From: Bartlett, Matthew 

Sent: Thursday, September 08, 2011 10:01 AM 

To: Simon 

Cc: George Adams; Asadul Chowdhury; John Stamatakos; Sircar, Madhumita 

Subject: RE: Structural and Digital I&C 

INIS has provided the following commitments in response to our request. 

Sincerely, 

Matt Bartlett 

Project Manager 

U.S. Nuclear Regulatory Commission 

NMSS/FCSS/AFCB 

(301)-492-3119 

From: John Miller [mailto:jjmiller@intisoid.com] 

Sent: Wednesday, September 07, 2011 5:37 PM 

To: Bartlett, Matthew 

Cc: Jim Thomas; 'Steve Laflin' 

Subject: 

Matt, 

We will revise the LA to include the following commitments: 

1. Structural Request: 

In the LA (possibly section 1.5.4) provide a commitment substantially similar to the following: 

IIFP commits to develop a geotechnical and geophysical investigation and analysis plan which 

includes a commitment to acquire the necessary information on the site soil class, seismic site 

response, liquefaction potential, soil settlement potential, and allowable bearing capacity for the 

IIFP site. The field activities are to include dilatometer soundings, seismic cone penetration 

tests, cross-hole seismic tests, standard penetration tests, auger borings, and soil sampling. 

IIFP commits to conduct the geotechnical and geophysical investigations in accordance with the 

ASTM standards listed in ISA Summary Section 2.3.3 [list the appropriate standards]. 

Revise Section 1.5.4 to include: 

IIFP commits to develop a geotechnical and geophysical investigation and analysis plan which 

includes a commitment to acquire the necessary information on the site soil class, seismic site 

response, liquefaction potential, soil settlement potential, and allowable bearing capacity for the 

IIFP site. The field activities are to include dilatometer soundings, seismic cone penetration 

tests, cross-hole seismic tests, standard penetration tests, auger borings, and soil sampling. 

IIFP commits to conduct the geotechnical and geophysical investigations in accordance with the 

ASTM standards listed in ISA Summary Section 2.3.3. 

2. Digital I&C Request: 

In the LA (possibly in section 11.4.1.1) provide a commitment substantially similar to the 

following: For administrative control preventive IROFS in the same accident sequence, IIFP 

commits to ensure the procedures will be written to ensure strict independence of the preventive 

IROFS. 
Revise Section 11.4.1 to include: 

For administrative control preventive IROFS in the same accident sequence, IIFP commits to 

ensure the procedures will be written to ensure strict independence of the preventive IROFS. 

3. Financial Assurance 

 In regard to the Financial Assurance License conditions; IIFP concurs with the following: 

1. The licensee shall not obtain radioactive material until the NRC reviews and 

approves the executed financial assurance instrument and certification of financial 

assurance. 

2. The licensee shall provide an updated DFP, and updated facility decommissioning 

cost estimate to NRC for review at least six months prior to the planned date for 

obtaining licensed material. 

On an annual basis, starting on the anniversary date of obtaining licensed material, 

the licensee shall provide an updated DFP, and updated facility decommissioning

cost estimate to the NRC for review. With each annual update, if the cost estimate 

exceeds the amount of financial assurance provided, the licensee shall provide 

financial assurance in the amount of the updated cost estimate and an updated 

certification of financial assurance to NRC for review and approval. 

All updates to the DFP, and cost estimate for facility decommissioning and financial 

assurance instruments, shall be updated to current year United States dollars and 

shall encompass all current cost data, taking into account changes in inflation, 

possession limits, licensed material, labor rates, disposal and shipping rates, and site 

and facility factors. All updates to the DFP, and cost estimate for facility 

decommissioning and financial assurance instruments shall also include updated 

costs for the disposal of DUF6, DUF4, DUO2, and UO2. The licensee shall include the 

costs of shipping and disposal of any DUF6 that the licensee has financial 

responsibility for its disposal, including DUF6 that the licensee holds legal title. All 

costs shall be supported by a detailed basis, be based on the costs of a third party 

contractor or the Department of Energy, and shall not take credit for any salvage 

value that might be realized from the sale of potential assets during or after 

decommissioning. The total cost estimate shall include a contingency factor of at 

least 25 percent.

John J. Miller CHP 

International Isotopes Inc 

Phone: 208.524.5300