008a) and submitted to the NRC for approval.

This chapter fulfills the applicable provisions of NUREG-1 757 (NRC, 2006) through submittal of

information in tabular form (Tables 10- 1 through 10- 18) as suggested by the NUREG.

License Documentation Impact: The first paragraph of the IIFP License Application Section

10.1 will be deleted and the revised Section will read as follows. Former paragraph three will be
General Information

revised in response to RAI D-1. Also, the wording "Phase I" will be deleted from the title of

Section 10.1.1 as shown below.

10.1 Decommissioning Strategy

The Decommissioning Funding Plan addresses the overaill Stfateg' for deeoffmfisSionling the

entirce Phase -2 facility. However-, because of the twe phase construcetion approeach to thisfcity

the DFP onRal praVideS a detailed cost estimate, schedule and the financial aSSUrance Plan fro the

Phase 1 equipment and the infrastretu equi'en that will be commen to both phases. Thisa

initial DFP, including dest estimates, schedule and finae.ial assurane, assumfes that only a Phase

1 f wduld acility exist a the time that decommys in ast required. This s sateg' of prepdwing and

Su~bMituing an initial DFP for Phase 1 facilities only, in this license application, conseR.'aively

cnsiderrs that e would nFP cease business before Phase 2 is onstructed Or that Phase 2 wouldn

mater-ialize. This contingency strateg' deS prE. ide for- the financial assur-ance of the Phase I

facility in an, ease. Expansion of the plant to Phase 2 will require admiendments t the siFP

license, and the DFP will be updated and Fe submitted to the NRG for approVal pRior to the

intopductieon mf nulenr materials into the Phase 2 portien of the faciity.

The overall strategy for decommissioning is to decontaminate or remove all materials from the

site in order to release the facility and the site for unrestricted use. This approach avoids

long-term storage and monitoring of wastes on site. The type and volume of wastes produced

at the FEP/DUP facility do not warrant delays in waste removal normally associated with a

deferred dismantlement option.

At the end of useful plant life, the FEP/DaP facility will be decommissioned such that the site

and remaining facilities may be released for unrestricted use as defined in 10 CFR 20.1402 (CFR,

2008b). IIFP will use guidance provided in NUREG-1 505. NUREG-1 575 and NUREG-1 757 in

developing initial and final site survey plans sufficient to provide background and

post-decontamination site condition to enable the free release of the site. .

All remaining facilities will be decontaminated where needed to acceptable levels for unrestricted

use. Hazardous wastes will be treated or disposed of in licensed hazardous waste facilities.

Disposal of radioactive or hazardous material will not occur at the plant site, but at licensed

facilities located elsewhere. Following decommissioning, the facilities and site will be available

for reuse.

Financial arrangements are made to cover costs required for returning the Phase 1 portions of the

&iteIIFP Facility to unrestricted use. Updates on cost and funding will be provided as described

above. A detailed updated Decommissioning Plan will be submitted at a date near end of plant

life, in accordance with 10 CFR 40.42 (CFR, 2008a).

The following describes decommissioning plans and funding arrangements. This information was

developed in support of the decommissioning cost estimate. Specific elements of the planning

may change with the submittal of the decommissioning plan required at the time of license

termination.
General Information

10.1.1 IIFP Ph se4-Facility Description

License Documentation Impact: Paragraph two in LA Section 10.1.3.1 and the first paragraph

in Section 10.3.2 will be revised to eliminate references to a Phase 2 facility and will read

(changes in red text) as follows:

Actual decontamination and decommissioning would follow shortly upon approval of the plan

and the award of any subcontracts. The decommissioning plan schedule for the Phase-1IFP

Ffacility is shown as Figure 10-1. At the time Of required decommissi.ning, if Only a Phase 1

plant exists, then upon deeommissioning and final sai-vey and confirmation by the NRC, the

license wouild be terminated and the site,'facilit, eeould be released &Fo reuse. 1f a Phase 2 also

exiAs at the timne of requirced decomissonig, the updated future DCF Pilan fcr Phase 2 will

have indentified the eosts, sehcdule and an") deeontamination and decomisson equiremfenltsfo

the.-DUF-6-to oxide proceess beyond these already, identified ini the Phase 1 Plan.

In accordance with 10 CFR 40.36(d) (CFR, 2008h), IIFP will update the decommissioning cost

estimate for the FEP/DUP, and the associated funding levels, over the life of the facility. Updates

will take into account changes resulting from inflation or site-specific factors, such as changes in

facility conditions or expected decommissioning procedures. Funding level Updates will also

address anticipated operation of Phase 2 portionis of the facility pr-ior to introdueaing nuclearmnaterials into that equipment.

License Documentation Impact: Table 7-3 of the IMP License Application will be revised to

delete the subtitle "Phase 1" from the second row of the Table. The remaining Table data are for

the IIFP Facility that is described in the current licensing activities and License Application.
General Information

GI-6

B. LA Sections 1.1.2.1 and 1.1.2.2 and Table 1-2 provide a description of each of the

major buildings at the facility. However, buildings which process uranium (listed in Table 1-2

in bold text) are grouped and described in general terms, while other major buildings, e.g.,

decontamination building, fire pump house, etc. are described individually, building by

building. Consistent with the requirements in NUREG-1520, Section 1.1.4.3 (2), provide a

description of the processes conducted in the processing of uranium, building by building,

similar to the other major buildings listed in Section 1.1.2.2. Ensure that the description is

presented in a manner that facilitates an understanding of the flow of material through the

process.

RESPONSE: The process buildings and their type of construction were described in LA Section

1.1.2.1 mainly as a group as we viewed the LA Chapter 1, "General Information" as more

introductory to the License Application. We described the "Other Major Buildings" in more detail

in Section 1.1.2.2 originally in order to differentiate their type of construction and individual

functions in support of the process building group. The Section 1.1.2.1 is being revised, as shown

below, to include individual process building descriptions and in a manner that will describe the

basics of flow of material through the processes that are later described in the Section 1.1.3 of the

LA Chapter 1, "General Information".

License Documentation Impact: Starting at former paragraph four of Section 1.1.2 of the LA,

the Section is being revised to move and update the Table 1-2. Additional wording and a list have

been added to the end of paragraph seven in response to RAI SS-8 (black text is original and red

text is change) to read as follows. The changes shown below are relevant to RAI GI-6B. Other

changes to Section 1.1.2 will be made in response to RAI GI-8.

The process equipment is located within building structures, where feasible. Process buildings

that function as product and waste material storage have separate areas for each purpose. Those

areas have loading/unloading docks to facilitate shipping.

Process buildings have aprons, curbing and dikes and external pads have curbing and dikes where

chemicals are stored or handled. Pumps are provided on pads and in building selected areas to

transfer chemicals to containers or to the Environmental Protection Process (EPP) in event of a

spill or leak.

Auxiliary buildings generally house:

* Materials;

0 Maintenance shop;

* Laboratory equipment;

0 Steam boilers and supporting utilities;

• Electrical utility equipment;

0 Sanitary water treatment, certain equipment for process water treatment and

recycle, and

a Accommodation for personnel work, break-rooms, change-rooms, and toilets.
General Information

The following is a list of applicable Federal, State, and local codes and standards that the DB

contractor will use during the detailed design, construction and startup stage of the project to

insure adequate protection against natural phenomena, environmental conditions, and dynamic

effects. The DB contractor will also ensure, as part of the written contract, that design meets these

applicable federal, state and local codes and standards. Buildings, lighting, fire protection, and

building support systems are designed in accordance with latest revisions, of building and

construction codes including where applicable the National Fire Protection Association (NFPA)

standards, local and State codes, and related codes and standards. NFPA Standards are listed in

Chapter 7 of the LA, Table 7-1. The primar_ applicable codes and standards (editions applicable

at time of design) for the design and building requirements of the IIFP Facility include the

following:

2006 New Mexico Commercial Building Code (adopts by

reference the 2006 International Building Code (IBC) with

amendments)

2006 New Mexico Energy Conservation Code (adopts by reference

the 2006 international energy conservation code (IECC) with

amendments)

2006 New Mexico Plumbing Code (adopts by reference the 2006

Uniform Plumbing Code (UPC) with amendments)

2006 New Mexico Mechanical Code (adopts by reference the 2006

Uniform Mechanical Code (UMC) with amendments)

2008 New Mexico Electrical Code (adopts by reference the 2008

national electrical code (NEC) with amendments)

2007 New Mexico Electrical Safety Code (adopts by reference the

2007 national electrical safety code (NESC) with

amendments)

2006 International Fire Code

2007 American Society for Mechanical Engineering (ASME)

Section VIII, Division I Design and Fabrication of Pressure

Vessels.

2007 ASME B3 1.1 "Power Piping"

2008 ASME B31.3 "Process Piping"

2006 ASME B3 1.5 "Refrigeration Piping and Heat Transfer

Components"

2008 ASME PA jqjling Services Piping" and

National Fire Protection Association NFPA applicable codes

A listing of the n*4qetWlijAs
General Information

Table 1-2 IIFP FEP/DUP Plant Building Sizes

following:

2006 New Mexico Commercial Building Code (adopts by

reference the 2006 International Building Code (IBC) with

amendments)

2006 New Mexico Energy Conservation Code (adopts by reference

the 2006 international energy conservation code (IECC) with

amendments)

2006 New Mexico Plumbing Code (adopts by reference the 2006

Uniform Plumbing Code (UPC) with amendments)

2006 New Mexico Mechanical Code (adopts by reference the 2006

Uniform Mechanical Code (UMC) with amendments)

2008 New Mexico Electrical Code (adopts by reference the 2008

national electrical code (NEC) with amendments)

2007 New Mexico Electrical Safety Code (adopts by reference the

2007 national electrical safety code (NESC) with

amendments)

2006 International Fire Code

2007 American Society for Mechanical Engineering (ASME)

Section VIII, Division I Design and Fabrication of Pressure

Vessels.

2007 ASME B3 1.1 "Power Piping"

2008 ASME B31.3 "Process Piping"

2006 ASME B31.5 "Refrigeration Piping and Heat Transfer

Components"

2008 ASME B31.9 "Building Services Piping" and

National Fire Protection Association NFPA applicable codes

as detailed in Table 7-1 "NFPA Standards of this License

DIMENSIONS (feet)

BUILDING (Areas where uranium is APPROXIMATE

processed or stored are marked in "bold" APPROXIMATE VOLUME (cubic

print") AREA (square fee~t feet)

red text is change) to read as fol ows:

EAVE

_1_7_1 Praw-.•R.d,.hlino• •I ILENGTH WIDTH HEIGHT

DUF6 Autoclave Building 90 60 40 5,400 216,000

General Description

The DUF6 Autoclave Building, DUF4 Process Building, DUF4 Container Storage Building, DUF4

Container Staging Building, Decontamination (Decon) Building, FEP Process Building (SiF4 and

BF3), FEP Oxide Staging Building, FEP Product Storage & Packaging Building and the EPP

Building are of structural steel beam and column construction with metal wall panels and with
General Information

Class 1 metal roofs. The first floor of each building is constructed of reinforced concrete with

curbing to function as a containment-_pe barrier. Loeated in the nor"theast eerrier of the aess

pad and adjacent to the D! Pr.cess Building, is the DUF4 ContainRe Staging Building. This

building is used for rmemving DUF4 f~ere-D44F shipping container-s that may be receiNved from

suppliers nd fo. r .. t.ansfeing into the D!4 hoppers loeated in the DUF4 .eeess. Build.hrgThe A-IF Staging Containment Building and the Fluoride Products Trailer Loading Building are

constructed of reinforced concrete floor slabs with a containment-bpe barrier design around the

inside perimeter. The upper sections of these buildings are of concrete or concrete block

construction with Class 1 metal roofs.

Radiological boundary control hand-foot monitors are strategically located at building walkway

exits of areas where determined to be needed. Fluoride and radiological detection systems, local

alarms and alarm notification to Controls Rooms are also strategically located in those building

areas, where applicable.

The ProeeS buld: UUF4, Process Building and the FEP Process Building are multi-story

buildings where ne-essary to provid S for cqu..ipm.f-n..t-. spaec and to provide elevations

for permitting gravity flow of particulate solids through equipment and piping, where applicable.

The Upper floors are cnfigured such as to pro.vide adequate room for equipment ,-nction and

mnaintenance.The uppef floor areas below the equipment and piping containing powdered

materials are constructed of reinforced concrete with curbing and seal coatings on floor and wall

surfaces. Other upper floor areas of the buildings are constructed of metal grating or metal

flooring.

Process Control Rooms are provided in the major processes, including appropriate monitoring,

recording, alarm notification and control instrumentation. A Control Room is located in the DUF4

Process Building. The DUF6 Autoclave Building is controlled from the DUF4 Process Building.

The FEP Process Building ptant-has its own process Control Room for the SiF4 and BF3

processes. The AHF Staging Containment Building and Fluoride Products Trailer Loading

Faeility-Building share a Control Room. Likewise, one control area is located in the Utilities

Building for monitoring and controlling the steam boiler system, air compressors and other utility

supply equipment. Control room areas and electrical and instrument rooms are typically of

concrete block construction with concrete or metal roofs. Ceiling assemblies and fire walls

separate these areas from production areas of the facilities. Process area Control Rooms, where

routinely occupied by workers, have environments maintained for comfort and safety. Control

Rooms located in process areas, where uranium or hazardous chemicals are processed, stored or

handled, have separate heating, ventilation and air conditioning (HVAC) systems. The Control

Rooms in these areas are designed to maintain a positive pressure environment with

high-efficiency filtration of intake air and are provided with low pressure alarms to notify

occupants should a loss of pressure inside a Control Room occur.

The process buildings are classified per NFPA 13 as Ordinary Group 2 and are protected with 100

percent coverage, wet-type fire protection sprinkler systems with Class 1 standpipes between

floors in all exit stairways of multi-story buildings- (NFPA, 2007). Codes followed for

construction are the latest editions as adopted by the State of New Mexico. Further information is

provided for code construction conformance requirements in the IIFP Integrated Safety Analysis

Summary, Section 2.3. IIFP will contract and use a Design and Build contractor for detail design,

engineering and construction of the IIFP Facility. A final Record of Codes for construction will be

established at the time the Design and Build contractor starts the detail design.
General Information

Each process building/area and its relationship to respective process flows are further described

below.

Full DUF6 Cylinder Storage Pad

Cylinders containing solid DUF6 are received by truck from customers/suppliers in accordance

with approved Department of Transportation shipping requirements. After following

pre-unloading procedures for material accountability, cylinder inspection, shipping document

verifications, and IROFS requirements related to assay and weight verification, the cylinder is

unloaded for temporary storage at the Full DUF6 Cylinder Storage Pad. This pad is used to stage

full DUF6 cylinders for processing. Cylinders are moved by a special cylinder hauler to the DUF6

Autoclave Building as needed for feeding of contents to the DUF6-to-DUF4 process. Protective

anchored concrete-filled pipe bollards are installed around the perimeter of the cylinder pad in

locations where a potential exposure to uncontrolled vehicle traffic exists. The pad is constructed

of reinforced concrete and is approximately 175 feet wide by 200 feet long and is sized to store up

to 60 full cylinders. The entire storage pad is curbed for storm water collection and is provided

with underground drains connecting to the Cylinder Pad Stormwater Retention Basin located

south of the cylinder pad. The surface and slope of the cylinder pad is designed to prevent any

significant pooling of liquids. The pad is provided with saddles to space and support the cylinders.

A full cylinder is placed in a saddle and never stacked.

DUF6 Autoclave Buildine

The DUF6 Autoclave Building is one level and includes a large overhead area to accommodate a

bridge crane. The building contains two containment-type autoclaves that use controlled steam to

safely vaporize the solid DUF6 for feeding to the DUF4 process. The vaporized DUF6 flow is from

the feed cylinder located in the autoclave through a feed header and piping to the DUF6-toDUF4

reaction vessel that is located in the DUF4 Process Building. Typically, the content of one DUF6

cylinder is being fed to the reaction vessel from one autoclave. The other autoclave is going

through a cycle of unloading an emptied cylinder, reloading of a full solid-contents cylinder and

heating the cylinder contents in preparing it to be fed to the reaction vessel.

Also included in the DUF6 Autoclave Building are two cold boxes cooled by refrigeration

systems and sized to contain one 48Y-type cylinder each. One cold box is used to collect DUF6

cylinder heels after cylinders have been fed out to the DUF4 process. The other cold box is the

receiving vessel for the purge and evacuation system that serves the DUF4 process.

Two rail mounted cylinder carts and weigh scales are provided in the autoclave area. One cart and

scale are located between the two autoclaves, and the other cart and scale are located between the

cold boxes. An overhead bridge crane is installed to hoist the DUF6 cylinders into and out of the

autoclaves and cold boxes. The crane path is designed to permit lateral movement without

traveling above an autoclave or cold box containing a DUF6 cylinder.

Motor Control Center (MCC) and instrumentation equipment rooms are located in the east end of

the DUF6 Autoclave Building on the first floor.

Just west of the DUF6 Autoclave Building, a reinforced concrete pad is installed as a staging area

for DUF6 cylinders. This pad is located at the entrance doors to the DUF6 Autoclave Building to

provide for staging of both empty and full cylinders by the cylinder hauler to and from the
General Information

outdoor cylinder storage pads. Protective anchored concrete filled pipe bollards are installed

around the staging area for protection of DUF6 cylinders from vehicular traffic.

Empty DUF6 Cylinder Storage Pad

Approximately 150 ft east of the intersection of the East and South Roads is the Empty DUF6

Cylinder Storage Pad. This pad is used to stage empty DUF6 cylinders in preparation for shipment

from the facility. A security fence is installed around the entire perimeter of the cylinder pad with

one entrance opening with clearance for the cylinder hauler to maneuver. The pad is constructed

of reinforced concrete and is approximately 105 ft wide x 185 ft long and sized to contain up to 40

empty cylinders. The pad is provided with saddles to space and support the cylinders. Empty

cylinders may be double stacked if necessary.

DUF4 Process Buildine

The DUF4 Process Building is a five level building adjacent to the DUF6 Autoclave Building with

a fire barrier between the two buildings. It is within this building that DUF6 is converted to DUF4

and AHF.

The DUF6 from the DUF6 Autoclave Building flows to the DUF6 surge tank where it enters the

top of the DUF6 to DUF4 reaction vessel. Also hydrogen gas from the hydrogen gas generator

system, that is located outside and remote of the DUF4 Process Building, flows through control

systems into the top of the reaction vessel. The DUF6 reacts with the hydrogen gas to form DUF4

solid particles and AHF gas. The DUF4 powder is removed from the reaction vessel by a cooling

screw where it is transported to hoppers for temporary storage. The AHF exits the bottom of the

reaction vessel through the cooling screw as an off-gas: passes through two sets of filters in series

configuration: through a series of carbon-bed traps to remove any residual un-reacted DUF6 then

through two in-series condensers where the AHF liquefies and drains into temporary storage

tanks that are located in the Al-F Staging Containment Building. The residual off-gas that passes

through the second condenser flows through a hydrogen burner and the Plant KOH Scrubbing

System and vent stack, all of which are located external to the DUF4 Process Building.

The top level of the DUF4 Process Building contains the top portion of the reaction vessel and the

DUF6 surge tank. Also on this level are the primary and secondary dust collectors and dust

collector blower. The fourth level houses six carbon-bed traps (configured as two banks of three

traps in series), the off-gas primary filter, and the off-gas secondary filter. The partial AHF

condenser, total AHIF condenser and the cooling screw conveyor are located on the third level.

The second level contains the product transfer screw, vibrating screen and the top heads of the

three DUF4 storage hoppers. The bottom outlets of the three DUF4 storage hoppers and the

product vacuum transfer system are located on the first level. One bay is clear on all floors to be

used to facilitate maintenance of equipment, instrumentation and piping. Just west of the DUF4

Process Building, a reinforced concrete equipment access pad is installed to provide access to

equipment for removal from the DUF4 Building if removal of such equipment is required for

maintenance.

DUF4 Container Staging- Building

Located in the northeast comer of the access pad and adjacent to the DUF4 Process Building, is

the DUF4 Container Staging Building. The purpose of this building is to provide equipment and

space for unloading, staging and emptying DUF4 containers that may have been used to
General Information

temporarily store additional inventory of DUF4. The building may also be used to handle DUF4

that may be received from other suppliers for conversion of DUF4 to fluoride gas products. This

building is used for removing DUF4 from storage or shipping containers and for transferring into

the DUF4 hoppers located in the DUF4 Process Building.

Decontamination (Decon) Building

The Decontamination Building serves as a facility with equipment to manage Low-Level

Contaminated Waste (LLW) other than the depleted uranium oxide waste. A more detail

explanation in the use of the Decontamination Building to manage LLW is provided in Section

9.2.2.1, "Waste Management Procedures;" Chapter 9 of the IIFP License Application.

The Decontamination (Decon) Building is located adjacent to, and on the north side of the DUF4

Process Building. The construction provides for a fire barrier between the Decontamination

Building and the DUF4 Process Building. This Building and its equipment is used for

decontamination of process equipment for maintenance and removal of depleted uranium from

decontamination wash waters or from small volumes of contaminated liquors. The Decon

Building contains an equipment cleaning booth and hood system, primary and secondary dust

collector system in series, holding tanks, precipitation tanks, primary and polishing filters,

associated pumps, piping, field equipment instrumentation panels, ion exchange columns and

associated controls and backwash systems.

FEP Process Buildin2

The FEP Process Building is a four level building located just east of the DUF4 Process Building.

The SiF4 and BF3 processes that involve licensed material are housed in this building. The flow of

process materials for both of these processes begins with DUF4 being transported from the DUF4

Process Building to the respective DUF4 feed hoppers (bin) in the FEP Process Building.

In the SiF4 process, the DUF4 is mixed with Si02 and fed to the rotary calciner equipment. In the

rotary calciner the mixture reacts to form SiF4 gas and solid particle uranium oxide. The depleted

uranium (DU) oxide discharges the end of the rotary calciner and is temporarily stored in hoppers

until packaged for shipment to an off-site licensed disposal facility. The SiF4 product exits the

rotary calciner as an off-gas, flows through a set of filters configured in series flow and through

pre-condensers for removing hydrogen fluoride (HF) impurities. The product gas then flows to

primary and secondary cold traps where the product is collected. The residual off-gas from the

secondary cold trap flows to the Plant KOH Scrubbing System to receive three-stage treatment

prior to discharging to the atmosphere through the vent stack.

In the BF3 process, the DUF4 is mixed with B203, fed into a pre-heater where moisture is removed

by forming HF that leaves the pre-heater as a vapor and flows to the Plant KOH Scrubbing

System. The mixed solids discharge the pre-heater into a rotary calciner where the BF3 product

gas and uranium oxide are produced. The depleted uranium oxide discharges the rotary calciner to

temporary storage hoppers until packaged for shipment to an off-site licensed disposal facility.

The BF3 product gas flows from the rotary calciner through two in-series filters, through

pre-condensers for HF impurity removal, and then is collected in primary and secondary cold

traps. The off-gas that exits the secondary cold trap flows to the Plant KOH Scrubbing System for

three-stage treatment prior to discharging to the atmosphere through the vent stack.
General Information

The top level of the FEP Building supports the product cold traps, the pre-condensers, secondary

filters, primary and secondary dust collectors, and dust collector blower. The third level houses

the primary filters, the Si02 and B203 feed hoppers, DUF4 feed hopper, the dust collector fines

hopper, the ribbon blender, the feed conveyors, and the pre-heater (for the BF3 process only). The

second level contains the rotary calciners for the SiF4 and BF3 processes. The cooling screws

associated with the rotating calciner discharges are also on the second level. The oxide hoppers

and the drum-off stations are located on the first level. Also located on the first level are the FEP

Control Room, as described above, and the electrical equipment room.

The largest amount of solid waste generated at the IIFP Facility is the depleted uranium oxide that

is a byproduct of the FEP process. This waste is managed using the equipment and facilities of the

FEP Process Building and the FEP Oxide Staging Building. The use of these buildings and

associated equipment in managing this oxide waste is described in Section 9.2.2.1, "Waste

Management Procedures;" Chapter 9 of the IIFP License Application.

FEP Oxide Sta-ina Buildinp

The FEP Oxide Staging Building is adjacent to, and on the east side of the FEP Process Building.

The wall between the FEP Oxide Staging Building and the FEP Process Building is a fire barrier.

This building is a two level building with a reinforced concrete floor on the first level with

containment-type curbing. It is used for staging of oxide waste containers for loading into truck

trailers and transporting to an off-site licensed waste disposal facility. Equipment in the building

consists of enclosed container-loading stations, weighing equipment, electrical and

instrumentation monitoring and alarm panels and controls, exhaust hood systems, piping and

ductwork connections to the primary dust collector system.

DUF4 Container Storage Building

Just east of, and adjacent to, the FEP Oxide Staging Building is the DUF4 Container Storage

Building. This building is used to store additional inventory of DUF4 or shipping containers of

DUF4 that may be received from suppliers. This source of DUF4 can be used in production of

FEP products and/or de-converted to depleted uranium oxide.

FEP Product Storage and Packagin2 Building

The FEP Product Storage and Packaging Building is separated from, and located at the south side

of the FEP Process Building. In this building, the purified SiF4 and BF3 products, which are

chemically and physically separated from licensed material, are received for temporary storage

and packaging. When a product cold trap in the FEP Process Building is ready to be unloaded, the

respective product compressor and evaporator in the FEP Product Storage and Packaging Building

is used to transfer the product to storage tubes in this building. The building contains two levels

and has a reinforced concrete floor on the first level with containment-type curbing. The

equipment in this building is used transfer product from temporary storage tubes to truck

tube-trailers located in the Fluoride Products Trailer Loading Building or to package and store

SiF4 and BF3 product gas in cylinders for shipment to customers. This building houses the FEP

compressors and associated coolers, product evaporator vessels, storage systems,

containment-type enclosures containing the packaging manifolds, and the exhaust hoods and

ductwork that connect to an emergency scrubber. The FEP product gas storage system consists of

12-in. diameter by 30 ft long, high pressure, ASME coded and stamped storage tubes inside a

common
General Information

cooling area. Approximately 30 FEP product storage tubes that are configured in banks of five are

provided, including the spare tubes.

FEP Building Dock

An elevated dock on the southeast side of the FEP Process Building provides access for truck

loading for transporting oxide containers to licensed waste disposal facilities and for truck

loading for shipping SiF4 and BF3 cylinders to customers.

Plant Potassium Hydroxide (KOH) Scrubbing System

A KOH liquid scrubbing system is used to remove residual fluorides from each process off-gas

prior to venting the off-gas flows to the atmosphere. This Plant KOH Scrubbing System vents

treated gases through a single stack. The system is utilized to treat final off-gas streams from the

DUF4 production process (DUF6 to DUF4) and the SiF4 and BF3 processes. The off-gas streams

flow first through a concurrent-venturi where the gas contacts aqueous KOH solution and then

flow is through a counter-current flow pack tower where further scrubbing with aqueous KOH

solution occurs. Final scrubbing of the gas is achieved by flow through a bed of sized coke in

contact with a counter-current flow of aqueous KOH solution, where the treated gas is then

discharged through a vent stack to the atmosphere. The Plant KOH Scrubbing System stack is

monitored to measure for traces of fluorides or uranium in the vent gas.

The spent liquors resulting from scrubbing the fluorides contain mainly potassium fluoride, water

and some un-reacted KOH. The spent liquors are sent to the Environmental Protection Process

(EPP) Building to regenerate the KOH liquid for recycle back to the scrubbing system.

The KOH venturi-type (primary), packed tower (secondary), and coke box (tertiary) scrubbers and

pumps, KOH tanks and associated equipment; and dike pad that serve the DUF4 process are

located outside and adjacent to the east side of the DUF4 Process Building. The system consists of

two similar lines of three-stage in-series scrubbers.

The primary scrubber equipment (venturi-type) for the FEP process is located outside and on the

west side of the FEP Process Building, with the venturi off-gas vents connected by piping to the

packed towers of the scrubber system that serves the DUF4 process. This configuration provides

secondary and tertiary treatment of the final effluents from the FEP processes prior to venting to

the atmosphere.

Environmental Protection Process Building

The Environmental Protection Process (EPP) Building is located east of the DUF4 Container

Storage Building and inside the EPP process dike area. The building equipment is used to treat

fluoride bearing liquors for recycle and reuse in the plant processes. In this process, hydrated lime

is reacted with spent KOH solution that is received from the Plant KOH Scrubbing System. The

reaction results in regeneration of KOH and formation of calcium fluoride. The solid particle

calcium fluoride (CaF2) is filtered and dried for shipment to customers or disposal at an off-site

licensed disposal facility. The regenerated KOH is pumped back to the Plant KOH Scrubbing

System for reuse.

The building houses the EPP control systems, rotary vacuum filter, dryer feed screw, dryer, and

discharge screw. Equipment for reacting hydrated lime with the fluoride bearing liquors includes
General Information

the reaction tank, clarifier, pumps, regenerated KOH recycle tank, holding/feed tanks, and

associated equipment. This equipment is located outside the EPP Building and within the process

dike area.

AHF Staging Containment and Fluoride Products Trailer Loading Buildings

The AHIF Staging Containment Building and the Fluoride Products Trailer Loading Building are

located east of the DUF6 Autoclave Building and south of the FEP Product Storage and Packaging

Building. A fire barrier is located between the Al4F Staging Containment Building and the

Fluoride Products Trailer Loading Building, and between the FEP Product Storage and Packaging

Building and the Fluoride Products Trailer Loading Building. A minimum number of sealed pipes

and conduits penetrate the walls separating these buildings. Each building is constructed as a

separate enclosed area. The buildings are not totally leak tight, but provide a level of secondary

containment to suppress or inhibit an ARF. SiF4 or BF3 release in the event of a spill or leak.

The AH-F Staging Containment Building houses four (4) 8,000 pound AlIF storage tanks, piping

and controls. The Fluoride Products Trailer Loading Building is used as an enclosed area for

loading AHF trailers and for loading SiF4 and BF3 tube trailers for shipment to customers. Vent

lines and relief valve lines on the storage tanks and from the trailer during loading are connected

to the Plant KOH Scrubbing System described above.

The products are loaded from the storage tanks into approved Department of Transportation

(DOT) tank trailers when inventories reach a level for shipment. A minimum number of product

transfer lines from each process enter the Fluoride Products Trailer Loading Building.

The Fluoride Products Trailer Loading Building contains a truck entrance door on one side that

remains sealed, closed and controlled except for short periods when the trailer is moved in and

out. Safety precautions are taken to prevent the trailer from contacting the fill line by the

installation of physical barriers, and to prevent inadvertent movement of the trailer during

load-out.

Two positive-air-lock doors are located in each building. One air-lock in each building is an

emergency exit to the outside. The other air-lock in each building is an exit and also an entrance

to a separate control room, under positive pressure, where surveillance and operational controls

for the two containment areas are managed.

In these buildings, the SiF4, BF3and AHF products have been chemically separated from licensed

materials. These products in these buildings are also physically separated from licensed materialssuch as not to affect licensed materials.

License Documentation Impact: LA, Section 1.1.2.2 is being revised to remove duplicated

descriptions that will be revised and moved to Section 1.2.2.1 above. Also, "Material Warehouse"

description is being revised in Section 1.1.2.2 to identify its function as part of managing nonradioactive waste. The remaining text in the section will remain unchanged. Changes below are

relevant to RAI GI-6B. Other changes will be made to Section 1.1.2.2 in response to RAI OA-2.

Decontamination Buildina
General Information

The Decontamination Building is leeated adjacent to, and on the north side of the4DUF4PFEeeeSS

Building. The construetion proevides for- a fire barrier betweeni the Decontamination Building and

the-DUF4 Process Building. This building is used fcr decontamnination of equipment fcrmaintenance anid r-emoval of uranlium from decontam ination wash waters or- froem small volumes

cf contaminated liquorFS. The Decontaminaition Building contains an equipment cleanling boothand hood system, pr-imnar-y and seeondafy dust ecileetOr SyStem'l in series, eontaminated wate

holding tanks, pr-imaryj and polishing filters, associated pumps, piping, field equipmfenit

instrumentation panels, ion excehange columns and associated controls and baekwash systems.-

DUF4 Container Storgae Buildina

just east of-, and adjacent to), the FEP Oxide Staging Building is the-IDUF4 Container- Stoaffge

Building. This building is uised to store shipping containers Of DUF4-that may be received from

~L~J~JLLL 0.

depleted ur-anium oxide.

•UL •

r 1-

Material Warehouse

The Material Warehouse is located just northeast of the Process Offices and/-Laboratory

Building. This warehouse is used to receive and store such items as piping components, electrical

conduit, wiring, equipment for capital construction projects and spare parts. Small quantities of

chemicals such as paints, oils, and cleaning agents are stored in the warehouse, but the quantities

are limited to meet New Mexico Commercial Building Code (NMCBC and NFPA requirements.

No licensed, raw, or in-process materials or finished products are stored in this building.

Part of the Material Warehouse is used for managing non-radioactive waste. This function is

described in Section 9.2.2.1. "Waste Management Procedures;" Chapter 9 of the IIFP License

Application.
General Information

GI-6

C. LA Section 1.1.3.2, Page 1-13, thirdfull paragraph contains a description of the

exothermic reaction of Depleted Uranium Hexafluoride (DUF6) to Depleted Uranium

Tetrafluoride (DUF4) and Anhydrous Hydrogen Fluoride (AHF). Consistent with

NUHEU g9, Spetid& what reacts exothermically with the DUF6. Specify where this reaction

takes place, e.g., in the DUF4 building, and specify which building listed in LA Table 1-2

contains the reaction vessel for this process.

RESPONSE: The standard heat of formation (enthalpy) for hydrogen and uranium hexafluoride

reaction to form DUF4 and AHF is considerably exothermic; approximately - 285 kilojoules/mol.

In the DUF6 to DUF4 process, in order to ensure an efficient reaction, the reaction is initiated at

about 300 F, or above, at which the reaction is exothermic and sustains an efficient reaction

temperature. Air cooling around the reaction vessel is employed to control the reaction at set

temperature, while insulation around the reaction vessel and electrical heating around part of the

reaction vessel are utilized for fine control of the reaction temperature. In the DUF6 reaction

vessel, hydrogen gas reacts with DUF6 as an exothermic reaction to produce DUF4. The DUF6

reaction vessel is located in the DUF4 Process Building.

License Documentation Impact: Section 1.1.3.2, paragraph 6 of the ITFP License Application

will be revised to read as shown below. The changes shown below are relevant to RAI question

GI-6B. Other changes made in response to RAIs GI-7C and ISA-14 in the Integrated Safety

Analysis Summary, Revision A, Section 3.1.2.2 will be incorporated, as applicable, in future

revisions of the LA, specifically Section 1.1.3.2.

The DUF6 cylinder is placed in a containment-type autoclave; where the contents are vaporized.

The DUF6 vapor is then fed to a-the DUF6 reaction vessel, located in the DUF4 Process Building,

where it und"ergoes . x.thermi- reactsioei-with hydrogen gas to produce DUF4 and AHF. The

reaction is exothermic which sustains an efficient reaction temperature. Air cooling around the

reaction vessel is employed to control the reaction at set operating temperatures. Insulation around

the reaction vessel and electrical heating around part of the reaction vessel are utilized for fine

control of the reaction temperature. The DUF4 solid powder is continuously withdrawn from the

reaction vessel bottom through a cooling screw mechanism and transferred to storage hoppers. A

two-2-stage dust collector system is provided to control and recycle DUF4 dusts-dust that is

generated by gas flows are-internal to the solids handling equipment. and generated b" air Or gas

flews asse.iated with the handling equipment. The DUF4 in the storage hoppers is transferred to

the FEPplant for use as raw material feed in producing SiF4 and BF3.
General Information

GI- 7 LA Pages 1-1 and 1-2 list the estimated average inventories for the major chemicals onsite and the

limits for the agreement with the state of New Mexico. In addition, LA Section 1.3 contains Table 1-4 which

indicates the maximum quantity of licensed material requested in the application. However, additional

information is needed regarding the quantity of materials and their chemical and physical forms.

Consistent with the acceptance requirements presented in NUREG 1.2.4.3(3), provide the following

information:

A. LA Table 1-1 lists the projected average for various chemicals used in the process.

Each chemical is represented by a range of values. Clarify if the range of values is the

minimum and maximum quantity. If not, describe how these ranges of values are calculated and

how they represent an average. Add a description of the physical form (gas, powder, liquid) of

licensed material listed in Table 1-1.

RESPONSE: The original Table 1-1, Revision A of the IIFP License Application, "General

Information" Section, was prepared to show the typical range of inventories used in the IIFP

Facility processes based on the estimated variable rates of production and the facility projected

production capacity. The word "average" is a misnomer because the typical range is not

necessarily derived from a calculated average of material inventory. The range of inventory

amounts does not necessarily represent the minimum/maximum values. The range is derived from

estimates of production through-put rates, plant process capacities and additional contingencies

relative to inventory management.

The contingencies included in the estimate are operational and material delivery situations that

may cause variations in the facility raw material, work-in-process and product inventories but

would be controlled such as to not cause licensed materials possession limits to be exceeded. For

example, the upper range of the DUF4 inventory considers that production rates for DUF4 would

be a scenario where, the reaction vessel is operated at its optimum throughput for several

consecutive days thereby accumulating a full inventory in the DUF4 storage hoppers. Then, it

considers the DUF4 reaction vessel may be shutdown, perhaps for scheduling reasons or

preventive maintenance, thus resulting in the inventory drawdown as that inventory is being fed

as the raw material to the FEP process. This mode of operation would contribute to the DUF4

inventory being at the upper amount then decreasing to the lower amount; typical in inventory

management for industrial manufacturing facilities, particularly chemical plants. The normal

variability in production scheduling caused by the operational inter-dependency of the facility

various processes makes it necessary to estimate inventories as a projected range of values.

Some of the contingencies considered in estimating the subject range of inventories include

unexpected changes and variations in market demand, uncertainties in shipping and transportation

schedules, delivery lead-time variability, and abnormal outages on processes and utilities.

In the case of "total depleted uranium", the upper range value is the licensed possession limit. It is

should be noted that State of New Mexico limits are agreed to at higher levels than the requested

license possession limits for kilograms (kg) of total depleted uranium (as "U"). This difference is

a result of the State considering that facility expansions and requests for higher possession limits

may occur under future and separate license requests and actions. The requested licensed materials

possession limit for the current IIFP License Application is 750,000 kg uranium.
General Information

The other chemicals, that are not part of the licensed possession limit, do not have inventory

limits, but are shown in Table 1-1 for reference to other aspects of the IIFP Facility operation.

We are revising Table 1-1 from a projected average to a table of estimated typical range of

inventories for the facility projected (design) production capacity. An additional table colunm

(number three) will be added to provide a description of the physical form of the materials listed

in Table 1-1.

License Documentation Impact: The original Table 1-1 in Section 1, "General Information",

Revision A of the IIFP License Application is being deleted in total and a new Table 1-I is being

added as shown below. The original paragraphs six (also modified in response to RAI GI-2) and

seven along with Table 1-1 will read as follows (black text is original and red text is change or

new). See also RAls GI-2, GI-6A, and GI-7A.

IIFP is requesting a license authorizing up to 750,000 kilograms of depleted uranium (kg U) to be

maintained at any one time in the facility inventory. IIFP is requesting the license authorization

for up to 40 years and is plannings to operate the facility indefinitely and continue to renew the

licenses as needed. IIFP also has a written agreement with the State of New Mexico on the

maximum inventories of mejr- hemie ndepleted uranium oxide and total depleted uranium that

can be maintained on site.

Table 1-1 provides the estimated aver-age-typical range of inventories of major chemical materials

used at the IIFP Facility and the physical forms for each material. Also shown is amd-the

maximum limit on the major chemical inventories as per the IIFP agreement with the State of

New Mexico.
General Information

TUhl& - 1J !FP Fac"ib: .n.-ntr-c.e.-

following:

2006

2006

2006

2006

2008

2007

2006

2007

2007

2008

2006

2008

New Mexico Commercial Building Code (adopts by

reference the 2006 International Building Code (IBC) with

amendments)

New Mexico Energy Conservation Code (adopts by reference

the 2006 international energy conservation code (IECC) with

amendments)

New Mexico Plumbing Code (adopts by reference the 2006

Uniform Plumbing Code (UPC) with amendments)

New Mexico Mechanical Code (adopts by reference the 2006

Uniform Mechanical Code (UMC) with amendments)

New Mexico Electrical Code (adopts by reference the 2008

national electrical code (NEC) with amendments)

New Mexico Electrical Safety Code (adopts by reference the

2007 national electrical safety code (NESC) with

amendments)

International Fire Code

American Society for Mechanical Engineering (ASME)

Section VIII, Division I Design and Fabrication of Pressure

Vessels.

ASME B3 1.1 "Power Piping"

ASME B31.3 "Process Piping"

ASME B31.5 "Refrigeration Piping and Heat Transfer

Components"

ASME B31.9 "Building Services Piping" and

2-

2OO- OW . Gt

L, .rr~-'~ -

a je • ! • I S !

6 ORO WU02. M&MERUM

1 r !t"
General Information

Table 1-1 ILFP Facility Inventories of Maior Chemicals

following:

2006 New Mexico Commercial Building Code (adopts by

reference the 2006 International Building Code (IBC) with

amendments)

2006 New Mexico Energy Conservation Code (adopts by reference

the 2006 international energy conservation code (IECC) with

amendments)

2006 New Mexico Plumbing Code (adopts by reference the 2006

Uniform Plumbing Code (UPC) with amendments)

2006 New Mexico Mechanical Code (adopts by reference the 2006

Uniform Mechanical Code (UMC) with amendments)

2008 New Mexico Electrical Code (adopts by reference the 2008

national electrical code (NEC) with amendments)

2007 New Mexico Electrical Safety Code (adopts by reference the

2007 national electrical safety code (NESC) with

amendments)

2006 International Fire Code

2007 American Society for Mechanical Engineering (ASME)

Section VIII, Division I Design and Fabrication of Pressure

Vessels.

2007 ASME B3 1.1 "Power Piping"

2008 ASME B31.3 "Process Piping"

2006 ASME B31.5 "Refrigeration Piping and Heat Transfer

Components"

2008 ASME B31.9 "Building Services Piping" and

National Fire Protection Association NFPA applicable codes

as detailed in Table 7-1 "NFPA Standards of this License

DIMENSIONS (feet)

BUILDING (Areas where uranium is APPROXIMATE

processed or stored are marked in "bold" APPROXIMATE VOLUME (cubic

print") AREA (square feet) feet)
General Information

GI-7

B. Section 2.4.1 of the ISA, first paragraph, indicates that the DUF6 is vaporized via steam.

State whether the DUF6 will be sublimed or passed through a liquid phase, and indicate the

location and maximum quantity of liquid DUF6 that will be produced throughout the facility.

RESPONSE: Liquid DUF6 is formed only at temperatures and pressures greater than the triple

point as shown below in the UF6 Phase Diagram. Below the triple point, solid DUF6 will change

phase directly to DUF6 gas (vapor) by sublimation when the temperature is raised and/or the

pressure is lowered at continuous points along the solid/gas interface line. In the IIFP DUF6 feed

process at the process operating conditions, the DUF6 passes through a liquid phase because the

operating pressure required to feed the DUF4 reaction vessel is greater than the triple point

pressure of 22 pound per square inch absolute (psia).

Pure UF6 follows its phase diagram (shown below) consistently regardless of isotopic content.

The liquid DUF6 phase and gas (vapor) phase are in equilibrium at autoclave operating

temperatures. The gas (vapor) phase is transferred from the cylinder to the process through a

pigtail attached to the autoclave feed manifold with the DUF6 cylinder valve at the 12:00 o'clock

position.

Sold

Autoclave Operating

Pressure Range 67.7-77.3

psio @ 220-230 F

Liquid

Vaporize - Soiiy •

H

CL

100-

10':

0.1

, - Cond

Ise

.4

/

Autoclove

Atmospheric Operating

Pressure Temperature

Feed Range

220-230 F

Sublime

Desubilmo Gas

ir

O 25 50 75 100 125 150 175 200 225 250 2,75

Temperature (OF) FtA8801

Svrntc: DOEIEIS 2011

UF6 Phase Diagram

The IIFP Facility maximum quantity of liquid DUF6 will be found in autoclaves at operating

temperature. The maximum amount of liquid DUF6 expected to be in components during

operations is approximately 56,000 pounds or about two full DUF6 cylinders at operating
General Information

temperatures and is contained within the autoclaves. All autoclaves are housed in the DUF6

Autoclave Building.

License Documentation Impact: Paragraph one (paragraph one becomes paragraphs one, two

and three, following paragraphs will shift down accordingly) and former paragraph two of

Section 2.4.1 of the IIFP Integrated Safety Analysis Summary will be revised to read as follows:

2.4.1 DUF6 Autoclave Building

The DUF6 Autoclave Building is one level and includes a large overhead area to accommodate a

bridge crane. The building contains two containment-type autoclaves that use controlled steam to

safely vaporize the-solid-depleted UF6 for feeding to the DUF4 !!process Building. As steam is

admitted to the autoclave containing a cylinder with solid contents, the cylinder temperature rises.

DUF6 solid begins to vaporize and the vapor pressure in the cylinder increases until the solidliquid-vapor triple point is reached at about 22 pound per square inch absolute (psia). At the triple

point the solid begins to melt forming liquid in addition to the solid and vapor physical states.

There is essentially no further increase in pressure or temperature of the DUF6 in the cylinder until

the solid DIJF6 is melted to liquid, i.e., virtually all of the heat absorbed by the cylinder contents is

used to melt the DUF6 solid. After the solid is melted, the continuation of heating evaporates

liquid DUF6 and increases both the temperature and pressure in the cylinder along the UF6 vapor

pressure curve. When the DUF6 in the cylinder reaches the temperature of the steam in the

autoclave, there is no further increase in either temperature or pressure. When the cylinder reaches

the desired operating (feed) pressure, the cylinder and feed header piping valves are opened to

provide feed to the DUF4 reaction vessel. The liquid DUF6 phase and vapor phase are in

equilibrium at autoclave operating temperature (typically 220°F-230°F with a maximum shutoff

at 235°F) refer to Figure 3-1. The vapor is transferred to the process through a pigtail attached to

the autoclave feed manifold with the DUF6 cylinder valve at the 12:00 o'clock position. Further

discussion of vaporizing and feeding DUF6 is provided in Section 3.1.2.3 of the IIFP ISA

Summary. Safety controls relative to steam, pressure, and temperature for the autoclave system

that are Items Relied on For Safety (IROFS) are identified in Table 6-1 of the ISA Summary.

The IIFP Facility maximum quantity of liquid DUF6 will be found in the cylinders inside the

containment-type autoclaves at operating temperature. The maximum liquid DUF6 in inventory

for the IIFP at any one time for the IIFP Facility being licensed is approximately 56,000 pounds

or about two full DUF6 cylinders at operating temperatures.

Also included are two cold boxes cooled by refrigeration systems and sized to contain one 48Ytype cylinder each. One cold box is used to collect DUF6 cylinder heels after cylinders have been

fed out to the DUF4 process. The other cold box is the receiving vessel for the purge and

evacuation system that serves the DUF4 process.

Two rail mounted cylinder carts and weigh scales are provided in the autoclave area. One cart and

scale are located between the two autoclaves, and the other cart and scale are located between the

cold boxes. An overhead bridge crane is installed to hoist the DUF6 cylinders into and out of the

autoclaves and hot-cold boxes. The crane path is defined to permit lateral movement without

traveling above an autoclave or cold box containing a DUF6 cylinder.

Motor Control Center (MCC) and instrumentation equipment rooms are located in the east end of

the DUF6 Autoclave Building on the first floor.
General Information

Just west of the DUF6 Autoclave Building, a reinforced concrete pad is installed as a staging area

for DUF6 cylinders. This pad is located at the entrance doors to the DUF6 Autoclave Building to

provide for staging of both empty and full cylinders by the cylinder hauler to and from the

outdoor cylinder storage pad. Protective anchored concrete filled pipe bollards are installed

around the staging area for protection of DUF6 cylinders from vehicular traffic.
General Information

GI-7

C. Each 48Y cylinder can contain as much as 22 kg (IAEA-TECDOC-750 "Interim guidance

for the safe transport of reprocessed uranium, "pg 55) of heal. Address whether Technetium-99

and transuranics will be present in the cylinder tails from previous operations.

RESPONSE: The IIFP Facility in Hobbs, New Mexico receives depleted uranium

hexafluoride (DUF6) in a solid physical state contained in 14-ton type 48-Y (or 48-G) or I 0-ton

type 48-X cylinders typically owned by the supplier (IIFP toll de-conversion customer). HFP

will contract with commercial enrichment plant suppliers (customers) who have requirements

and licenses for their facilities to receive and process UF6 that has resulted from natural uranium

feed that at a minimum, meets or exceeds the definition of commercial natural UF6 for

enrichment with the requirements of American Society of Testing and Materials (ASTM)

C787-03, "Standard Specification for Uranium Hexafluoride for Enrichment" (ASTM, 2003).

Under the current IIFP License Application and commitments, it is highly unlikely that IIFP

would receive DUF6 cylinders that contain technetium (Tc) or transuranic (TRU). IIFP is not

requesting a possession license to receive DUF6 tails from facilities that enrich reprocessed

uranium. Also with the current license request and the technology described in the current

License Application, IIFP will not receive DUF6 tails (that contain technetium or transuranic

elements) from the Department of Energy (DOE) stockpile; for the reasons discussed below. IIFP

will assure these requirements are met through contractual arrangement, technical specifications,

terms and conditions of the contract and auditing of the enrichment facility license. If IFP in the

future has the opportunity for receiving and processing (de-conversion) of DOE stockpiled DUF6

and determines it to be feasible, then IIFP will prepare and submit a separate licensing

amendment.

It is important to understand, under the current licensing request, why receipt of Tc or TRU in

DUF6 by IIFP for de-conversion would be highly unlikely. The following summary of the

credible technical studies by government national laboratories and the DOE helps explain the

basis for this determination.

Studies conducted at Oak Ridge National Laboratory and results of a peer review by Lawrence

Livermore National Laboratory state that "the only plausible pathway for TRU and technetium to

end up in the depleted UF6 cylinders is by way of heels from prior use of the cylinders to store

reactor return feed." ("Strategy for Characterizing Transuranics and Technetium Contamination in

Depleted UF6 Cylinders", Oak Ridge National Laboratory, J.R. Hightower, et al, October 2000

and "A Peer Review of the Strategy for Characterizing Transuranics and Technetium

Contamination in Depleted Uranium Hexafluoride Tails Cylinder", Lawrence Livermore National

Laboratory, G.P. Brumbaurgh, et al, September 1, 2000).

The Department of Energy (DOE) in preparing their Environmental Impact Statement for the

DOE De-conversion facilities built at their Paducah, Kentucky and Portsmouth, Ohio sites,

commissioned the Oak Ridge National Laboratory and Lawrence Livermore Laboratory to

conduct the studies referenced above. DOE knew that because reprocessed uranium was enriched

in the early years of the government owned gaseous diffusion plants that some of the DOE

stockpile of depleted UF6 (DUF6) was possibly contaminated with small amounts of technetium

(Tc) and transuranic (TRU) elements plutonium (Pu), neptunium (Np) and americium (Am).

Appendix B of the Portsmouth DUF6 Conversion Final EIS (can be found on the DOE website)
General Information

thoroughly addresses and explains the basis for the Oak Ridge National Laboratory study and

conclusions and the extent of Tc and TRU contamination in DOE DUF6 cylinders.

The following excerpt is from the referenced DOE Portsmouth EIS:

"B. 1.3 Extent of Transuranic and Technetium Contamination in the DUF6 (referring to DOE)

Cylinders"

"Both the ORNL team and the peer review team reviewed the previous characterization studies

conducted on the tails cylinders. The ORNL team also interviewed some staff members who worked

at the Portsmouth and Paducah Gaseous Diffusion Plant sites when the recycled uranium was

being fed to the cascades. On the basis of those reviews and the characterization performed in the

period December 1999 to August 2000, it was concluded that the level of contamination in the tails

cylinders is very limited. The peer review team stated that the only plausible pathway for the TRU

and Tc to get into the DUF6 cylinders was by way of the heels from prior use of the cylinders to

store reactor return feed It was discovered during the investigations that some cylinders that were

used to store reprocessed UF6 were emptied into the cascades for reenriching the UF6. The same

cylinders were later filled with DUF6 without first being cleaned. The TRU contamination in the

feed cylinders consisted mainly of nonvolatile fluorides. Therefore, they were concentrated in the

heels of the feed cylinders. Any TRU isotopes that were carried into the cascades were thought to

have plated out and been captured in the cascades; thus, they never made it into the tails cylinders.

Similarly, nonvolatile compounds of Tc stayed in the heels, while the volatile components, because

of their low molecular weight compared with UF6, moved up the cascades and either were released

in the purge stream or stayed with the enriched product.

The number of reprocessed uranium feed cylinders that were later used to store DUF6 was not

known, but it was estimated to be in the hundreds (Hightower et al. 2000). This number represents

only a portion of the total of approximately 60,000 DUF6 cylinders that are used to store DOE's

inventory of DUF6 at the three storage sites - Portsmouth, Paducah, and East Tennessee

Technology Park.

It is believed that when the cylinders with contaminated heels were filled with DUF6, the liquid

DUF6 entering the cylinder stirred the heels and caused some fraction of the contamination to be

mixed with the DUF6. It is also possible that a smallfraction of the TRU that had been captured in

the cascades may have re-volatized during the cascade improvement projects and was carried into

some DUF6 cylinders. Therefore, TRU and Tc could be found both in the heels and in the bulk of a

small, but unknown, number of DUF6 cylinders in the DOE inventory."

Therefore, ILFP will require suppliers of cylinders that are used for depleted tails and received by

IIFP to preclude use of cylinders that in the past have contained reprocessed UF6, unless those

cylinders have been decontaminated and verification is made that such cylinders do not contain

Tc and TRU contaminants. Suppliers of DUF6 to IIFP will be required to provide written

evidence as to the origin of the cylinders that are filled with DUF6 and shipped to the IIFP

Facility. Also, periodic audits of suppliers will be performed to provide assurance that these

requirements are satisfied.

License Documentation Impact: Additional paragraphs will be added to Section 1.4 of the UFP

License Application (LA) to address the Tc and TRU question. Also, the first paragraph of

Section 1.3 and Table 1-4 of the License Application will be revised to add a small amount of

natural uranium for use in laboratory standards and methods. Additionally, in the next LA

revision, the new references shown in the text will be added to the respective LA chapter
General Information

reference page. The following revisions (changes in red text) will be made to Sections 1.3 and 1.4

of the LA. See also RALs GI-2 and GI-7D. The changes shown below are relevant to RAI GI-7C.

Other changes will be made in LA Sections 1.3 and 1.4 in response to RAIs ISA-14, MCA- 1 and

MCA-2.

1.3 Type, Quantity, and Form of Licensed Material

IIFP proposes to acquire, deliver, receive, possess, produce, use, transfer, and/or store source

material meeting the criteria of Source Material as described in 10 CFR 40.4, "Definitions"

(CFR, 2008a). Details of the source material are provided in Table 1-4, "Type, Quantity, and

Form of Licensed Source Material." Also it-it is anticipated that some license materials may be

used for instrument calibrations. As those needs are identified during the detailed design

phasegne, IIFP will prepare a license amendment as needed. A small amount of natural uranium

for use in laboratory standards and methods is included in the licensed material request.

Table 1-4 Type, Quantity, and Form of Licensed Source Material

following:

2006 New Mexico Commercial Building Code (adopts by

reference the 2006 International Building Code (IBC) with

amendments)

2006 New Mexico Energy Conservation Code (adopts by reference

the 2006 international energy conservation code (IECC) with

amendments)

2006 New Mexico Plumbing Code (adopts by reference the 2006

Uniform Plumbing Code (UPC) with amendments)

2006 New Mexico Mechanical Code (adopts by reference the 2006

Uniform Mechanical Code (UMC) with amendments)

*millicurRci) and • •4•ico Electrical Code (adopts by reference the 2008

national electrical code (NEC) with amendments)

1.Ueode (adopts by reference the

2007 national eFectrnca 4etv cone (NE,,•C with

The Source Material license for the material described in Table 1-4 of Section 1.3 above is

requested to be authorized for up to 40 years. IIFP plans to operate the facility indefinitely and

continue to renew the license as needed.

IIFP will not store or process Special Nuclear Material (SNM) at the FEP/DUP facility.

Therefore, no licenses and authorized uses for SNM are requested. SNM is defined in 10 CFR

70.4, "Definitions," (2008d).

IIFP will contract with commercial enrichment plant suppliers (customers) who have requirements

and licenses for their facilities to receive and process UF6 that has resulted from natural uranium

feed. Under the current IIFP License Application and commitments, it is highly unlikely that IIFP

would receive DUF6 cylinders that contain technetium (Tc) or transuranics (TRU). IIFP is not

requesting a possession license to receive DUF6 tails from facilities that enrich reprocessed

uranium. Also with the current license request and the technology described in the current License

Application, IIFP will not receive DUF6 cylinders from the Department of Energy (DOE)

stocknile (that contain technetium or transuranic elements) for reasons discussed in the
General Information

DOE "Portsmouth DUF6 Conversion Final EIS, Appendix B" (DOE, 2000). IIFP will assure these

requirements are met through contractual arrangement, technical specifications, terms and

conditions of the contract and auditing of the commercial enrichment facility license.

Studies conducted at Oak Ridge National Laboratory and results of a peer review by Lawrence

Livermore National Laboratory state that "the only plausible pathway for TRU and technetium to

end up in the depleted UF6 cylinders is by way of heels from prior use of the cylinders to store

reactor return feed." ("Strategy for Characterizing Transuranics and Technetium Contamination in

Depleted UF6 Cylinders", Oak Ridge National Laboratory, J.R. Hightower, et al, October 2000

and "A Peer Review of the Strategy for Characterizing Transuranics and Technetium

Contamination in Depleted Uranium Hexafluoride Tails Cylinder", Lawrence Livermore National

Laboratory, G.P. Brumbaurgh, et al, September 1. 2000).

Therefore, IIFP will require suppliers of cylinders that are used for depleted tails and received by

IIFP to preclude use of cylinders that in the past have contained reprocessed UF6, unless those

cylinders have been decontaminated and verification is made that such cylinders do not contain

Tc and TRU contaminants. Suppliers of DUF6 to IIFP will be required to provide written

evidence as to the origin of the cylinders that are filled with DUF6 and shipped to the IIFP

Facility. Also, periodic audits of suppliers will be performed to provide assurance that these

requirements are satisfied.

License Documentation Impact (1): The commitment by IIFP not to receive DUF6 cylinders

(that contain technetium or transuranics) from the Department of Energy stockpile under this

License Application is provided at the end of former paragraph two - new paragraph 8 as part of

the revised Section 3.1.2.2 in the IIFP ISA Summary. Changes shown below are relevant to RAI

GI-7C (see also RAI ISA-14). Other changes will be made in ISA Section 3.1.2.2 relative to the

RAI ISA-16 response.

The type 48-G cylinders have been aret'ypieally used by some enrichment facilities and the

Department of Energy for on-site storage of DUF6 and btA-have been utilized fEw at times by the

for transport of normal or depleted UF6. by the Department of Energy. Under the current IIFP

license request, cylinders of DUF6 (that contain technetium or transuranic elements) from the

U.S. Department of Energy stockpile will not be received by IIFP.

License Documentation Impact (2): To clarify that IIFP will use type 48-Y, type 48-G and type

48-X cylinders former paragraphs one through three will be revised in ISA Section 3.1.2.2.

Changes shown below are relevant to RAI G17-C with former paragraphs one and two becoming

new paragraphs 1, 6,7and 8 and paragraph three being deleted in its entirety from Section 3.1.2.2

in the IIFP ISA Summary. Other changes will be made in ISA Section 3.1.2.2 relative to the RAI

ISA- 16 response.

3.1.2.2 Receipt of Depleted Uranium Hexafluoride (DUF6)

The IIFP Ffacility in Hobbs, New Mexico receives DUF6 materials in a solid physical state,

typically contained in 14-ton type 48-Y (or 48-G) or in 10-ton type 48-X cylinders owned by the

supplier (the HFP de-conversion customer). IIFP will follow the "American National Standard for

Nuclear Materials-Uranium Hexafluoride-Packaging for Transport". ANSI N 14.1-2001 relative to

UF6 cylinders. A discussion follows about the maximum allowable working pressure and margins

of safety for the UF6 cylinders to be used in the I1FP mrocess.
General Information

DUFT-hese cylinders are built to American Natifial Standards Institute (ANSI) standards (ANSI,

200 1)- antd are transported by truck trailers that are Department of Transportation (DOT) approved.

The type 48-Y and type 48-X cylinders are approved for multi-shipments, provided the ANSI

N 14.1-2001 standards&,(ANSI, 2001) which includes a 5-year hydrostatic test requirement, are

met. Empty cylinders are returned to the supplier/customer following de-conversion.

The type 48-G cylinders have been are-typieally used by some enrichment facilities and the

Department of Energy for on-site storage of DUF6 and bta-have been utilized fef at times by the

for transport of normal or depleted UF6.by the Department of Energy.Under the current IIFP

license request, cylinders of DUF6 (that contain technetium or transuranic elements) from the

U.S. Department of Energy stockpile will not be received by IIFP.

Shipment of the type 48-G cylinders to the IIFP Ffacility will may require the supplier/customer

to obtain a DOT Speei•l-Pe'mit-"competent authority certification" for shipping DUF6 in this type

cylinder. The type 48-G cylinders if shipped to UFP would be are-a one-time use cylinder.

Disposition of the empty cylinder would require the complete removal of DUF6. One option under

consideration would be to qualify the emptiedy 48-Y-G cylinders as Industrial Packages (IP) and

utilize them as a depleted uranium DU oxide transport and disposal container.

Upon receipt, full caylinderS of DUF6-are v'iSually inSPected fer damage and sur~'eyed for- radiation

and removable conltamfinationl. Documents thAt contain informffation regar-ding eylinderidetifcatonweight, and uranium assay thaft accompany the shipment afe rL ewed anid verified

.f.- .eeei.ey. Uranium assay is qualitatively v.erified by performing a n,,n destructive gamma

su•.e•y mea.Suremf.iet. Onaceaccepted for reeipt, the cylinders are unloaded using the fadility

caylinder- hauler vehicle and place rmea-teFl no U6ClnerSseae..ad

until it is sehedulcd for- feed to the de cnerso arcss.7
General Information

GI-7

D. Table 1-4 lists uranyl fluoride (UO2F2) as a chemical form for the process. In response to

the RAIprovide a description of where this chemical form occurs in the process and whether or

not it is described in Chapter 1. Provide a description in the LA of the quantity and conditions

which result in production of U02F2 in the licensed operation. (Note: U02F2 is mentioned as

occurring in air effluents, but not as a part of the process.) Clarify whether U02F2 is actually

part of the process or incidental due to reaction with moisture in the air. Since U02F2 is soluble,

indicate the quantity of U02F2 produced, the possible exposure to staff, and precautions

implemented to prevent inadvertent exposure.

RESPONSE: DUO2F2 is formed by the reaction of DUF6 and moisture. Small amounts of

DUO2F2 that are formed in the process would only be incidental to the process. Equipment and

piping that contain DUF6 are evacuated and purged using the DUF4 Process Building Purge and

Evacuation System prior to opening for maintenance to minimize the potential for DUO2F2

formation. Workers wear protective respiratory equipment and clothing per Radiological

Procedures and Permits to prevent exposure to any trace or small amounts of residual DUO2F2.

License Documentation Impact: In the IIFP LA, Section 1.3, remove U02F2 from Table 1-4

(See also RAI GI-7C) owing to it being incidental to the process only. The changes shown below

are relevant to RAI GI-7D. Other changes will be made in LA Sections 1.3 in response to RAI

MCA-1, MCA-2 and ISA-14.

Table 1-4 Type, Quantity, and Form of Licensed Source Material

following:

2006 New Mexico Commercial Building Code (adopts by

reference the 2006 International Building Code (IBC) with

amendments)

2006 New Mexico Energy Conservation Code (adopts by reference

the 2006 international energy conservation code (IECC) with

amendments)

2006 New Mexico Plumbing Code (adopts by reference the 2006

Uniform Plumbing Code (UPC) with amendments)

2006 New Mexico Mechanical Code (adopts by reference the 2006

Uniform Mechanical Code (UMC) with amendments)

*millicu&&(8 Ci) and ne ico Electrical Code (adopts by reference the 2008

national electrical code (NEC) with amendments)

2007 New Mexico Electrical Safety Code (adopts by reference the

2007 national electrical ;afetv code (NFSCI with
General Information

GI-8 Sections 1.1.1 and 1.1.2 contain site maps and a description of the site layout. The application

distinguishes between a 40-acre plot and a 640-acre plot, but does not make a clear distinction between the

site boundary, controlled area, and restricted area. Consistent with the requirements in 20.1003, 70.61(f)

and the acceptance criterion in NUREG-1520, Section 1.3.4.3(1), provide the following information:

In the LA and other licensing documents, define what part of the International Isotopes Fluorine

Products (IIFP) will be the controlled area, e.g., 40-acre plot, in accordance with the definitions

in 20.1003 "Controlled area." Clarify in the application whether the 640-acres, excluding the

40-acre plot, represent a buffer zone between the site boundary and the controlled area. Add a

paragraph to the LA and other licensing documents, as appropriate, describing in general terms

the controlled area and access controls. The ISA Summary in particular should contain

information on the controlled area and boundary definitions [70.61(t)], including information on

whether the 640-acres will be fenced and marked and information on whether the controlled area

entrance will have access controls such as gates or security checkpoints.

RESPONSE: The UFP Facility property boundary is the 640- acres. The property boundary

will not be fenced. The facility site "Controlled Area" will be within the approximately 40-acre

perimeter fence but consists of areas that are not within Restricted Areas. The "Controlled Area"

will be marked at the perimeter fence and will have access controls, gates and security

checkpoints. Restricted Areas will be within the perimeter fence and will be further limited from

access for the purpose of protecting individuals against undue risks from exposure to radiation

and radioactive materials.

The same added definitions and descriptive information being placed in the LA (as below), will

also be incorporated into Section 2 of the ISA "Facility Description" in the next revision of the

license application documents.

License Documentation Impact: New paragraphs will be inserted between exiting paragraphs 1

and 2 in Section 1.1.2 of the UIP License Application, "General Information" (see also RAI GI6B). The changes shown below are relevant to RAI GI-8. Other changes will be made to LA

Section 1.1.2 in response to RAI SS-8.

1.1.2 Facility Description

The facility and infrastructure are typical of specialty chemical and industrial facilities. Buildings,

in addition to the process buildings, are included for administration, laboratory, maintenance shop,

stores inventories, security checkpoints, utilities and powerhouse, and warehousing. Figure 1-5

shows the facility site plan and layout of the buildings, roads and major infrastructure.

The Site Boundary and Unrestricted Area are defined below:

* The IIFP Lea County, New Mexico property boundary is approximately 640- acres.

The facility site is approximately 40-acres that are fenced within the 640-acre property

boundary. The remainder of the property boundary is not fenced, but is a buffer zone around

the 40-acre facility site. The property ownership of the buffer zone prevents other industries

or the public from establishing extended or permanent occupancy close to the 40-acre facility

site.
General Information

NRC regulation 10 CFR 20.1003 defines an unrestricted area as an area, access to

which is neither limited nor controlled by the licensee. The area adjacent to the 40-acre

facility site and outside the fenced area where the IIFP does not normally exercise access

control is an Unrestricted Area. This area can be accessed by members of the public,

indigenous wildlife, or by facility personnel. The Unrestricted Area is governed by the limits

in 10 CFR 20.1301. The total effective dose equivalent to individual members of the public

from the licensed operation may not exceed I milli-Sievert (mSv) or 100 millirem (mrem) in

a year (exclusive of background radiation). The dose in any Unrestricted Area from external

sources may not exceed 0.02 mSv (2 mrem) in any one hour. In addition to the NRC limit,

the Environmental Protection Agency, in 40 CFR 190, imposes annual dose equivalent limits

of 0.25 mSv (25 mrem) to the whole body, 0.75 mSv (75 mrem) to the thyroid, and 0.25 mSv

(25 mrem) to any other organ of any member of the public as the result of exposures to

planned discharges of radioactive materials to the general environment from uranium fuel

cycle operations and to radiation from these operations.

The Controlled and Restricted Areas are defined as below:

0 In 10 CFR 20.1003, the NRC defines a "Controlled Area" as an area, outside of a

Restricted Area but inside the site boundary, access to which can be limited by the licensee

for any reason. The NRC defines a restricted area as an area, access to which is limited by the

licensee for the purpose of protecting individuals against undue risks from exposure to

radiation and radioactive materials.

0 The IIFP Facility site Controlled Area is within the approximately 40-acre perimeter

fence but consists of area that is not within Restricted Areas. The Controlled Area is marked

at the perimeter fence and has access controls, gates and security checkpoints. The area of the

plant within the perimeter fence but outside any Restricted Area is part of the Controlled

Area. Facility employees and contractors have authorized access to the Controlled Area based

on specific applicable pre-authorization procedures and training.

0 Due to the presence of the owner controlled area fence, members of the public and

site visitors do not have direct access to this Controlled Area of the site and must be processed

by security and authorized to enter the site. Training for access to a Controlled Area is

provided commensurate with the radiological hazard. Site visitors may include delivery

people, tour guests and service personnel who are temporary, transient occupants of the

Controlled Area. Area monitoring demonstrates compliance with public exposure limits for

such visitors.

0 Examples of Restricted Areas include staging/storage areas for DUF6, DUF4 and

depleted uranium oxide, and the DUF4 Process Building. Personnel who have not been trained

in radiation protection procedures are not allowed to access a Restricted Area without escort

by trained personnel.

0 All personnel are required to monitor themselves prior to exiting Restricted Areas that

have the potential for contamination, using monitoring instruments that detect contamination.

• Access control to Restricted Areas and some of the type of areas that may exist within

Restricted Areas are discussed in the IIFP License Application Section 4.7.15, "Access

Control." These areas may be temporary or permanent. The areas are posted to inform

workers of the potential hazard in the area and to help prevent the spread of contamination.

These areas are conspicuously posted in accordance with the requirements of 10 CFR

20.1902.
General Information

The 40-acre facility site is surrounded by security fence with a surveillance road just inside the

fence. Pole mounted security lighting is installed around the perimeter of the security fence.

The entrance to the facility is from the west via a paved road (approximately 3/4 mile) that

intersects with NM 483. The road connects with the plant road system at the main gate and guard

station.
General Information

GI-9 Sections 1.6.2.1-1.6.2.3 provide information on the local demographics. Consistent with the

acceptance criteria in NUREG 1.3.4.3 (2), provide the following information:

A. LA Section 1.6.2.1 provides the population of Gaines and Andrews Counties.

However, the population of Lea County is not provided. Provide the latest census numbers for

the population ofLea County.

Response: The License Application Section, former 1.6.2.1 - new Section 1.7.2.1 (in response to

RAI RP-13) will be revised to include the population of Lea County along with the latest

population estimates for the three counties.

License Documentation Impact: The License Application former Section 1.6.2.1 - new Section

1.7.2.1 will be revised as follows:

1.6.2.1 Latest Census Rce 1tsl.7.2.1 Latest Census Results

According to the U. S. Census Bureau, the population of Lea County was 55,511 in 2000 with a

population density of 4.9 people per square kilometer. the-The population of Andrews County

was 13,004 in 2000 with a population density of 3.3 people per square kilometer (see IIFP ER).

Its population experienced a similar growth/decline pattern as that of Lea County. The population

of Gaines County in 2000 was 14,467 with a population density of 3.7 people per square

kilometer. Unlike in Andrews County, the population of Gaines County was relatively stable

during the 1990's. The total population of the three principal counties in the region of influence

was nearly 83,000 in 2000. The area did not experience the population increase that occurred in

other areas of New Mexico and Texas. The latest U.S. Census Bureau estimates for 2008 as

reported in the ER (IIFP, 2009b) were 59,155 for Lea County, 13,645 for Andrews County, and

15,081 for Gaines County.
General Information

GI-9

B. Section 1.6.2.1 provides the population density per kilometer for Andrews County.

For consistency, provide the population density for Gaines and Lea Counties also.

RESPONSE: Former Section 1.6.2.1 - new 1.7.2.1 (in response to RAI RP-13) will be revised to

include the population density for Gaines and Lea Counties.

License Documentation Impact: Former Section 1.6.2.1 - new Section 1.7.2.1 of the License

Application will be revised as shown in the License Documentation Impact for RAI GI-9A.
General Information

GI-9

C. LA Section 1.6.2.3 contains information on schools. This information appears to have

discrepancies with the data in the ER in the first full paragraph above Table 3-52. Correct any

discrepancies and provide the location and capacity of the nearest hospitals. Provide a sentence

indicating where the nearest pre-schools, day cares, and nursing homes are located. (Note:

Some of this information exists in the ER. This information may be referenced rather than

repeated in the LA, if desired.)

Response: License Application former Section 1.6.2.3 - new Section 1.7.23 (in response to RAI

RP-13) will be revised to reflect the correct number of educational institutions in Hobbs, NM.

The section will also be revised to address nearest pre-schools, daycares, hospitals and nursing

homes.

License Documentation Impact: License Application, Revision A, Chapter 1, former Section

1.6.2.3 -new Section 1.7.2.3, paragraph one will be revised as follows and a new paragraph two

will be inserted and the former paragraph two will shift accordingly.

Urban development is relatively sparse in the vicinity of the pfese4-IIFP Ssite. The nearest city,

Hobbs, New Mexico, is approximately 22.5 m (14 mi) to the east. Within Hobbs, New Mexico,

several educational institutions are available for the education of personnel in the local

community. There are three colleges including a community vocational junior college, a high

school and an alternative high school, three junerF high-middle schools, and edeventwelve

elementary schools as well as two private schools.

There are two hospitals in Lea County, New Mexico. The Lea Regional Medical Center is located

in Hobbs, New Mexico. Lea Regional Medical Center is a 221 licensed-bed hospital that can

handle acute and stable chronic care patients. The Lea Regional Medical Center is 15.5 km (9.6

mi) directly east northeast from the site, or 31.4 (19.5 mi) from the site using NM 483, U.S. 62,

North Grimes Street and North Lovington Highway. In Lovington, New Mexico, Covenant

Medical Systems manages Nor-Lea Hospital, a full-service, 27-bed facility. The Nor-Lea Hospital

is 27.0 km (16.8 mi) north of the IIFP Site.

There are fourteen nursing homes or senior living facilities in Hobbs. There are 21 daycare

providers and preschool centers in Hobbs.

As mentioned above, there are no state or federal parks are located within five (5) miles of the

IIFP site.
General Information

GI-9

D. Emergency Plan, Section 3.0 lists four facilities within afive-mile radius. The LA

Section 1.6.2.4 only lists one of these facilities. Add the other three facilities listed in Emergency

Plan to the LA. In the LA, provide the average number of employees who work at these facilities

(for separate facilities and combined), and indicate how this number changes with each shift.

Response: Former Section 1.6.2.4 - new Section 1.7.2.4 (in response to RAI RP-13) of the

License Application will be revised to correct the name of the Xcel Energy Cunningham Station

and to add the three other facilities listed in the Emergency Plan. The average number of

employees who work at the facilities will be added as Table 1-5 to this section.

License Documentation Impact: Section 1.6.2.4- new Section 1.7.2.4, "Near-by Industrial

Facilities," of the License Application will be revised as follows:

Land around the pr-opese4-lIFP Ssite has been mostly developed by the oil and gas industry. T-he-

!one nefyiiutrial facility iz thc IN~ewv _Mlerco Power. anid Light Company plant on the west

boundary . Mexieo .ew Highway 483) of . the .FP prep.sed preperty line. Nearby industrial

facilities are the Xcel Energy Cunningham Station plant on the west boundary (New Mexico

Highway 483). approximately 1.6 km (1.0 mi) fromof the I1FP Site, the Xcel Energy Maddox

Station 3.5 km (2.2 mi) to the east, the Colorado Energy Hobbs Generating Station approximately

3.1 km (1.9 mi) east-northeast of the site, and the DCP Midstream Plant 5.8 km (3.6 mi) southeast

of the site. The average number of employees who work at these facilities are shown in Table 1.5.

Table 1.5 Nearby Industrial Facilities

following:

2006 New Mexico Commercial Building Code (adopts by

reference the 2006 International Building Code (IBC) with

amendments)

2006 New Mexico Energy Conservation Code (adopts by reference

the 2006 international energy conservation code (IECC) with

License DocumentatianIidpw*isFormer Section 1.6.2.5 - new Section 1.7.2.5, "Land Use

within a Five Mile Radius," will be revised as follows:

As mentioned above, the site is undeveloped and utilized for oil and gas wells. Several power

lines and underground power lines run generally east to west and several gas pipelines run north

and west as well as east to west.

Surrounding property consists of vacant land,.-d t-.h Ne....w Me•i•o POWer ad Light Com.pany

power- plant on th" wet boundary of . the .FP proposed preperty line, three power companies and

the gas processing plant mentioned above. Cattle grazing on nearby sites occur throughout the

year. Land around the p4'epsed-IIFP Ssite has been mostly developed by the oil and gas industry.

The nearest residence is situated west northwesteast of the site -42.6 km (41.6 mi) from the

north boundary.
General Information

GI-JO LA Section 1.6.3, ER Section 3.6, and ISA Summary Section 1.3 contain information on the

meteorology for the site. Some of this information contains minor typos or requires clarification.

Consistent with the requirements in NUREG-1520, Section 1.3.4.3(3), provide the following information:

A. Some of the temperatures in Table 1-6 of the LA, Table 3-17 of ERX and Table 1-2 of ISA

Summary are reported as positive when they should be negative. In addition, some of the

temperatures in Table 3-14 of the ER should have negatives. Review all the temperatures in all

the tables throughout the submittals and verify that they have the correct sign.

RESPONSE: IIFP concurs that some of the temperatures are incorrect as shown. The tables

listed will be corrected and other tables will be reviewed for similar errors.

License Documentation Impact: Temperatures in former Table 3-14 (new Table 3-17)of

Revision A of the ILFP Environmental Report will be revised as follows:

21.7 0C will be revised to -21.7 0C for January

18.9 'C will be revised to -18.9 0C for February

-17.2 'C will be revised to -18.3 'C for December

License Documentation Impact: Temperatures in former Table 3-17(new Table 3-20) of

Revision A of the IIFP Environmental Report will be revised as follows:

21.7 'C will be revised to -21.7 'C for January

23.9 'C will be revised to -23.9 'C for February

16.1 'C will be revised to -16.1 'C for December

License Documentation Impact: Measurements in former Table 3-18 (new Table 3-21) of

Revision A of the IIFP Environmental Report will be revised as follows:

.025 will be changed to 0.25 for mean snowfall for October

12.95 cm (5.1 in) will be changed to 11.93 cm (4.7 in) for the Annual mean snowfall.

License Documentation Impact: Former Table 1-5 - new Table 1-6 (in response to RAI GI9D)

of Revision A of the IIFP License Application will be deleted and replaced with revised ER

former Table 3-18 (new Table 3-21) above and be numbered as Table 1-6.

Temperatures in former Table 1-6 - new Table 1-7 (in response to RAI GI-9D) of Revision A of

the IIFP License Application will be revised as follows:

21.7 'C will be revised to -21.7 'C for January
General Information

23.9 'C will be revised to -23.9 'C for February

16.1 'C will be revised to -16.1 'C for December

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

Analysis Summary will be deleted and replaced with revised ER former Table 3-18 (new Table

321) above and be numbered as Table 1-1.

Temperatures in Table 1-2 of Revision A of the IIFP Integrated Safety Analysis Summary will be

revised as follows:

21.7 'C will be revised to -21.7 'C for January

23.9 'C will be revised to -23.9 'C for February

16.1 'C will be revised to -16.1 'C for December
General Information

GI-10

B. The design basis precipitation is stated at 3.5-4 inches for the 1 00-year timeframe in LA

Section 1.1.5.3 and ISA Summary Section 1.3.2.8. The design basis precipitation appears to be

based on the data in ER Table 3-21. Incorporate or reference this table in the LA and ISA

Summary. In addition, ER Sections 3.4.11.3 and 3.4.11.4, and LA Section 1.6. 3.3, and ISA

Summary Section 1.3.2.8 indicate that the IIFP is not within the 500-year floodplain. In response

to this RAI, provide the basis for this determination. Also, ifpossible, consistent with the

100-year data in ER Table 3-21, provide similar precipitation data for the 500-year flood.

RESPONSE: Former Table 3-21 - now Table 3-24 in the ER shows 100-year return period

one-hour point precipitation information from NOAA Precipitation Frequency Data Server for

three weather stations in the general vicinity of the H1FP Facility. Also, the coordinates for the

IIFP site were entered into the NOAA Precipitation Frequency Data Server and corresponding

estimates for that specific location were obtained. Based on this information, a 100-year one-hour

precipitation event of 4.0 inches was selected for stormwater sewer design. The selected

precipitation event is greater than the 90% confidence upper limit values for any of these four

locations. Table 3-24 will also be revised to include one-hour precipitation information for a 500

year return period.

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

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

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

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

performed using Department of Energy (DOE) documents DOE-STD- 1020-2002, DOE-STD1022-94 and DOE-STD-1023-95, and it was determined that a comprehensive flood hazard

assessment is not required. Preliminary screening indicates that flooding is not a design basis

event other than in consideration of stormwater runoff which is included in the detailed facility

design.

Sections 3.4.11.3 and 3.4.11.4 of the ER and section 1.6.3.3, subheading "Floods" of the LA will

be addressed under License Documentation Impact in response to question GI- 10 C below.

License Documentation Impact: Section 1.1.5.3, subheading "Storm Sewers" of Revision A of

the IIFP License Application will be revised as follows:

1.1.5.3 Sewer Systems and Collection Basins

Storm Sewers

The IIFP Ffacility storm sewer systems design assumes a 100-year return period sto"r Of 8.9 wcm (3.5 to 4 in) rain of 1 hu..r. du.tin for the Webbs, New Mexiee area one-hour

precipitation event of 4.0 inches. Information obtained from the NOAA Precipitation Frequency

Data Server is provided in Table 3-24 of the Environmental Report for three weather stations in

the Hobbs, NM area. These data show mean 100-year one-hour rainfalls of 3.33 to 3.40 inches

with a maximum 90% upper confidence limit of 3.77 inches. Preliminary engineering of the

drainage system size and layout was done to estimate costs and determine requirements and
General Information

information for additional detailed design later. The early design encompasses an area of the

facility that includes the process buildings, auxiliary buildings, pads, roads, parking lot and the

water treatment and electrical substation areas in the back acreage of the facility. All the storm

sewer systems are inside the inner fenced area and collect rainwater runoff from an estimated

2025 acres including roadways, building roofs and pads.

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

RAls GI-IOD and SS-2) of Revision A of the IIFP Integrated Safety Analysis Summary will be

deleted and replaced with the following:

.3.2.81.3.2.6 Floods

The HIFP site does net fWl within 100 year- or- 500 year floodplains (IIFP, 2009). The site is

l•cated in a semi arid l.catien with limfited bdies f watf-er. The site is located in an area which

has a semi-arid climate with an average rainfall of 12 to slightly less than 16 inches per year as

recorded for Hobbs city (15.93 in/yr), Hobbs airport (12.35 in/yr), Pearl, NM (13.91 in/yr), and

Roswell, NM (14.66 inL/yr). This information was obtained from the Western Regional Climate

Center website. The nearest river is the Pecos River to the southwest which is approximately 50

miles or greater from the site. Point precipitation information for coordinates of the site location

(32.716 degrees latitude, -103.33 degrees longitude) as presented in the NOAA Precipitation

Frequency Data Server are 3.40 in. (with 90% CLs of 2.98 and 3.77) for a one-hour rain with an

Average Recurrence Interval (ARI) of 100 yr. For a 500 year ARI. the values are 4.33 in. (with

90% CLs of 3.74and 4.82). The same type of data for three weather stations in and around Hobbs,

NM is very similar and is displayed in Table 3-24 of the ER. According to the Federal Emergency

Management Agency (FEMA) Mapping Information Platform, the site lies in a FEMA Flood

Zone D which means that floodplain mapping has not been performed for this area.

Since there are no significant bodies of water or rivers within several miles of the site, it is

expected that any flooding would be due to extreme short-term precipitation which could result in

flash flooding. According to information obtained from NOAA National Climate Data Center

(NCDC) Storm Events, there have been 68 flood events in Lea County, New Mexico between

1/1/1 950 and 2/28/2010, an average of approximately one per year. Of these 68 events, there were

no deaths reported, and property damage was reported for only 14 of the events, all of which

occurred in the cities and towns of Lea County. Twenty-nine of the 68 events were reported for

Hobbs which is located at an elevation from 125 to 170 feet lower than the site and approximately

11.4 miles to the east. The Hobbs airport is at an elevation of about 125 feet lower and some 6.9

miles southeast of the site, and it is also in FEMA Zone D and unmapped. The IIFP Site would be

expected to receive some drainage from highway 483 on the west and possibly from the north as

parts of these areas are at slightly higher elevations than the IIFP Facility location. However, site

topography would indicate that water would drain away from the site toward the east and south as

gradual elevation declines occur in those directions for several miles. While the area where the

IIFP Facility is located has not been mapped, the site does not lie within areas that have been

mapped and that lie within the 100-year floodplain in and around Hobbs, New Mexico according

to information provided in the FEMA Mapping Information Platform.

Guidelines in the following Department of Energy (DOE) documents were used to perform a

flood hazard assessment for the IIFP Facility near Hobbs, NM: DOE-STD-1 020-2002, DOESTD-1022-94 and DOE-STD-1023-95. Based on the information included herein and the

guidance provided in these documents, it was determined that a comprehensive flood hazard

assessment is not required. Preliminary screening indicates that flooding is not a design basis
General Information

event other than in consideration of storm water runoff which will be included in the detailed

facility design with an engineering margin for storm sewer loading.

Based upon the above precipitation data for the site and information presented in Table 3-24 of

the IIFP "Environmental Report" an estimate of a 4.0 inch one-hour rainfall was used for storm

sewer design. The facility is designed to prevent flooding from extreme precipitation of short

duration. Structures containing SSCs are constructed above grade level and above the level of

plant roadways. They are curbed to prevent internal spills from leaving the structure, and this

curbing also serves as flood barriers for those structures. The terrain is contoured around the site

to improve drainage away from or diversion around the facility. In this way, the structures are

physically removed from potential sources of flooding.

License Documentation Impact: Former Table 3-21 (new Table 3-24) in Section 3.6.1.3 of the

IIFP Environmental Report, Revision A will be revised to include 500 year return period data

with current updates for the 100-year data.

Table 341-24 Estimates of the 24-Hour 100-Year and 500-Year Rain Event in Hobbs, New

Mexico

following:

2006 New Mexico Commercial Building Code (adopts by

reference the 2006 International Building Code (IBC) with

amendments)

2006 New Mexico Energy Conservation Code (adopts by reference

the 2006 international energy conservation code (IECC) with

amendments)

2006 New Mexico Plumbing Code (adopts by reference the 2006

Uniform Plumbing Code (UPC) with amendments)

2006 New Mexico Mechanical Code (adopts by reference the 2006

Uniform Mechanical Code (UMC) with amendments)

2008 New Mexico Electrical Code (adopts by reference the 2008

national electrical code (NEC) with amendments)

Soura.QC, 296M0•1 W t*rA& 4f Code (adopts by reference the

Server '1 inch = 2.54 ce=10"iational electrical safety code (NESC) with

amendmentO'I

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

Analysis Summary (see also RAI SS-2) will be revised as follows:

The IIFP FEP/DUP Ssite is lceated eutside has not been mapped but does not lie within areas that

have been mapped and that are in the 100-year flood-plainm, in and around Hobbs. New Mexico

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

the IIFP flood hazard assessment is provided in Section 1.3.2.6 of the ISA. however, a flood of

any manitud. was c.nsider.ed cr.dibl during . the a..id.nt analysis perfeormled in the ISA.The

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

are were limited (due to no fissile material existing at the site). Thus, flood type accidents are not

a significant risk for plant operations.
General Information

GI-10

C. The basis quoted in ER Figure 3-2 7for IFP being outside the I 00-yearfloodplain is

based on data provided by the Economic Development Corporation (EDC) of Lea County, NM.

In response to this RAJ, provide a basis for the credibility of the information. Indicate if the

EDC is qualified to develop these reports, or specify that the EDC compiled the information from

nationally recognized sources. In addition, in the LA, ISA Summary, and ER9 provide a basis

for the statement that the IIFP is outside the 500-year flood plain.

RESPONSE: The FEMA Mapping Information Platform was used to determine that the area

where the IIFP site is located is in Zone D and has not been mapped. Mapping is performed on a

priority basis. Certain areas in general vicinity of the IIFP site have been mapped and those maps

may be seen at this same site. Areas of potential flooding are shown in and around Hobbs, NM. A

topographic view of the area indicates that the IIFP site is 125 to 170 feet above these locations.

The site is also approximately 125 feet higher than the Lea County Airport which is also in Zone

D and has not been mapped. Based on this information, it is safe to say that the site is not in areas

which have been mapped and lie within the 100-year floodplain (Zone A) in and around Hobbs,

New Mexico and is at a higher elevation than areas which have been mapped. FEMA is the source

of the EDC floodplain information as documented on the map provided to IIFP. The 500year

information is not shown either in the information provided by the EDC or on maps located using

the FEMA Mapping Information Platform. References to the 500-year floodplain have been

removed as appropriate.

License Documentation Impact: The source reference for the floodplain information shown in

Section 3.4.1. 1, Figure 3-27 of Revision A of the IIFP Environmental Report will be changed

from the EDC to include provider to EDC, FEMA and USGS.

Source: EDC4, 2008, Drawing provided by Gordon Environmental Inc. to EDC of Lea County, Floodplain information

FEMA and Topographical Information: U. S. Geological Survey.

License Documentation Impact: Section 3.4.11.3 of Revision A of the IIFP Environmental

Report will be deleted and replaced with the following:

3.4.11.3 Floodplain Description/Flood Control Measures

Site grade is fiabove tha eleVatiOR Ofthe 100 year and the 500 year flod elevatiens. See Figurld3

27, "Waterourrses, Floodplains, and Playas Map" fcr location of FEMA Zone A (afeas inundted

induring yeaf 1000 fld event) nc.theast of the Site or northWeSt Of Hobbs, New Memacp around the

Hoebbs Industr ial Air Park. The IIFP Site StorM Systemf is designed to accommodate a 100 yearr-etm period pr-ecipitatien event. No additional flood conitrol measures arcO proposed for- the IIFPSiegade is significantly above areas which have been mapped and ar in the 100-year floodplain

in and around Hobbs, New Mexico according to information provided in the FEMA Mapping

Information Platform. These mapped areas and topographical data are displayed in Section

3.4. 1. 1. Figure 3-27. "Watercourses, Floodplains. and Playas Map" for location of FEMA Zone A

(areas inundated during 1 00-year flood event). This map was provided to the Economic

Development Council of Lea County by Gordon Environmental Inc. who references FEMA as the

source for floodplain information and the U. S. Geological Survey (USGS) as the source for

tonogranhical information.
General Information

The IIFP site stormwater system is designed to accommodate a 100-year return period

precipitation event. An estimate of a 4.0 inch one-hour rainfall was used for storm sewer design.

See Section 1.3.2.6 "Floods" of the ISA. The facility is designed to prevent flooding from

extreme precipitation of short duration. Structures containing SSCs are constructed above grade

level and above the level of plant roadways. They are curbed to prevent internal spills from

leaving the structure, and this curbing also serves as flood barriers for those structures. The site

terrain is contoured to improve drainage away from or diversion around the facility. In this way,

the structures are physically removed from potential sources of flooding.

License Documentation Impact: Section 3.4.11.4 of Revision A of the IIFP Environmental

Report will be deleted and replaced with the following:

3.4.11.4 Design-Basis Flood Elevation

Site grade is above the 500 year- flood elevations.

The IIFP site has not been mapped but does not lie within areas which have been mapped and are

in the 100-year floodplain in and around Hobbs, New Mexico according to information provided

in the FEMA Mapping Information Platform. Preliminary screening indicates that flooding is not

a design basis event other than in consideration of stormwater runoff which is included in the

detailed facility design. See section 1.3.2.6, "Floods" of the ISA.

License Documentation Impact: Former Section 1.6.3.3 - new Section 1.7.3.3, subheading

"Floods" (in response to RAI RP-13) of Revision A of the IIFP License Application Section will

be deleted and replaced with the following:

Floods

The IIFP site does ncet fall within 100 year OF 500 year- fleedplains (see HFP ER). The site is

located in a semi arid location with limited bodies of water.

The IIFP Site has not been mapped but does not lie within areas which have been mapped and are

in the 100-year floodplain in and around Hobbs, New Mexico according to information provided

in the FEMA Mapping Information Platform. Preliminary screening indicates that flooding is not

a design basis event other than in consideration of stormwater runoff which is included in the

detailed facility design. See section 1.3.2.6 "Floods" of the ISA.

License Documentation Impact: Former Section 1.6.3.3 - new Section 1.7.3.3, insert a

new subheading "Snow" and text in HIFP License Application Section to read as follows:

Snow

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

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

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

also occurred in November.

2

The design-basis ground snow load for I1FP structurs will be 10 lb/ft as specified in ASCE 7

05. There is also a rain-on-snow surcharge of 5 lb/ft recommended by this standard which will
General Information

have to be considered. Since IIFP is using DOE Performance Category 3 criteria for its risk

assessment of process buildings, an importance factor of 1.2 will be used to calculate the final

design-basis snow load (ASCE. 2006). (DOE. 2002).
General Information

GI-10

D. For the design basis wind strength in the ISA Summary, provide a return year period

and maximum wind speed for both intermediated term (100-500 years) and long term (>1000

years). Specify the basis for both the maximum wind speed and return year period for the

information, e.g., a site-specific study, national weather service, etc. In addition, Table 3-22 in

the ER has a very limited timeframe (82-97). Justify that this limited timeframe is adequate for

the design basis wind. Demonstrate that the wind assessments were from a recognized source

and the method used for analyzing high-wind hazard is a commonly used and accepted method.

RESPONSE: The determination of design basis wind speed has been reevaluated using a

different methodology and under a different set of criteria than those addressed in Question GI-10

D. A discussion of that methodology is provided in this response.

The evaluation of tornadoes and straight winds was made based on NUREG/CR-4461, Revision 2

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

provides calculations based upon 46,800 tornado segments occurring from January 1, 1950

through August 2003 of which more than 39,600 had sufficient information on location, intensity,

length, and width to be used in the analysis included in this report. NUREG/CR-4461, Revision I

had been published in April 2005. The National Weather Service changed from using the Fujita

Scale to the Enhanced Fujita Scale in February 2007. Revision 2 incorporates the Enhanced Fujita

Scale in its methodology and calculations. Specifically, Chapter 5 of the NUREG has been revised

to show lxlO, lxl0, and lxlO" probability design wind speeds (i.e., probability of exceeding

that wind speed in one year) for the contiguous United States estimated using the above database

and the Enhanced Fujita Scale. (NCDC, 2010b)

The two-degree box where the IIFP site is located is in Region 2. While the two-degree and

four-degree boxes are considered to be more reliable since they contain data for more events, the

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

provide accurate calculations. Instructions for using the NUREG Appendix C, Results for

one-degree boxes state that the data set should contain a minimum of 10 events with 20 or more

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

0 0

the 32 /103 gridline. Of these, 56 were used in the calculations. The four-degree box uses data

from 364 events of the 435 events observed.

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

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

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

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

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

curve at approximately a I x I07year return period or a probability of exceeding of 1 x 107.

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

-4

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

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

10000000

RETURN

PERIOD

(YRS)

1000000

100000 -

10000 -

1000

100

10

1

traight Gust Wind Speed vs Tornado Wind for 1, 2, & 4 Degree Boxes

40BOX,

S11RA1GHT43USTWI[NDS

0 50 100 150

WIND SPEED (MPH)

200 250 300

Legend: 4 Box -Red; 1 Box -Green; 2 Box -Blue

Note: See the discussion of straight winds below for the derivation of basic gust wind speeds

versus probability used in the plots discussed above.

Design wind speeds for all buildings and structures that do not contain licensed material or for

buildings and structures containing chemicals or processes that do not affect licensed material

will be determined in accordance with the applicable model building codes (New Mexico

Commercial Building Code (NMCBC, 2006) and American Society of Civil Engineers (ASCE

705) or latest editions adopted by the State of New Mexico at time of design). Specifically,

these buildings and structures will be designed for a minimum straight gust wind speed of 90

mph.

Design wind speeds for all buildings and structures containing licensed material or buildings and

structures containing chemicals or processes affecting licensed material are determined in

accordance with NUREG- 1520, Revision 1 (Appendix D and Annex to Appendix D) by reference

to DOE-STD-1020-2002.

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

exposure and for tornadoes at 1Oim (33 fi) above the ground versus "Performance Category and

Annual Probability of Exceedance" for 23 DOE sites across the United States.

By definition, DOE Performance Category 3 (PC-3) buildings and other structures are buildings

and other common structures not classified as PC-4 structures which contain sufficient quantities

of toxic or explosive substances to be dangerous to the public if released. PC-4 SSCs are

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

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

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

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

material or process buildings containing processes or materials potentially affecting licensed

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

defined in ASCE 7-05 Table 1-4(DOE G 420.1-2, 3/28/00).

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

speeds for straight winds and for tornadoes for several DOE sites for Performance Categories

PC I thru PC-4 structures. DOE Performance Categories are used below for illustrative purposes

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

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

-2

10 probability of exceeding the speed) are consistent with the USGS wind speed maps adopted

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

design wind speed for PC-I structures per the USGS wind speed maps is 90 mph (2 x10 2), the

-2

design wind speed per DOE-STD-1020-2002, Table 3-2 for PC-2 structures is 96 mph (1 x 10 ),

-3 -4

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

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

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

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

-4

an occurrence probability of lxlO (135 mph), or 2) design the facility to withstand a straight-line

-3

wind load of lxI 0 (117 mph), but incorporate factors of safety such that the Ratio of Hazard to

Performance Probability is equal to or greater than 10 using the methodology in Appendix D of

DOE-STD-1020-2002. IIFP decided to use the first approach for meeting the performance criteria

by designing PC-3 structures to withstand a 135 mph straight-line wind. At this design wind speed

and probability of exceeding the speed, no credit is taken for the Ratio of Hazard to Performance

Probability allowed in DOE-STD-1020-2002, Appendix D, Table D-2, even though conservatism

will be achieved in the design due to factors of safety inherent in the design process and in

material allowable stress specifications. From the evaluation that was performed, it was

determined that the likelihood of a tornado generating winds at 135 mph was much lower for this

-5

area with a probability of less than 10 . Also, according to Appendix A of NUREG/CR-4461,

Rev.2, the .&vo~degree box which contains the IJFP site has a tornado strike probability of 8.444 x

speed at the 10 probability level represents a conservative approach with respect to wind speed.

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

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

in 10 CFR part 70.61, "Performance Requirements," are treated for the purposes of evaluating

risks as PC-3 structures per the Natural Phenomena Hazard Evaluation methods prescribed in

DOE-STD-1020-2002. As mentioned above, those structures will meet the performance category

of 1 x 104, which is designed to withstand a I x 10 probability per year occurrence straight-line

wind event. Hence, based on the order of magnitude scale for determining event likelihood using

the ISA methodology in NUREG-1520, Rev. 1, the collapse or loss of the building integrity is

-5

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

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

risk without the need to further reduce the likelihood of hazardous release or mitigate its

consequences. Therefore, designing the PC-3 facilities to withstand straight-line wind events with

an occurrence frequency of 1 x 10 per year meets ISA risk acceptance levels regardless of the
General Information

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

hazardous release.

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

Analysis Summary (see also RAI SS-2) will be deleted and replaced with the following:

1.3.2.3 Extreme Winds

Winid spOEeds over the State of New Meyico are usually mRoderaite, although r-elatively strong

winds often accompany eccasional frontal aetivity during late winter and spring Menths and

sometimnes occr.fjust in advance Of thunderstOrmsl. Frontal winds may exeeed 30 mile/ir. for

sever-a! hours and r-each peak speeds of mor-e than 50 mile/hr

This section describes the basis for evaluation of wind loading on the structures at the I1FP

Facility in Lea County, New Mexico. Three sources of wind loading are evaluated; wind loading

from a hurricane, straight wind loading and wind loading from a tornado.

Hurricanes

The IIFP Facility site is located in the extreme southeastern portion of New Mexico and over 500

miles inland from the Gulf of Mexico. Hurricane winds dissipate over Louisiana and Texas

enough to prevent a wind damage threat to the IIFP Facility site as evidenced by the following

information provided by NOAA, National Climatic Data Center (NCDC).

According to NOAA/ NCDC, of the 155 thunderstorm events recorded between 01/01/59 and

02/28/10, the maximum thunderstorm wind speed recorded for Lea County was 80 knots (92.1

mph) on 07/14/89. Some of these thunderstorm events likely would have been the result of

dissipated hurricanes. (NCDC, 2010a)

Tornadoes and Straight Winds

NOAA NCDC Storm Events includes information for 527 tornado events reported for the state of

New Mexico for the period 1950-2010 for an average of 8.78 events per year. Lea County

reported 92 tornadoes for the same period for an average of 1.53 tornadoes per year. Of these 92

tornado events for Lea County between 01/01/50 and 01/31/10, 63 - FO, 20 - FI, 8 - F2, and oneF3 tornadoes were reported. During this same sixty-year period, no F4 or F5 tornadoes were

reported. (NCDC, 2010a)

The evaluation of tornadoes and straight winds was made based on NUREG/CR-4461, Revision 2

(February, 2007) including data in Appendices A, B and C of the NUREG, DOE-1020-2002 and

DOE-STD-1022-2002 including Appendix D. It was determined from this evaluation that straight

gust wind speeds will be used as the design basis for buildings and structures at the IIFP Facility.

Design wind speeds for all buildings and structures that do not contain licensed material or for

buildings and structures containing chemicals or processes that do not affect licensed material will

be determined in accordance with the applicable model building codes (New Mexico Commercial

Building Code (NMCBC, 2006) and American Society of Civil Engineers (ASCE 705) or latest

editions adopted by the State of New Mexico at time of design). Specifically, these buildings and

structures will be designed for a minimum straight gust wind speed of 90 mph.
General Information

Design wind speeds for all buildings and structures containing licensed material or buildings and

structures containing chemicals or processes affecting licensed material are determined in

accordance with NUREG-1 520, Revision 1 and by reference to DOE-STD-1020-2002 which, in

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

at I Om (33 ft) above the ground versus "Performance Category and Annual Probability of

Exceedance" for 23 DOE sites across the United States.

By definition, DOE Performance Category 3 (PC-3) buildings and other structures are buildings

and other common structures not classified as PC-4 structures which contain sufficient quantities

of toxic or explosive substances to be dangerous to the public if released. PC-4 SSCs are

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

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

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

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

material or process buildings containing processes or materials potentially affecting licensed

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

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

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

straight winds and for tornadoes for several DOE sites for Performance Categories PC-I thru

-2

PC4 structures. The design wind speeds listed in Table 3-2 for PC-1 structures (2 x 10

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

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

design wind speed for PC-I structures per the USGS wind speed maps is 90 mph (2 x 10-2

), the

-2

design wind speed per Table 3-2 for PC-2 structures is 96 mph (lxlO ) for PC-3 structures is

117 mph (lxlO) and for PC-4 structures is 135 mph (lxlO).

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

-4 -4

to design for the facility to withstand a straight-line wind load that occurs at a lxlO . This lx 10

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

using a 135 mph straight wind gust at the lx 10 probability level where no credit is taken for the

Ratio of Hazard to Performance Probability allowed per Table D-2. Therefore, the IIFP design

basis wind speed is one order of magnitude more conservative than the design basis required by

DOE for PC-3 structures where a hazard probability of I x] 0" with a Ratio of Hazard to

Performance Probability of 10 may be used to meet the performance goal of 1 x 10

From the evaluation that was performed, it was determined that the likelihood -5 of a tornado

generating winds at 135 mph is at a probability level of less than lxlO . Also, according to

Appendix A ofNlJREG/CR-4461, Revision 2, strike probabilities for the one-degree, the

two-degree and the four-degree boxes containing the IIFP site are 5.235 x 10 5

yr,1 8.444 x 105 yr"

-5 -1

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

structures of 135 mph at the l xl 0 probability level represents a conservative approach. The IIFP

Facility building and structures that contain hazardous radiological and chemical (if applicable)

materials that must be controlled or mitigated to meet the performance criteria given in 10 CFR

part 70.61, "Performance Requirements," are treated for the purposes of evaluating risks as PC-3

structures per the Natural Phenomena Hazard Evaluation methods prescribed in DOE-STD-1020-

2002. As mentioned above, those structures will meet the performance category of I xl& A, and be

designed to withstand a lxi 0 probability per year occurrence straight-line wind event. Hence,

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

methodology in NUREG-1520, Rev. 1, the collapse or loss of the building integrity is considered
General Information

-5

to be highly unlikely and meets the qualitative frequency scale of lxlO per year or less. Events

that occur at a highly unlikely frequency meet the performance criteria for acceptable risk without

the need to further reduce the likelihood of hazardous release or mitigate its consequences.

Therefore, designing the IIFP applicable facilities to withstand straight-line wind events with an -4

occurrence frequency of I xl 0 per year meets ISA risk acceptance levels regardless of the

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

hazardous release.

License Documentation Impact: Additional references will be included in Section 1.8

License Documentation Impact: Sections 1.3.2.6 and 1.3.2.7, of Revision A of the IIFP

Integrated Safety Analysis Summary have been incorporated above in Section 1.3.2.3 "Extreme

Winds" as subsections "Hurricanes" and "Tornadoes and Straight Winds", respectively. The

Sections will be removed in their entirety and subsequent Sections and subsections will be

renumbered accordingly.

1.3.2.6 Tornadoes

Tornadoes af re occSionally reported in New Mexieo, most frequently dur-ing afternoon and earlyevening heor-s from May through August. There is an aver-age of nine tornados a ycar in New

Mexico. Tornadecs Oecur ifreqtufetly ii the Vicinity Of the IWP Site. Onfly Po toiadoe sWerereported in Lea County from 1980 to 1989. Only, one tornad was r-epoired in Andrews CoUnty, l

Texas inl the Sa4.ce peri.d.

1.3.2.7 Tropical Storms e4d 4ur-ricanes

Hufficanes are lo pesuPr-eS5 weather systemos that develop over- the tropical oceans anad as theymove inward they lose their intensity quickly once the, make landfall. The !WP site is

appro..mately 500 mile from the nea.est e.ast, it is likely that any hurri.ane that mo, ved in that

direetion would have downgraded to a tropical depr-ession before it reacahed HFP-.

License Documentation Impact: Section 1.6.3.3, "Extreme Winds" of Revision A of the IIFP

License Application (now Section 1.7.3.3, in response to RAI RP-13) will be revised as follows

to include marked paragraphs:

Extreme Winds

Wind speeds over the State of New Mexico are usually moderate, although relatively strong

winds often accompany occasional frontal activity during late winter and spring months and

sometimes occur just in advance of thunderstorms. Frontal winds may exceed 30 mile/hr for

several hours and reach peak speeds of more than 50 mile/hr.

Design wind speeds for all buildings and structures that do not contain licensed material or for

buildings and structures containing chemicals or processes that do not affect licensed material

will be determined in accordance with the applicable model building codes (New Mexico

Commercial Building Code (NMCBC, 2006) and American Society of Civil Engineers (ASCE

705) or latest editions adopted by the State of New Mexico at time of design). Specifically,

these buildings and structures will be designed for a minimum straight gust wind speed of 90

mph.
General Information

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

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

10 CFR part 70.61, "Performance Requirements," are treated for the purposes of evaluating risk as

equivalent to PC-3 structures per the Natural Phenomena Hazard Evaluation methods prescribed

in DOE-STD-1020-2002. These structures will be designed to withstand a straight gust wind

speed of 135 mph at the 10 probability level of exceeding. Hence, based on the order of

magnitude scale for determining event likelihood using the ISA methodology in NUR-EG-1 520,

Rev. 1, the collapse or loss of the building integrity is considered to be highly unlikely at this

design basis.
General Information

GI-10

E. Regarding the design basis threat for a tornado, provide the source of the information

that 9 tornados occur annually in New Mexico, e.g., National Oceanic and Atmospheric

Administration. Provide the source of the information which indicates that two tornados occurred

in Lea County. Specify the probability frequency of a tornado hitting an IIFP building and

provide the basis for this information. Indicated if this frequency information or some other

reason is used as a basis for not assigning Items Relied on for Safety (IROFS) for tornados in the

ISA.

RESPONSE: NOAA NCDC Storm Events provides data for 527 tornado events in New Mexico

over a 60 year period for an average of 8.78 tornadoes per year. Lea County reported 92

tornadoes for the same period for an average of 1.53 tornadoes per year. Of these 92 tornado

events for Lea County between 01/01/50 and 01/31/10, 63 - FO, 20 - F1, 8 - F2, and one- F3

tornadoes were reported.

Also, according to Appendix A of NUREG/CR-4461, Rev.2, strike probabilities for the

one-degree, the two-degree and the four-degree boxes containing the IIFP site are 5.235 x

W5 44 .1?c 10 yr and 3.975 x 10- yr' respectively.

-4

The design basis wind speed for the HIFP Facility is 135 mph at a 10 probability level.

According to data provided in NUREG/CR-4461, Rev. 2, it is highly unlikely that a tornado with

winds exceeding 135 mph will occur in this locale. Also, all strike probabilities for the

one-degree, two-degree and four-degree boxes in Appendix A are at a less than 10& probability

level.

License Documentation Impact: Section 1.3.2.6 of Revision A of the IIFP Integrated Safety

Analysis Summary will be deleted has been incorporated into Section 1.3.2.3, subheading

"Tornadoes and Straight Winds (see RAI GI-OD).

License Documentation Impact: Former Section 1.6.3.3, "Tornadoes" (now Section 1.7.3.3, in

response to RAI RP-13) of Revision A of the IIFP License Application will be revised to read as

follows:

Tornadoes

Tornadoes are occasionally reported in New Mexico, most frequently during afternoon and early

evening hours from May through August. There is an aVer.ge Of nin. tonadoes .ear a in. New

Mexico. Tcrnadoes occur infr~egucnt1) inl the Viciniity' ef UIP. Only two tornladoes were repred

in Lea County' firm 1880 to 1989. Onfly one tornado Was reported in Andrews County', Te.as in_

the-same r-iod-NOAA National Climate Data Center (NCDC) Storm Events includes

information for 527 tornado events reported for the state of New Mexico for the period 1950-

2010 for an average of 8.78 events per year. Lea County reported 92 tornadoes for the same

period for an average of 1.53 tornadoes per year. Of these 92 tornado events for Lea County

between 01/01/50 and 01/31/10, 63 - FO, 20 - Fl, 8 - F2, and one- F3 tornadoes were reported.

During this same sixty-year period, no F4 or F5 tornadoes were reported. (NCDC, 201 Oa)

License Documentation Impact: Paragraph three from section 3.6.1.6 of Revision A of the HFP

Environmental Report will be revised to read as follows:
General Information

Tornadoes are occasionally reported in New Mexico, most frequently during afternoon and early

evening hours from May through August. There is an average of nine tornadooes a year- in NeW

Mexiee. Tornadees eccur infrequently in the vicinily of IF-P. Only twc tornadoes were r-epored

in Lea Counlty from 1880 to) 1989. Onily onfe tornado was r-eported in Andrews Ccunfty, Texas inthe-same -1r- From NOAA National Climate Data Center (NCDC) Storm Events, it was

determined that 527 tornado events were reported for the state of New Mexico for the period

1950-2010 for an average of 8.78 per year. Lea County reported 92 tornadoes for the same period

for an average of 1.53 tornadoes per year. Of the 92 tornado events between 01/01/1950 and

01/31/2010, 63 - FO. 20 - F1, 8 - F2, and one- F3 tornadoes were reported in Lea County. During

this sixty-year period, no F4 or F5 tornadoes were reported. See Figure 3-60-61 showing the

Tornado Probability Map of the United States.
General Information

GI-1O

F. In response to this RAI, provide information from the Process Hazards Assessment

(PHA) which demonstrates that the Accident Analysis 101.9from ISA Table 4-3 has a correct

value of 10-4. Indicate whether this number is based on the probability of a tornado striking

the facility. Add information to the description in the ISA Summary Section 1.3.2.6 which

indicates the source of information for determining the tornado data.

RESPONSE: According to Appendix A of NUREG/CR-446 1, Rev.2, the two-degree box which

contains the IIFP site has a strike probability of 8.444 x 10" yr. Strike probabilities for the

one-degree and four-degree boxes are 5.235 x 10 yr' and 3.975 x 105 yr respectively.

-4

The design basis wind speed for the IIFP Facility is 135 mph at a 10 probability level.

According to data provided in NUREG/CR-4461, Rev. 2, it is highly unlikely that a tornado with

-5

winds exceeding 135 mph will occur in this locale (less than 10 probability). Also, all strike

probabilities for the one-degree, two-degree and four-degree boxes in Appendix A are at a less

than 10 probability level. The assignment of a likelihood index of-4 is a conservative estimate

-4 -5

based upon strike probabilities of less than I x 10 but greater than 1 x 10

License Documentation Impact: Former Section 1.3.2.6 of Revision A of the IIFP Integrated

Safety Analysis Summary will be deleted and incorporated in Section 1.3.2.3, "Tornadoes and

Straight Winds" as shown in Response to RAIs GI-l 0 D and SS-2.
General Information

GI-1O

G. Considering the population density in Lea County, the record of only 2 damaging

lightning strikes since 1950 does not provide adequate evidence of limited risk. Consistent with

70.64(a) (2), add a statement to the LA and ISA Summary that demonstrates the proposed IIFP

and the associated power systems are designed and built with heavy grounding or lightning

protection to handle lightning strikes. Also, in response to the RAI, provide information from

the PHA which demonstrates that the accident analysis for a lightning strike at the IIFP is low

consequence, taking into account the average yearly thunderstorms.

RESPONSE: Information taken from NOAA indicates that Lea County is in a region that has an

average flash density of 4 to 5 flashes/km'/yr. The conversion of this flash density to a 40 acre

basis for the IIFP fenced area indicates that the site could expect 0.65 to 0.81 flashes per year

(equivalently less than one flash per year). IIFP structures, equipment and associated power

systems will be designed and built with heavy grounding and/or lightning protection to handle

lightning strikes.

License Documentation Impact: Section 1.6.3.3 "Lightning" of Revision A of the IIFP License

Application (now Section 1.7.3.3, "Lightning", in response to RAI RP-13) will be revised to read

as follows:

Only two lightning events having sufficient intensity to cause loss of life, injury, significant

property damage, and/or disruption to commerce were reported in Lea County, New Mexico,

between January 1, 1950 and April 30, 2004 (see IIFP ER). The closest lightning event occurred

in Hobbs with minor property damage of $3,000 on August 12, 1997. The second occurred in

Lovington on August 8, 1996, causing two deaths.

The NOAA database indicates that Lea County is in a region that has an average flash density of

2

4 to 5 flashes/km /yr. The conversion of this flash density to a 40 acre basis for the HFP fenced

area indicates that the site could expect 0.65 to 0.81 flashes per year (equivalently less than one

flash per year). IIFP structures, equipment and associated power systems will be designed and

built with heavy grounding and/or lightning protection to handle lightning strikes.

(http://www.lightningsafety.noaa.gov/stats/08 Vaisala NLDN Poster.pdf)

License Documentation Impact: Section 1.3.2.5 of Revision A of the IFP Integrated Safety

Analysis Summary will be revised to read as follows:

Only two lightning events having sufficient intensity to cause loss of life, injury, significant

property damage, and/or disruption to commerce were reported in Lea County, New Mexico,

between January 1, 1950 and April 30, 2004 (see IFP ER). The closest lightning event occurred

in Hobbs with minor property damage of $3,000 on August 12, 1997. The second occurred in

Lovington on August 8, 1996, causing two deaths.

The NOAA database indicates that Lea County is in a region that has an average flash density of

4 to 5 flashes/km /yr. The conversion of this flash density to a 40 acre basis for the IIFP fenced

area indicates that the site could expect 0.65 to 0.81 flashes per year (equivalently less than one

flash per year). IIFP structures, equipment and associated power systems will be designed and

built with heavy grounding and/or lightning protection to handle lightning strikes.
General Information

(http://www.lightningsafety.noaa.gov/stats/08 Vaisala NLDN Poster.pdf)
General Information

GI-11 LA Sections 1.6.3.4-1.6.3.8 contain information on groundwater. Consistent with the

acceptance criteria in NUREG-1520, Section 1.3.4.3(4), provide the following information:

A. The third full paragraph in LA Section 1.6.3.4 indicates runofffrom the site will not

travel to a river. For completeness, in this same paragraph, specify the distance to the nearest

river. Also, modify this commitment to be consistent with the statement in ER Section 3.4.11.5

that "IIFP plant has no direct outfall to a surface water body." Clarify the meaning of direct

outfall.

RESPONSE: The distance to the nearest river (Pecos River) from the IIFP facility site is

approximately 50 miles. This information along with the referenced statement in ER Section

3.4.11.5 and the definition of "direct outfall" will be added and clarified in the LA Section

1.6.3.4.

License Documentation Impact: Former LA Section 1.6.3.4, "Characteristics of Nearby Rivers,

Streams and other Bodies of Water" (now a subheading under 1.7.3.4 in response to RAls RP-13

and GI-5) will be revised to read as follows:

Characteristics of Nearby Rivers, Streams and other Bodies of Water

Surfacle drainiage At the Site is eentaincd within twe local playa lakes that have ne exteffift

drainage. There is also a small Streamf that FRuS from the southeast to the nott~hwest southeast

acrOSS the pr-epe~t' that would be predominantly d~' during the year:. Essentially' all the

pr-eeipitatien that oeeutrs at the site is subjeet to inifiltration andor- evapetranspiratien. Mree 2

tfm EMO "2 OR:• AT•......Ief e t .,•.t me 1+--S tttee +•t e a tg .... unfte-,tt•; •- + tt.;+-, + E D , -;+e

ER Section 3.1. There are also sever-al intermittent surface features in the vieinity ef the IIFP sit

that may ellet w.ater-fcr- hert periods of times fllowing heaNvy rainfall events.

The climate in southeast New Mexico is semi-arid. Precipitation in the IIFP area averages only 33

to 38 cm/yr (13 to 15 in/yr). Evaporation and transpiration rates are high which results in minimal,

if any, surface water occurrence or groundwater recharge.

Two small intermittent drainages are located on the southwest quadrant of Section 27. The

drainages grade to the southeast and coalesce approximately 396 m (1,300 ft) south of the section

boundary. The coalesced drainage continues to grade to the south/southeast toward Monument

Draw. Monument Draw is a maior surface drainage feature in southern Lea County and is clearly

present in topographical maps approximately 22.5 km (14 mi) southeast of the section boundary.

Although the drainage present in Section 27 grades toward Monument Draw, a review of

topographic maps did not reveal a clear physical connection to Monument Draw. The drainage

terminates in a playa approximately 12.9 km (8 mi) southeast of the section (GLEI, 2010c).

Surface drainage at the site is also contained within two local playa lakes that have no external

drainage. The nearest river to the IIFP Facility site is 50 miles, or greater, away (the Pecos River)

and rRunoff does-not from the site is unlikely todoes not drain to this river.ene of the state's

-er. rivers. Surface water is lost through ev'aperatin-, infiltration and/or evapotranspiration

resulting in high salinity conditions and the waters in soils associated with the playas. These

conditions are not favorable for the development of viable aquatic or riparian habitats. The IIFP

Facility has no direct outfall to a natural body of surface water. HFP defines "direct outfall" as a
General Information

discharge of facility water directly into a natural body of surface water such as a river or stream,

or as a water discharge normally identified as an "outfall" in a National Pollutant Discharge

Elimination (NPDES) permit. At the IIFP Facility, process water and cooling water are either

recycled back into the process systems or evaporated in the Environmental Protection Process

(EPP) Facility as part of the treatment. Process areas where hazardous chemicals or licensed

materials are processed and handled have sealed dikes, curbs and pumps, where necessary, to

collect and transport leaks or spills in those areas back into the process or to the EPP for treatment

as process water. Sanitary wastewater from toilets, lavatories and showers receives primary,

secondary and tertiary treatment and is used to water an on-site tree farm in accordance with New

Mexico ground-water permit requirements, where applicable. Disposition of sanitary water and

collected rain or storm water is further described in Section 1. 1.5.3 above. T-here is nie designated

FEMA Z'ne "A" area that would be inundated during a 100 year flood event.
General Information

GI-11

B. The ER Section 4.4.7 refers to a Stormwater Pollution Prevention Plan (SWPPP). This

plan does not appear to be a commitment addressed in the LA. Since the ER is not part of the

license application, incorporate the commitment to maintain the SWPPP into the LA. Add a

commitment similar to ER Sections 3.4.11.4 and 3.4.11.5 to the LA.

RESPONSE: The information relative to a Stormwater Pollution Prevention Plan (SWPPP) for

the IIFP Facility operations that is described in the IIFP ER Section 4.4.7 will be included as a

new paragraph five in the former LA Section 1.6.3.6 "Groundwater Hydrology" (now subheading

under 1.7.3.4 in response to RAIs RP-13 and GI-5.) The information in the IIFP ER for

commitment to a SWPPP is found in ER Section 3.4.10; not the referenced ER Sections 3.4.11.4

and 3.4.11.5. The SWPPP commitment in ER Section 3.4.10 will be added appropriately as

paragraph four in LA Section subheading "Groundwater Hydrology in the new 1.7.3.4.

License Documentation Impact: New paragraphs 4 and 5 will be added to the HFP LA former

Section 1.6.3.6 (new 1.7.3.4) subheading "Groundwater Hydrology."

A NPDES--Construction General Permit for stormwater discharge is required because

construction of the IFP plant will involve the grubbing, clearing, grading or excavation of one or

more acres of land. This permit is required prior to certain pre-construction activities and to

construction activities and will be administered by the Environmental Protection Agency (EPA)

with oversight review by the New Mexico Water Quality Bureau. Various land clearing activities

such as off-site borrow pits for fill material are covered under this general permit. IIFP

construction contractors will be clearing approximately 40 acres during the construction stage of

the proiect. lIFP will develop a Storm Water Pollution Prevention Plan (SWPPP) and file a

Notice of Intent (NO) with the EPA, at least seven days prior to the commencement of

construction activities, in accordance with regulatory requirements

A Spill Prevention Control and Countermeasure (SPCC) plan will be implemented for the facility

to identify potential spill substances, sources and responsibilities. In addition, storm water

discharges during plant operation will be controlled by a Stormwater Pollution Prevention Plan

(SWPPP) to assure that runoff released to the environment will be of acceptable water quality.