International Isotopes Inc.

April 29, 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 documents are 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) Official Responses to Financial Assurance RAIs (Public)

(2) Official Responses to Financial Assurance RAIs (Non-Public - Proprietary Information)

An affidavit is also included to withhold Enclosure (2) as proprietary information.

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

questions regarding this letter or require additional information.

Sincerely,

John J. Miller, CHP

Radiation Safety Officer

JJM-2011-30

Enclosures as Stated

cc: Dr. Matthew Bartlett

U.S. Nuclear Regulatory Commission

Mail Stop E2C40M

6003 Executive Blvd.

Rockville, MD 20852

4137 Commerce Circle, Idaho Falls, Idaho 83401

Phone: 208-524-5300, 800-699-3108 Fax: 208-424-1411
International Isotopes Inc.

Affidavit Declaring Confidential Information Submitted Under 10 CFR 2.390

Proprietary - Commercial and Financial Information

Document:

Company Officer:

Enclosure (2) of JJM-2011-30

Laurie McKenzie-Carter

Title: Chief Financial Officer

Company: International Isotopes Inc. (INIS)

Declaration: Enclosure (2) of JJM-2011-30, Official Response to Financial

Assurance RAIs contains waste disposal cost estimate information in

the response to RAI FA-5, prepared using verbal quotes provided by

Energy Solutions during a meeting held in December 2008. The cost

estimate includes a disposal cost per cubic foot of waste with a 7%

increase per year, an activity surcharge and applicable taxes. INIS

considers this information as Proprietary, Commercial and Financial

Information that if released to the public could jeopardize INIS's ability

to negotiate waste disposal rates with alternative waste disposal

companies such as US Ecology and Waste Control Specialists.

Additionally the response to RAI FA-7 provides information regarding

the requested amount of the loan that INIS applied for through the DOE

Loan Guarantee Office. As this request has not yet been approved we

believe that releasing the requested amount could positively or

negatively influence potential investors. Because the loan value is

linked to and can be derived from the estimated cost of the project, this

estimated cost has been redacted as well.

Laurie McKenzie-Carter CFO Date

4137 Commerce Circle, Idaho Falls, Idaho 83401

Phone: 208-524-5300, 800-699-3108 Fax: 208-524-1411

Website: www.intisoid.com
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAls

The financial assurance requirements for source material licensees, among others, are located in 10 CFR

40.36, 10 CFR 40.42 and the Consolidated Decommissioning Guidance contained in NUREG 1757. The

following information is needed to demonstrate compliance with the acceptance criteria in NUREG-1 757

and the regulatory requirements in Part 40. Consistent with 10 CFR 40.32, 10 CFR 40.42, and NUREG175 7, please provide the following information:

FA-1 Clarify that the DCE uses the following: a) independent third-party labor costs and; b) that all

third-party labor costs, including profit, are presented (NUREG-1 757, Volume 3, Appendix A,

Pages A-26 to A-28).

A. Neither the Major Assumptions (§ 10.2.2.2) nor Table 10-14 "Worker Unit Cost Schedule"

state explicitly that all labor costs are based on a third-party contractor performing the work.

Section 10.1.2.4 "Management Organization, "states the following:

IIFP intends to be the Prime Decommissioning Operations Contractor (DOC)

responsible for decommissioning the FEP/DUP. In this capacity, IIFP will have

direct experience with the plant operations and have control and oversight over

all decommissioning activities. IIFP also plans to secure contract services to

supplement its capabilities, as necessary.

NUREG-1 757 states that "7e] estimated costs should be based on reasonable and

documented assumptions, and provide sufficient funds to allow an independent third party to

assume responsibility for and carry out the decommissioning of the facility if the licensee is

unable to do so. " (A-27) However, it is unclear whether the DFP submitted by IIFP is based

on independent third-party costs, and the material quoted above suggests that it is not. If the

DFP is based on third-party labor costs, state that fact explicitly as one of the assumptions.

Otherwise, revise the cost estimate to ensure that it is based on the costs of an independent

third-party contractor performing the work.

RESPONSE: The original DCE did not include the cost of a third-party contractor to do the

labor. A profit margin is now being added to allow an independent third party contractor to

assume responsibility for carrying out the facility decommissioning if IIFP is unable to do the

work. The profit margin has been added to the total labor cost including those for planning,

project management, dismantling, equipment sizing (volume reduction), decontamination,

packaging, surveying, administrative, etc. These additional costs are derived by multiplying a

1.12 margin by all of the labor, overhead (See RAI FA-1B below) and material costs used in the

DFP Chapter 10 License Application Revision A. The added margin is not added to the

transportation and disposal costs because those estimated cost categories already include the

vendor margins for profit and overheads. The affected cost Tables and Chapter 10 text will be

revised as shown in the License Documentation Impact below.

Table 10-18 will be deleted and replaced with a new table which clearly reflects third party costs.

In order to provide the simplest and most accurate representation in the tables, Tables 10-7, 10-8,

10-9, 10-11, and 10-13 have been reworked to show base labor hours and cost plus the estimated

cost of supplies to perform the different tasks. These individual Tables do not include third party

contractor profit. However, in the new Table 10-18, "Total Decommissioning Cost", three

columns are now provided. The first column shows total base labor hours plus supplies for each

decommissioning task. Costs shown in the second column reflect a 12 percent margin for third

Financial Assurance RAIs Page I I
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

party contractor profit. The third column also reflects the required 25 percent contingency applied

to all costs.

License Documentation Impact: Tables 10-7, 10-8, 10-9, 10-11, 10-13, 10-15, 10-17 and 10-18

will be deleted and replaced by new tables using the same identification numbers. New tables to

be included in the next LA revision are provided in red text at the end of the RAI response

document package. Tables 10-10 and 10-12 were not changed but are included in black text for

reference purposes.

Financial Assurance RAIs Page 1 2
Enclosure 1 JJM-2011-30 April29, 2011

Official Response to Financial Assurance RAIs

FA-1

B. NUREG-1 757 states that labor cost estimates include basic wages and benefits, overhead

costs, and profit "sufficient to allow an independent third party to carry out the

decommissioning project. " (A-28) Although Table 10-14 provides amounts for "salary and

fringe "for eight separate labor categories and adds a 25 percent "overhead rate, " there is

no indication that profit for a third-party contractor is included in the estimated labor costs.

Clarify whether an estimate for third-party contractor profit is included in the "overhead

rate;" and if it is not, add a reasonable estimate for profit to the estimated labor costs in the

DFP.

RESPONSE: IIFP agrees that an overhead rate of 25 percent as broken out and expressed in the

original Chapter 10 Revision A estimate appears low. Originally, some overhead costs along with

fringe costs were included in the wages and salaries and were not broken out specifically to

accurately reflect overhead costs. We have now broken out the fringe (30% rate) and overhead

(60% rate). As a result, the following process was used to more accurately explain the labor costs.

Base wages for the region were verified using the State of New Mexico Department of Workforce

Solutions for Eastern New Mexico where region-specific wages are provided for different labor

categories. It is assumed that a third-party contractor would transfer some project management

and professional staff into the local area but that local unskilled and skilled labor for

decontaminating, dismantling and packaging would be used from the Hobbs area workforce.

Fringe and overhead rates of 30 and 60 percent respectively were added to the base labor rates for

the labor categories. This breakout and presentation of fringes and overheads more clearly show a

multiplier of 1.9 times direct wages or 2.13 times wages when third-party contractor profit is

included. The breakdown is now shown in the new Table 10-14, "Worker Unit Cost Schedule."

These total wage rates (with fringes and overheads) are used in the determination of

decommissioning cost for the different decommissioning tasks. The third-party profit margin and

contingency are then applied as described in response to RAI FA-lA above.

License Documentation Impact: Table 10-14 will be deleted and replaced by a new table using

the same identification number. Other tables affected by these changes are addressed in response

to RAI FA-1A. The new tables to be included in the next License Application revision are

provided in red text at the end of this RAI response document package.

License Documentation Impact: Section 10.2.2.1, first paragraph of the License Application

will be revised to reflect a change in the decommissioning cost from approximately "$12.2

million" to $12.8 million" to read as follows:

The decommissioning cost estimate for the FEP/DUP facility is approximately $4-.'-241 2.8 million

(2009 dollars). The decommissioning cost estimate and supporting information are presented in

Tables 10-1 through 10-18, consistent with the applicable provisions of NUREG- 1757 Volume 3,

"Consolidated NMSS Decommissioning Guidance - Financial Assurance, Recordkeeping and

Timeliness" (NRC, 2006).

License Documentation Impact: Section 10.3.2, third paragraph of the License Application will

be revised to reflect a change in the decommissioning cost from "nearly $12.2 million" to

approximately $12.8 million" to read as follows:

Financial Assurance RAls Page I13
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

For the first four year period of operationr, IIFP is committed ilie-ds to provide financial

assurance deeommissioning funding for the IIFP Facility. assurance for, only !he Phase 1 portions

of the facility. In 20-09 olrth0aii\ decommIPissioning cost estimiate would be assured.

Applying a 25% contingency factor to the decommissioning cost estimate, yields a total projected decommissioning cost for the IIFP FacilityPhase I FEP/DUP 4 ,el-,we ,,:•e- forwhich

financial assurance would be provided, of near-ly $-12approximatelv $12.8 million (expressed in

2009 U.S. dollars).

Financial Assurance RAIs Page 1 4
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

FA-2 Provide a more complete estimate of the amount of radioactive wastes that will require disposal

(NUREG-1 757, Volume 3, Appendix A, Page A-2 7).

A. Tables 10-1 through 10-6 of the DFP provide volume estimates for individual components for

each of the separate buildings at the facility. However, these tables do not sum these

estimates to provide either a building-specific estimate or a comprehensive facility-wide total

for the amount of low level radioactive waste (LLRW) that will need to be disposed as part of

the decommissioning. Revise Tables 10-1 through 10-6 to provide a building-specific

estimate of the total amount ofLLRW; and sum these to provide a comprehensive, facilitywide estimate of wastes that will need to be disposed during decommissioning.

RESPONSE: Tables 10-1 through 10-6 will be deleted and replaced with new tables which total

both non-LLW and LLW wastes for the different buildings. Since LLW disposal cost is based on

volume, it is logical to focus on volumes rather than equipment dimensions although the volumes

are calculated from dimensions in the supporting documentation. This also makes the tables more

straightforward and easier to read. The LLW totals for these areas are transferred to new Table 10-

16, "Packaging, Shipping and Disposal of Radioactive Wastes" which shows estimated facilitywide LLW volumes and disposal costs.

License Documentation Impact: Tables 10-1 through 10-6 will be deleted and replaced by new

tables using the same identification numbers. New tables to be included in the next LA revision

are provided in red text at the end of the RAI response document package.

Financial Assurance RAIs Page 1 5
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

FA-2

B. Table 10-16 "Shipping and Disposal of Radioactive Wastes, "provides the estimated costs of

LLR W disposal for various floors of various buildings throughout the facility. Table 10-16

does not sum these estimates to provide building-specific disposal costs. In addition, the

amounts ofLLRW corresponding to the specified costs are not included in the Table. Revise

Table 10-16 to provide a building-specific estimate of the total costs along with the

corresponding quantity ofLLRW; and sum these to provide a comprehensive, facility-wide

estimate of the costs and wastes that will need to be disposed during decommissioning.

RESPONSE: Table 10-16, "Packaging, Shipping and Disposal of Radioactive Wastes" has been

revised to provide LLW volumes by building rather than by floor levels to simplify the

presentation of the information and to make the transition between tables easier to follow and

understand. Volumes of LLW for each building are included in new Table 10-16 per request.

License Documentation Impact: Table 10-16 will be deleted and replaced by a new table

"Packaging, Shipping and Disposal of Radioactive Wastes" using the same identification number.

The new Table to be included in the next LA revision is provided in red text at the end of the RAI

response document package.

Financial Assurance RAIs Page 1 6
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

FA-2

C. Furthermore, the relationship between the data in Tables 10-1 through 10-6 and the data in

Table 10-16 is not easily discernable. As a result, it is difficult to ascertain which data from

Tables 10-1 through 10-6 provide a basis for the estimated LLRW volume and disposal costs

listed in Table 10-16. (For instance, if Table 10-1 corresponds to the "DUF4 Process

Building ]s level " through "DUF4 Process Building 5h level, "the DFP should clearly state

this.) Clearly indicate which data from the supporting tables (e.g., 10-1 through 10-6)

provide a basis for the estimated LLRW volume and disposal costs which will be listed in

Table 10-16, once it is revised in accordance with b) above.

RESPONSE: Tables 10-1 through 10-6 and Table 10-16 were deleted and replaced with new

tables to better link the information provided in these tables.

License Documentation Impact: Tables 10-1 through 10-6 and 10-16 will be deleted and

replaced by new tables using the same identification number. New tables to be included in the

next LA revision are provided in red text at the end of the RAI response document package.

Financial Assurance RAIs Page 17
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

FA-2

D. Section 10.1.3.7 of the DFP states that "[a] complete estimate of the wastes and effluent to be

produced during decommissioning will be provided in the Decommissioning Plan that will be

submitted prior to initiating the decommissioning of the plant" (Page 10-8). However, the

DFP is to represent the best estimate of the amount of wastes to be disposed at the time it is

prepared, even if that estimate is later revised in the final Decommissioning Plan. As written,

the above excerpt suggests that the current estimate is incomplete. Therefore, either revise

the DFP so that it represents the best estimate of the amount of waste to be disposed; or if the

DFP currently represents the best estimate, revise the statement above to indicate that an

updated estimate will be provided in the Decommissioning Plan.

RESPONSE: The DFP represents the current best estimate of the amount of waste to be

disposed. At the time of the development of the Decommissioning Plan, an updated estimate will

be provided.

License Documentation Impact: The second paragraph in LA Section 10.1.3.7 will be revised as

follows:

Radioactive wastes will ultimately be disposed of in licensed low-level radioactive waste disposal

facilities. Hazardous wastes will be disposed of in hazardous waste disposal facilities. Nonhazardous and non-radioactive wastes will be disposed of in a manner consistent with good

industrial practice and in accordance with all applicable regulations. While current best estimates

of the these wastes are provided in the IlFP License Application Chapter 10, an A-complete

updated estimate of the wastes and effluent to be produced during decommissioning will be

provided in the Decommissioning Funding Plan that will be submitted prior to initiating the

decommissioning of the p4aWfacilitv.

Financial Assurance RAls Page 1 8
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAls

FA-3 Provide a basis for the reduced size volume factors in Tables 10-1 through 10-6 (NUREG-175 7,

Volume 3, Appendix A, Page A-2 7).

Section 10.1.4 of the DFP describes the decontamination and size reduction process that will be

followed in decommissioning the facility. Section 10.1.4.2 states that the methodology will use

"conventional" size-reduction techniques, and Section 10.1.4.4 states that "[cicontaminated

plant components will be processed through the size reduction packaging facilities. " Tables 10-1

through 10-6 each contain a column for "Reduced Size Volume 6Vt) " indicating that some facility

components will be reduced in volume by various amounts. However, the DFP does not contain

any indication of the basis for the size reduction factors which, in some cases, result in a

substantial reduction in the volume of waste-including LLRW-to be disposed. NUREG-1757

states that the DCE be based on "reasonable and documented assumptions. " (A-27) Provide a

documented basis for the size reduction factors used in the DFP.

RESPONSE: Tables 10-1 through 10-6 have been revised to reflect volume reductions only

where it is anticipated that those will actually occur. The estimates are based upon how much the

volume could be reduced by cutting the equipment into pieces and arranging those pieces to

eliminate much of the void space. The reduction estimates of one-half to two-thirds of the original

volume are considered to be conservative when compared to an example of the deconstruction of

a 4 ft box with 0.25 inch thick sides. The volume of the box is 64 ft3 (4' x 4' x 4'). If the box is

disassembled and the 6 sides are stacked, the volume would be 2 ft3 (4'x 4' x 0.021' x 6 sides)

representing a volume reduction of approximately 97 percent.

It is cost effective to reduce volumes where possible, especially for LLW where disposal costs are

based on volume. Reductions are only considered for equipment such as tanks, storage bins,

ductwork and similar equipment containing significant volume void space. Volume reductions are

taken for approximately 13 percent of the pieces of equipment listed in the tables. The one-half to

two-thirds volume reductions taken are based on reasonable estimates where it is technically

feasible to cut and dismantle equipment to achieve smaller configurations.

License Documentation Impact: Tables 10-1 through 10-6 will be deleted and replaced by new

tables using the same identification number. New tables to be included in the next LA revision are

provided in red text at the end of the RAI response document package.

Financial Assurance RAls Page I19
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAts

FA-4 Provide a basis for the estimated labor costs for packaging in Table 10-13

(NUREG-1 757, Volume 3, Appendix A, Page A-27).

Four of the five decommissioning activities described in Table 10-13 "Total Work Days by Labor

Category (Labor Days)" are supported by a preceding table providing a labor breakdown by

activity or facility component. For example, Table 10-9, "Decontamination or Dismantling of

Radioactive Components, "provides information about the number of hours, for each of eight

labor categories, allocated to work on each of 14 separate areas of the facility. The data in

Table 10-9 support summary data in Table 10-13. However, no supporting data are provided for

the "Packaging" category in Table 10-13, which accounts for almost 40percent of the total

labor. Provide further support, either in the form of a table similar to Table 10-9 or in the form

of narrative, for the labor estimates for packaging in Table 10-13.

RESPONSE: Packaging cost estimates include the sizing of equipment for disposal, and this

activity represents the major portion of these costs. These estimates are based on both the original

size of the equipment and the complexity involved in additional sizing for disposal. Some of the

equipment is expected to be packaged into containers for disposal, and packaging costs include

cutting the equipment into pieces which will fit inside the containers. Some of the equipment

which is not packaged into containers may still require sizing for shipment and disposal as

standard or oversized bulk debris. Similarly, some larger pieces of equipment will be cut into

sections so that volume reductions can be achieved

These costs are estimated for individual pieces of equipment on the basis of crew hours where a

crew consists of 3 laborers, I HP technician, I supervisor and I transportation specialist (at the

engineer hourly rate). The crew hourly rate is the summation of the individual hourly rates and

totals $288. The total crew hour estimate for the facility is 4,740 hours and is equivalent to 28,440

total labor hours. A breakdown of these hours by labor category is as follows: laborer- 14,220

hours; HP technician - 4,740 hours; supervisor - 4,740 hours; transportation specialist - 4,740

hours. In terms of effort and complexity, sizing and packaging costs are similar to costs required

for decontamination and dismantling.

License Documentation Impact: None

Financial Assurance RAIs Page I 10
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

FA-5 Provide sources for the estimated costs ofLLRWpackaging, transportation, and disposal in

Table 10-16 (NUREG-1 757, Volume 3, Appendix A, Page A-28).

Section 10.1.2.6 of the DFP states that radioactive and hazardous wastes "will ultimately be

disposed in licensed radioactive or hazardous waste disposalfacilities located elsewhere. " Table

10-16, "Shipping and Disposal of Radioactive Wastes, "provides a breakdown ofpackaging,

LLRW disposal, and transportation costs for wastes from 14 separate components of the plant.

However, the DFP does not provide unit disposal cost factors for the packaging, LLRW disposal

costs, transportation costs, or the sources and basis for these costs. Provide additional

supporting information about the estimated costs for packaging, transportation, and disposal of

LLRW waste to ensure that the costs are based on reasonable and documented assumptions.

RESPONSE: Budgetary-type quoted rates for disposal were obtained prior to beginning the

decommissioning project estimates and the license application. The quotes were from an off-site

licensed disposal facility for low-level waste and depleted uranium oxides. A contract was not

developed at the time because of the relatively long period of time (4-5) years before the facility

would be operating and needing disposal services. The disposal company did however provide a

schedule of the quoted rates by email to International Isotopes, Inc. The schedule quoted a

disposal rate of per cubic foot of LLW or depleted oxide, plus an activity charge of about

per cubic foot (based on a full container of depleted uranium oxide) and a tax; totaling

approximately per cubic foot in year 2009 dollars.

The disposal company developed a yearly schedule and inflated the cost quotes per cubic foot at

per year for the burial cost ( per year on the total rate including taxes). IIFP estimated

the shipping cost by obtaining budgetary quotes from transport trucking companies who are

experienced in the shipping of LLW waste. The transport costs from Hobbs, New Mexico to

were developed from the trucking company quotes and the mileage. The

shipping costs were estimated at about per cubic foot of container volume.

In the decommissioning cost estimate, IIFP used a disposal cost of per cubic foot, well

above the budget quote of per cubic foot. An approximate per cubic foot packaging

cost, including containers, is added to the IIFP estimated disposal cost. Additionally, shipping

(transportation) costs used in disposal of LLW and uranium materials are about per cubic

foot as opposed to a budget quote of about per cubic foot from a trucking company

experienced in LLW transportation. The resulting total estimated costs for LLW disposal

averages approximately per cubic foot. The margins (approximately +30%) used in the

decommissioning estimates are added to the quoted rates in consideration that estimates were

obtained from experienced vendor quotes but those quotes are budgetary and not under a firm

written purchase quote.

License Documentation Impact: Table 10-16 will be deleted and replaced by a new table using

the same identification number. The new Table to be included in the next LA revision is provided

at the back of the RAI response package.

Financial Assurance RAIs Page I I1I
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FA-6 Provide clarification in the application that the IIFP submittal does not include Phase 2.

The first paragraph of LA Section 10.1 states, "The Decommissioning Funding Plan addresses

the overall strategy for decommissioning the entire Phase 2facility. " This sentence gives the

erroneous impression that Phases 1 and 2 of the facility are both included in the current

decommissioning plan. The statement in the last sentence of the first paragraph in Section 10.1

which states, "Expansion of the plant to Phase 2 will require amendments to the IIFP license,"

does not provide adequate clarification that Phase 2 is not under consideration in this license

application. Consistent with the requirements in 10 CFR 40.36, explain explicitly that no portion

of Phase 2 is under consideration as part of the current license application, and as such does not

need to be addressed as part of the current Decommissioning Plan. Remove or clarify the

discussion of Phase 2, particularly the first sentence of Section 10.1, to overcome the impression

that Phase 2 is part of the current submittal.

RESPONSE: The current decommissioning plan and Chapter 10 of the IIFP License Application

apply only to the first IIFP Facility (Phase 1) and does not apply to any future expansion (such as

a Phase 2) beyond what is being requested in the current licensing application. The introductory

section, Section 10.1 and related subsections 10.1.3.1 and 10.3.2 of IIFP Chapter 10,

"Decommissioning" has been revised as part of the responses to RAI-General Information, GL-6A

and for clarity this revision eliminates references to a Phase 2 facility. The revision for Chapter

10 is shown in the License Documentation Impact below.

License Documentation Impact (1): Chapter 10 of the IIFP License Application Revision A has

been revised to eliminate references to a Phase 2 facility and reads as follows:

10 Decommissioning

This chapter presents the International Isotopes Fluorine Products, Inc. (IIFP) Plant initial

Decommissioning Funding Plan for its Fluorine Extraction Process and Uranium De-conversion

Plant (FEP/DUP). This Decommissioning Funding Plan (DFP) has been developed following the

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

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

require an amended or separate DFP.

The U1FP facility will be c.onstr.ted in two phase-,. with Phase I completing the DUF4:4,&)44

e.o .o.i. lu e pr'oducts pnessesd the supprting ifastructue of the plant,.

111Plans to expand the facility do conversio•, apacity by constructing a Phase 2 pla

approeximately 41 year-s later-. The cufrrent licenjsinig application, hntegr-ated Safety kayss (ISA)

and Decomlmission Funding Plan submittal ar-e 4ibr Phase 1 construcition and opei-aflon oe'.

Separate or- amended licensinig mid a r-evised DFP; will be developed and submitted ata

appropriate time during the licenin .. roce ---ss Of the Phase 2 project. The Phase 2 will consist at

the additional pro.essing equipment to con.vert DUFP directly into . r.anium 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

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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 ofNUREG-1757 (NRC, 2006) through submittal of

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

License Documentation Impact (2): The first paragraph of the IIFP License Application

Section 10.1 will be deleted and the revised Section will read as follows. Other changes shown

are relevant for RAI GI-6A and Decommissioning RAI-1. Also, the wording "Phase 1" will be

deleted from the title of Section 10.1.1 as shown below.

10.1 Decommissioning Strategy

The Decomnmissioninig Fundinig Plani addr-ese, the eve~i-all stiategy fer dcomsinn th4e

enitrie Phase 2 faieility. because of the tw, phase construction approach to this . .owever, Ieility,

the D.P on!, p .ovi.de.a detailed ,ost estima.e, schedul. . and . he fiancial assprance plan fo)r the

Phase 1 equipment and the infirastructurtie eqimn tha 4ill be common to both phases. This

initial DFP. including cost.estimate, .hd..n..cilaurc, assumfes that onl), a Phase

1 f~acilit', w,.ould exist at the time that deeommission is requir-ed. This strategy of pr-eparing and

s-ubm..itting an initial DF-P for- Phase 1 faeilities only, in this license applic-ation, conserv.atively

con.sid er.s that ..WEPwould cease buasiness beftore Phase , 2 is onstirutied or that Phase 2 would not

mfateriatlize. This contingency) strategy does proevide for the finiancial assur-ance of the Phase I

Rhcility in any case. Ex.pansionf. plant to hase 2 will .ther.equie amendments to the 1112

license", and the DFP will 1 be and .pated r. submit-ed to the R foFr approVal prior" to theiltr odction 4.4Af•l nuclear materials into tle Phasie 2 portion114 the fiteility.

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 longterm 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/DUP 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-1505. NUREG-1575 and NUREG-1757 in

developing initial and final site survey plans sufficient to provide background and postdecontamination 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 I portions of the

-tellFP 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).

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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.

10.1.1 IIFP Phose -1Facility Description

License Documentation Impact (3): 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 (see also

RAI GI-6A) 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 Ph[ase4I1FP

_Facility is shown as Figure 10-1. At the time of required decormissioning, if only a Phase I

Plant exists, thenl upon de-mioingad final survey and co~nfiration by. the NRC._ the

license would be t --------- ad iefclt Gh ould be eleased fo rese f- aP Ae2als

exists at the timfe of requir-ed decomminissioning, the updated future DGF Plan for- Phase 2 will

have indentified tL L•.... dul. a..d any decontamination and d.c.....sion requirements f"r

the D-UF, to oxide process beyonid these alr-eady identitled in the Pha-e 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 a!so

address aniticipated operationi of Phase 2 poi-tions of the facility priorm to introducing, nular

materials into thiat equ~ipmient.

License Documentation Impact (4): Table 7-3 of the IIFP 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.

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FA-7 Provide the articles of incorporation, corporate organizational charts, and pro-forma financial

statements (10 CFR 40.38). Provide a corporate organizational chart that indicates all the

entities in the corporate lineage, including any parent companies and/or subsidiaries of 11FP.

Indicate the type of entity (e.g., Corporation, Limited Liability Company, etc.), as well as the

location of incorporation. Indicate which entity would have direct control of the NRC license and

which entity would own the site and facility.

Provide a copy of the articles of incorporation, a list of corporate officers and their country of

citizenship for the corporate entity which has direct control of the NRC license and its parent

company (ies).

Provide five years ofpro-forma cash flow statements and five years ofpro-forma balance sheets

for INIS and IIFP. Provide two years of audited historicalfinancial statements (balance sheets,

income statements, and cash flow statements)for INIS. All the above information is needed to

identify the corporate entities that have direct or indirect control of the license, site and facility;

and to determine ifIIFP is owned, controlled or dominated by an alien, a foreign corporation or

a foreign government (10 CFR 40.38) as well as to have reasonable assurance that INIS and

I1FP are financially viable.

RESPONSE: International Isotopes Inc. was formed as a Texas corporation in 1995. Its whollyowned subsidiaries are International Isotopes Idaho, Inc., a Texas corporation; International

Isotopes Fluorine Products, Inc., an Idaho corporation; and International Isotopes Transportation

Services, Inc., an Idaho corporation. Copies of the articles of incorporation will be submitted

separately. All corporate officers and board members are U.S. citizens.

Our headquarters and all current operations are located in Idaho Falls, Idaho. Our business

consists of six reportable segments which include: Nuclear Medicine Standards, Cobalt Products,

Radiochemical Products, Fluorine Products, Radiological Services, and Transportation Services.

International Isotopes Inc. (OTCBB "INIS") is a publically traded company. The Company has

been public since 1996 and is current and fully compliant in all Securities and Exchange

Commission (SEC) filings, audits, and reports. Fully audited financials for the company can be

found online using the SEC website or any of the commonly available financial market

information web based links. A detailed organization structure for the Company, as well as a

description of planned changes in this organization structure to manage the new uranium deconversion and fluorine extraction processing facility, are contained in Chapter 2, Organization

and Administration, of the license application. The wholly owned subsidiary, International

Isotopes Fluorine Products (IIFP) will have direct control and responsibility for the NRC license

for the uranium facility. At the present time the only organizational position within IIFP that is

filled is that of the President of IIFP, Steve T. Laflin. He is also President and CEO of the parent

company, INIS.

As a corporate policy INIS does not provide public financial revenue projections because of the

inherent liabilities associated with providing projections of any type. However, the sound

financial condition of the Company can be determined by reviewing our publically available

financial statements and noting the absence of any "going concern" statements by our

independent financial auditors, Hansen, Barnett, and Maxwell.

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A review of the information contained within the Management Discussion and Analysis (MD&A)

sections of our annual financial reports since 2005 summarizes the Company financial position

and our strategy for expanding the business and constructing the planned depleted uranium deconversion and fluorine extraction processing facility. In just the past four years the Company has

spent more than $11 million dollars on this project, under expenses identified as "Fluorine

Extraction" or "Research and Development" in the financial statements. While the core nuclear

medicine business provides the foundation for our company revenues, we have secured additional

investments in the company through convertible debentures and private placements to support the

depleted uranium project. In 2010, alone the Company raised over $8 million dollars to support

this continued effort on the uranium project.

We estimate that the total cost of the design, engineering and construction for this project will be

approximately million, and as we have indicated in our MD&A statements, the Company

will need to secure additional capital to complete the project. We are evaluating several options to

raise this capital including additional equity offerings and debt financing. Clearly the Company

projects profits from this undertaking that adequately justify the capital investment in the project.

One of the debt financing options we have considered is to obtain a loan for the project from the

Department of Energy (DOE). We have submitted an application to the DOE Loan Guarantee

Office for a loan for the balance of the capital cost of the project under the DOE's program

solicitation for "Energy Savings in Manufacturing Processes" (solicitation # DE-FOA-0000 140)

titled Energy Efficient Fluorine Gas Production and Depleted Uranium De-conversion. The DOE

loan program provides low cost loans for up to 80% of the capital cost of qualifying projects in

the fields of energy and energy efficiency. If we are approved under this program, funding would

be made available directly from the federal government. The part I application was submitted to

the DOE in June 2010 and the final part 2 application was submitted in December 2010. The part

2 application included both an independent engineers' assessment of the project and

creditworthiness assessment. Both of those assessments favorably viewed the project under the

requirements of the DOE loan office program. The requested loan amount is about million

which represents 80% of the total qualified project costs and we have requested a 20 year term on

the loan. We expect that the DOE will respond to this loan application around mid-2011 and, if

we are successful, funding would be available around the end of 2011.

The Company has other debt financing options if the DOE loan application is unsuccessful. We

believe the balance of the funds required for the planned facility can be supported through

additional equity raises or commercial debt financing. In parallel with our actions to pursue the

DOE guarantee, we will also continue to work towards establishing additional supply and service

agreements with prospective customers both for de-conversion services and the various fluoride

products. We believe that these additional agreements, if entered into, will strengthen our position

to complete additional equity raises or obtain alternative debt financing, or a combination of both,

should the DOE loan not be approved.

License Documentation Impact: At this stage of the project, IIFP recognizes that a license

condition for financial assurance updates annually would reduce some uncertainties associated

with the decommissioning cost estimates and financial assurance funding levels. Section 10.3.2 of

the IIFP License Application will be amended as follows to include in the early stages of the

project a commitment to more frequent updates than required by the regulations of the cost

estimates and financial assurance funding levels.

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10.3.2 Adjusting Decommissioning Costs and Funding

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 ... ill also

address anticipated operation ofPhase -2 portions .. of the acility prier to int..du.ing nuclear

materials into that equipment.

IIFP will provide decommissioning updates to the NRC annually beginning upon approval of the

license application and during the stages of engineering., construction and early operations. After

one year of facility operation IIFP intends to request the periodicity for decommissioning cost

estimate and associated lfunding level updates to be changed to the minimum three-year basis as

required by regulations. Thereafter. updatingS*eh-updati will occur approximately every three

years. A record of the update process and results will be retained for review as discussed in

Section 10.3.3, below. The NRC will be notified of any material changes to the decommissioning

cost estimate and associated funding levels (e.g., significant increases in costs beyond anticipated

inflation). To the extent the underlying instruments are revised to reflect changes in funding

levels, the NRC will be notified as appropriate.

F 14- 10. th frt .four year peiod f .operations,. I1FP is committed intends to provide financial

assurance deeommissioning funding for the IIFP Facility..,,assura•in.e fr only the Phase . portions

o~f the facility, In 2000 dolarIAs, thoe facility domisongcstestimate would be assurcd

Applying a 25% contingency factor to the decommissioning cost estimate, yields a total projected

decommissioning cost for the IIFP Facilitya . 4.FE4ADUP I f;aeiiy, operation, for which

financial assurance would be provided, of nearly &$l2.2approximatehv $12.8 million (expressed in

2009 U.S. dollars).

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FA-8 Provide draft text of the proposed financial instruments, including an appropriate financial

assurance mechanism as detailed in 10 CFR 40.36(e), standby trust agreement (if required by the

assurance mechanism selected), and certification offinancial assurance.

Financial assurance for decommissioning must be provided by one or more of the methods as set

forth in 10 CFR 40.36(e). In addition, 10 CFR 40.36(d) states that a Decommissioning Funding

Plan must also contain a certification by the licensee that financial assurance for

decommissioning has been provided in the amount of the cost estimate. LA Section 1.2.2 states,

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

reasonable financial assurance of decommissioning funding.... " To avoid duplication of effort

and expense, provide draft text of the proposed financial instruments, including an appropriate

financial assurance mechanism as detailed in 10 CFR 40.36(e), standby trust agreement (if

required by the assurance mechanism selected), and certification offinancial assurance.

RESPONSE: While IIFP has been evaluating several of the financial assurance mechanisms

identified in Volume 3 ofNUREG-1757; IIFP has yet to select a financial institution or specific

financial assurance mechanism to fund the decommissioning of the facility. IIFP will commit to

obtaining and providing financial assurance instruments to the NRC that are consistent with the

standard format and language of those provided in Appendix A of the NUREG-1757, Volume 3.

As stated in Section 1.2.2 of the license application, the financial assurance instruments will be

provided 6 months prior to the commencement of licensed operations. Draft text of proposed

financial assurance instruments has been copied from NUREG-1757 and has been provided on

the following pages.

License Documentation Impact:

None.

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PAYMENT SURETY BOND

Date bond executed:

Effective date:

Principal: International Isotopes Inc

Type of organization: Corporation

State of incorporation: Texas

NRC license number:

Name and address of facility:

Amount for decommissioning activities

guaranteed by this bond:

Surety: [Insert name and business address]

Type of organization: [Insert "proprietorship, "'"partnership, "or "corporation "]

State of incorporation: (if applicable)

Surety's qualification in jurisdiction where licensed facility is located:

Surety's bond number:

Total penal sum of bond: $

Know all persons by these presents, that we, the Principal and Surety hereto, are firmly bound to the U.S.

Nuclear Regulatory Commission (hereinafter called NRC) in the above penal sum for the payment of

which we bind ourselves, our heirs, executors, administrators, successors, and assigns jointly and

severally; provided that, where the Sureties are corporations acting as cosureties, we, the Sureties, bind

ourselves in such sum "jointly and severally" only for the purpose of allowing ajoint action or actions

against any or all of us, and for all other purposes each Surety binds itself, jointly and severally with the

Principal, for the payment of such sum only as is set forth opposite the name of such Surety; but if no

limit of liability is indicated, the limit of liability shall be the full amount of the penal sum.

WHEREAS, the U.S. Nuclear Regulatory Commission, an agency of the U.S. Government, pursuant to

the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974, has

promulgated regulations in title 10, Chapter 1 of the Code of Federal Regulations, Part 40, applicable to

the Principal, which require that a license holder or an applicant for a facility license provide financial

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assurance that funds will be available when needed for facility decommissioning;

NOW, THEREFORE, the conditions of the obligation are such that if the Principal shall faithfully, before

the beginning of decommissioning of each facility identified above, fund the standby trust fund in the

amount(s) identified above for the facility;

Or, if the Principal shall fund the standby trust fund in such amount(s) after an order to begin facility

decommissioning is issued by NRC or a U.S. District Court or other court of competent jurisdiction;

Or, if the Principal shall provide alternative financial assurance, and obtain NRC's written approval of

such assurance, within 30 days after the date a notice of cancellation from the Surety is received by both

the Principal and NRC, then this obligation shall be null and void; otherwise it is to remain in full force

and effect.

The Surety shall become liable on this bond obligation only when the Principal has failed to fulfill the

conditions described above. Upon notification by NRC that the Principal has failed to perform as

guaranteed by this bond, the Surety shall place funds in the amount guaranteed for the facility into the

standby trust fund.

The liability of the Surety shall not be discharged by any payment or succession of payments hereunder,

unless and until such payment or payments shall amount in the aggregate to the penal sum of the bond,

but in no event shall the obligation of the Surety hereunder exceed the amount of said penal sum.

The Surety may cancel the bond by sending notice of cancellation by certified mail to the Principal and to

NRC provided, however, that cancellation shall not occur during the 90 days beginning on the date of

receipt of the notice of cancellation by both the Principal and NRC, as evidenced by the return receipts.

The Principal may terminate this bond by sending written notice to NRC and to the Surety 90 days prior

to the proposed date of termination, provided, however, that no such notice shall become effective until

the Surety receives written authorization for termination of the bond from NRC.

The Principal and Surety hereby agree to adjust the penal sum of the bond yearly so that it guarantees a

new amount, provided that the penal sum does not increase by more than 20 percent in any one year and

no decrease in the penal sum takes place without the written permission of NRC.

If any part of this agreement is invalid, it shall not affect the remaining provisions that will remain valid

and enforceable.

In Witness Whereof, the Principal and Surety have executed this financial guarantee bond and have

affixed their seals on the date set forth above.

The persons whose signatures appear below hereby certify that they are authorized to execute this surety

bond on behalf of the Principal and Surety.

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PRINCIPAL

[Signatures]

[Names]

[Titles]

[Corporate seal]

CORPORATE SURETY

[Name and address]

State of incorporation:

Liability limit: $

[Sijgnatures]

[Names]

[Titles]

[Corporate seal]

[For every co-surety, provide signatures, names and titles, corporate seal, and other information

in the same manner as for the Sureties above.]

Bond Premium: $

STANDBY TRUST AGREEMENT

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TRUST AGREEMENT, the Agreement entered into as of [insert date] by and between International

Isotopes Inc, a Texas Corporation, herein referred to as the "Grantor," and [insert name and address of a

trustee acceptable to NRC], the "Trustee."

WHEREAS, the U.S. Nuclear Regulatory Commission (NRC), an agency of the U.S. Government,

pursuant to the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974, has

promulgated regulations in title 10, Chapter I, of the Code of Federal Regulations, Part 40. These

regulations, applicable to the Grantor, require that a holder of, or an applicant for, a materials license

issued pursuant to 10 CFR Part 40 provide assurance that funds will be available when needed for

required decommissioning activities.

WHEREAS, the Grantor has elected to use a surety bond, to provide [insert "all" or "part "] of such

financial assurance for the facilities identified herein; and

WHEREAS, when payment is made under a surety bond, this standby trust shall be used for the receipt of

such payment; and

WHEREAS, the Grantor, acting through its duly authorized officers, has selected the Trustee to be the

trustee under this Agreement, and the Trustee is willing to act as trustee;

NOW, THEREFORE, the Grantor and the Trustee agree as follows:

Section 1. Definitions. As used in this Agreement:

(a) The term "Grantor" means the NRC licensee who enters into this Agreement and any successors or

assigns of the Grantor.

(b) The term "Trustee" means the trustee who enters into this Agreement and any successor trustee.

Section 2. Costs of Decommissioning. This Agreement pertains to the costs of decommissioning the

materials and activities identified in License Number [insert license number] issued pursuant to 10 CFR

Part 40, as shown in Schedule A.

Section 3. Establishment of Fund. The Grantor and the Trustee hereby establish a standby trust fund (the

Fund) for the benefit of NRC. The Grantor and the Trustee intend that no third party shall have access to

the Fund except as provided herein.

Section 4. Payments Constituting the Fund. Payments made to the Trustee for the Fund shall consist of

cash, securities, or other liquid assets acceptable to the Trustee. The Fund is established initially as

consisting of the property, which is acceptable to the Trustee, described in Schedule B attached hereto.

Such property and any other property subsequently transferred to the Trustee are referred to as the

"Fund," together with all earnings and profits thereon, less any payments or distributions made by the

Trustee pursuant to this Agreement. The Fund shall be held by the Trustee, IN TRUST, as hereinafter

provided. The Trustee shall not be responsible nor shall it undertake any responsibility for the amount of,

or adequacy of the Fund, nor any duty to collect from the Grantor, any payments necessary to discharge

any liabilities of the Grantor established by NRC.

Section 5. Payment for Required Activities Specified in the Plan. The Trustee shall make payments from

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the Fund to the Grantor upon presentation to the Trustee of the following:

(a) A certificate duly executed by the Secretary of the Grantor attesting to the occurrence of the events,

and in the form set forth in the attached Certificate of Events, and

(b) A certificate attesting to the following conditions:

1. that decommissioning is proceeding pursuant to an NRC-approved plan;

2. that the funds withdrawn will be expended for activities undertaken pursuant to that plan; and

3. that NRC has been given 30 days prior notice of International Isotope Inc.'s intent to withdraw

funds from the trust fund.

No withdrawal from the Fund for a particular license can exceed 10 percent of the remaining funds

available for that license unless NRC written approval is attached.

In addition, the Trustee shall make payments from the Fund as NRC shall direct, in writing, to provide for

the payment of the costs of required activities covered by this Agreement. The Trustee shall reimburse the

Grantor or other persons as specified by NRC from the Fund for expenditures for required activities in

such amounts as NRC shall direct in writing. In addition, the Trustee shall refund to the Grantor such

amounts as NRC specifies in writing. Upon refund, such funds shall no longer constitute part of the Fund

as defined herein.

Section 6. Trust Management. The Trustee shall invest and reinvest the principal and income of the Fund

and keep the Fund invested as a single fund, without distinction between principal and income, in

accordance with general investment policies and guidelines which the Grantor may communicate in

writing to the Trustee from time to time, subject, however, to the provisions of this section. In investing,

reinvesting, exchanging, selling, and managing the Fund, the Trustee shall discharge its duties with

respect to the Fund solely in the interest of the beneficiary and with the care, skill, prudence and diligence

under the circumstances then prevailing which persons of prudence, acting in a like capacity and familiar

with such matters, would use in the conduct of an enterprise of a like character and with like aims, except

that:

(a) Securities or other obligations of the Grantor, or any other owner or operator of the facilities, or any

of their affiliates as defined in the Investment Company Act of 1940, as amended (15 U.S.C. 80a2(a)), shall not be acquired or held, unless they are securities or other obligations of the Federal or a

State government;

(b) The Trustee is authorized to invest the Fund in time or demand deposits of the Trustee, to the extent

insured by an agency of the Federal government, and in obligations of the Federal government such

as GNMA, FNMA, and FHLM bonds and certificates or State and Municipal bonds rated BBB or

higher by Standard & Poor's or Baa or higher by Moody's Investment Services; and

(c) For a reasonable time, not to exceed 60 days, the Trustee is authorized to hold uninvested cash,

awaiting investment or distribution, without liability for the payment of interest thereon.

Section 7. Commingling and Investment. The Trustee is expressly authorized in its discretion:

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(a) To transfer from time to time any or all of the assets of the Fund to any common, commingled, or

collective trust fund created by the Trustee in which the Fund is eligible to participate, subject to all

of the provisions thereof, to be commingled with the assets of other trusts participating therein; and

(b) To purchase shares in any investment company registered under the Investment Company Act of

1940 (15 U.S.C. 80a-1 et seq.), including one that may be created, managed, underwritten, or to

which investment advice is rendered, or the shares of which are sold by the Trustee. The Trustee

may vote such shares in its discretion.

Section 8. Express Powers of Trustee. Without in any way limiting the powers and discretion conferred

upon the Trustee by the other provisions of this Agreement or by law, the Trustee is expressly authorized

and empowered:

(a) To sell, exchange, convey, transfer, or otherwise dispose of any property held by it, by public or

private sale, as necessary to allow duly authorized withdrawals at the joint request of the Grantor

and NRC or to reinvest in securities at the direction of the Grantor;

(b) To make, execute, acknowledge, and deliver any and all documents of transfer and conveyance and

any and all other instruments that may be necessary or appropriate to carry out the powers herein

granted;

(c) To register any securities held in the Fund in its own name, or in the name of a nominee, and to

hold any security in bearer form or in book entry, or to combine certificates representing such

securities with certificates of the same issue held by the Trustee in other fiduciary capacities, to

reinvest interest payments and funds from matured and redeemed instruments, to file proper forms

concerning securities held in the Fund in a timely fashion with appropriate government agencies, or

to deposit or arrange for the deposit of such securities in a qualified central depository even though,

when so deposited, such securities may be merged and held in bulk in the name of the nominee or

such depository with other securities deposited therein by another person, or to deposit or arrange

for the deposit of any securities issued by the U.S. Government, or any agency or instrumentality

thereof, with a Federal Reserve Bank, but the books and records of the Trustee shall at all times

show that all such securities are part of the Fund;

(d) To deposit any cash in the Fund in interest-bearing accounts maintained or savings certificates

issued by the Trustee, in its separate corporate capacity, or in any other banking institution

affiliated with the Trustee, to the extent insured by an agency of the Federal government; and

(e) To compromise or otherwise adjust all claims in favor of or against the Fund.

Section 9. Taxes and Expenses. All taxes of any kind that may be assessed or levied against or in respect

of the Fund and all brokerage commissions incurred by the Fund shall be paid from the Fund. All other

expenses incurred by the Trustee in connection with the administration of this Trust, including fees for

legal services rendered to the Trustee, the compensation of the Trustee to the extent not paid directly by

the Grantor, and all other proper charges and disbursements of the Trustee shall be paid from the Fund.

Section 10. Annual Valuation. After payment has been made into this standby trust fund, the Trustee shall

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annually, at least 30 days before the anniversary date of receipt of payment into the standby trust fund,

furnish to the Grantor and to NRC a statement confirming the value of the Trust. Any securities in the

Fund shall be valued at market value as of no more than 60 days before the anniversary date of the

establishment of the Fund. The failure of the Grantor to object in writing to the Trustee within 90 days

after the statement has been furnished to the Grantor and NRC shall constitute a conclusively binding

assent by the Grantor, barring the Grantor from asserting any claim or liability against the Trustee with

respect to the matters disclosed in the statement.

Section 11. Advice of Counsel. The Trustee may from time to time consult with counsel with respect to

any question arising as to the construction of this Agreement or any action to be taken hereunder. The

Trustee shall be fully protected, to the extent permitted by law, in acting on the advice of counsel.

Section 12. Trustee Compensation. The Trustee shall be entitled to reasonable compensation for its

services as agreed upon in writing with the Grantor. (See Schedule C.)

Section 13. Successor Trustee. Upon 90 days notice to NRC and the Grantor, the Trustee may resign;

upon 90 days notice to NRC and the Trustee, the Grantor may replace the Trustee; but such resignation or

replacement shall not be effective until the Grantor has appointed a successor Trustee, the successor

accepts the appointment, the successor is ready to assume its duties as trustee, and NRC has agreed, in

writing, that the successor is an appropriate Federal or State government agency or an entity that has the

authority to act as a trustee and whose trust operations are regulated and examined by a Federal or State

agency. The successor Trustee shall have the same powers and duties as those conferred upon the Trustee

hereunder. When the resignation or replacement is effective, the Trustee shall assign, transfer, and pay

over to the successor Trustee the funds and properties then constituting the Fund. If for any reason the

Grantor cannot or does not act in the event of the resignation of the Trustee, the Trustee may apply to a

court of competent jurisdiction for the appointment of a successor Trustee or for instructions. The

successor Trustee shall specify the date on which it assumes administration of the trust, in a writing sent

to the Grantor, NRC, and the present Trustee, by certified mail 10 days before such change becomes

effective. Any expenses incurred by the Trustee as a result of any of the acts contemplated by this section

shall be paid as provided in Section 9.

Section 14. Instructions to the Trustee. All orders, requests, and instructions by the Grantor to the Trustee

shall be in writing, signed by such persons as are signatories to this Agreement or such other designees as

the Grantor may designate in writing. The Trustee shall be fully protected in acting without inquiry in

accordance with the Grantor's orders, requests, and instructions. IfNRC issues orders, requests, or

instructions to the Trustee these shall be in writing, signed by NRC or its designees, and the Trustee shall

act and shall be fully protected in acting in accordance with such orders, requests, and instructions. The

Trustee shall have the right to assume, in the absence of written notice to the contrary, that no event

constituting a change or a termination of the authority of any person to act on behalf of the Grantor or

NRC hereunder has occurred. The Trustee shall have no duty to act in the absence of such orders,

requests, and instructions from the Grantor and/or NRC, except as provided for herein.

Section 15. Amendment of Agreement. This Agreement may be amended by an instrument in writing

executed by the Grantor, the Trustee, and NRC, or by the Trustee and NRC if the Grantor ceases to exist.

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All amendments shall meet the relevant regulatory requirements of NRC.

Section 16. Irrevocability and Termination. Subject to the right of the parties to amend this Agreement as

provided in Section 15, this trust shall be irrevocable and shall continue until terminated at the written

agreement of the Grantor, the Trustee, and NRC, or by the Trustee and NRC if the Grantor ceases to exist.

Upon termination of the trust, all remaining trust property, less final trust administration expenses, shall

be delivered to the Grantor or its successor.

Section 17. Immunity and Indemnification. The Trustee shall not incur personal liability of any nature in

connection with any act or omission, made in good faith, in the administration of this trust, or in carrying

out any directions by the Grantor or NRC issued in accordance with this Agreement. The Trustee shall be

indemnified and saved harmless by the Grantor or from the trust fund, or both, from and against any

personal liability to which the Trustee may be subjected by reason of any act or conduct in its official

capacity, including all expenses reasonably incurred in its defense in the event the Grantor fails to provide

such defense.

Section 18. This Agreement shall be administered, construed, and enforced according to the laws of the

State of New Mexico.

Section 19. Interpretation and Severability. As used in this Agreement, words in the singular include the

plural and words in the plural include the singular. The descriptive headings for each section of this

Agreement shall not affect the interpretation or the legal efficacy of this Agreement. If any part of this

Agreement is invalid, it shall not affect the remaining provisions which will remain valid and enforceable.

IN WITNESS WHEREOF the parties have caused this Agreement to be executed by the respective

officers duly authorized and the incorporate seals to be hereunto affixed and attested as of the date first

written above.

International Isotopes Inc

[Signature of representative of Grantor]

[Title]

ATTEST:

[Title]

[Seal]

[Insert name and address of Trustee]

[Signature of representative of Trustee]

[Title]

ATTEST:

[Title]

[Seal]

Financial Assurance RAIs Page 126
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAls

Schedule A

This Agreement demonstrates financial assurance for the following cost estimates or prescribed amounts

for the following licensed activities:

U.S. NUCLEAR NAME AND ADDRESS OF COST ESTIMATES

REGULATORY ADDRESS OF LICENSED FOR REGULATORY

COMMISSION LICENSEE ACTIVITY ASSURANCES

LICENSE DEMONSTRATED

NUMBER(S) BY THIS

AGREEMENT

The cost estimates listed here were last adjusted and approved by NRC on.

Schedule B

AMOUNT:

AS EVIDENCED BY:

Schedule C

[Insert name, address, and phone number of Trustee.]

Trustee's fees shall be: per year.

Financial Assurance RAls Page 127
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAls

TABLE 10-1 DUF 4 PROCESS AND DUF 6 AUTOCLAVE BUILDING COMPONENTS

Total Total Volume for

Corponent Nurher Component Non-LLWVolume for

of oCopnns Components VCorponent Volume Volume RdcinDisposal After Nosal LLW Disposal

Reduction

EQUIPMENT/MATERIALS

DUF,; to DUF 4 Process Autoclaves 2 1130 1130 1130 0

Condensate Holdingt Tank 2 184 184 184 0

Refrigeration System for AHF Condensers 1. 240 240 240 0

20 Ton Bridge Crane Hoist 1 18 18 18 0

20 Ton Bridge Crane 1 360 360 360 0

201 Ton Bridge Crane Rails 2 150 150 150 0

3 Ton Monorail 1 8 8 8 0

Cylinder Cart 2 300 300 300 0

Cylinder Scale 1 150 150 150 0

Autoclave Hydraulic Pump System 2 96 96 196 0

DUF 6 Analyzer 1 2 2 0 2

DUF 6 Piping Autoclave to Surge Tank 2 25 25 0 25

DUF 6 Piping Surge Tank to Reaction Vessel I 6 6 0 6

Steam Piping from Boiler to AC 2 156 156 156 0

Condensate Return Piping 2 7 7 7 0

Autoclave Relief Piping 2 75 75 75 0

Heeling Cold Traps 2 1130 1130 1130 0

DUF. Vacuum Transfer System to FEP Facility 1 36 36 0 36

Transfer Piping DUF4 Storage Hoppers to Surge Hopper 1 113 113 113 0

P & E Cold Traps 85 85 0 85

P & E NaF (Sodium Fluoride Packing) Traps 3 32 32 0 32

P & E Activated Alumina Traps 3 32 32 0 32

Vacuum Pump 1 18 18 0 18

Vibrating Screen 1 67 67 0 67

DUF 4 Product Storage Bins 3 2526 842 0 842

Storage Bin Rotary Valves 3 43 43 0 43

Drum Fill Station 3 432 432 0 432

Fill Station Piping I 6 6 0 6

Reaction Vessel Cooling Screw Conveyor 1 5 0 5

Financial Assurance RAls Page 126
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

• • ~Total :' Number Total Toten Volume for Volumefor

Component Component Non-LLW Dispos

of Components Com e Volume After Disposal LLW Disposal

Volume__ __ __ __Reduction Disosal

Cooling Screw Conveyor Water Jacket 2 8 8 8 0

Cooling Screw Off Gas Plenumn 1 4 4 0 4

DUF4 Product Screw Conveyor 1 5 5 0 5

Partial HF Condenser 2 59 59 59 0

Total HF Condenser 2 15 15 15 0

Primary Filter - Off Gas Cyclone 1 50 50 0 50

Primary Filter - Sintered Filter Elements 1 46 46 0 46

Cyclone Filter Rotary Valve 2 29 29 0 29

Secondary Off Gas Filter with Sintered Filter Elements 1 46 46 0 46

Backup Filter Rotary Valve 1 14 14 0 14

Carbon-Bed Traps 6 125 125 0 125

Reaction Vessel Heaters 8 157 157 157 0

DUF 6 Surge Tank 1 38 38 0 38

Surge Tank/Feed Piping Hot Box Electric Heaters 1 II I I I1 0

Surge Tank/Fee [lot Box 1 79 79 79 0

Hydrogen Supply System 1 384 384 384 0

Hydrogen Surge Tank 1 33 333 331 0

DUFo to DUjF 4 Reaction Vessel 1 29 29 0 29

Hydrogen Burner 1 55 55 55 0

Primary Dust Collector 1 2280 912 0 912

Primary Dust Collector Rotary Valve 1 14 14 0 14

Secondary Dust Collector 1 588 235 0 235

Dust Collector Blower _ 216 216 0 216

Reaction Vessel Cooling Blower 1 36 36 0 36

Vacuum Cleaning Blower 1 36 36 0 36

Piping froom Screw Conveyor to Dust Collectors 1 56 56 0 56

Piping from DUF4 FEP Feed Hopper to Vacuum Pump 1 31 31 0 31

Oxide Inventory Pending Shipment After Shutdown 1 1350 1350 0 1350

Oxide Work-In-Process Residual 1 460 460 0 460

DUF4 Work-In-Process Residual 1 800 800 0 800

Carbon & Activated Alumina Residual In Process 1 150 150 0 150

Financial Assurance RAIs Page 127
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

Total TotalVolume for

Number Component Volum Volume for Component ofNuomponens Component Volume After Non-LLW LLW Disposal ofVolume Reduction Disposal

Ventilation Ducting firom Table 10-6:

DUF 6 Autoclave Room HVAC Ducting 1 432 144 0 144

DUF4 Process Building HVAC Ducting 1 1296 432 0 432

AHF Storage Tanks 4 980 980 980 0

AlIF Transfer System (pump, piping & hoses) 1 80 80 80 0

DUF6 in Cylinders in Average Inventory Waiting to be Approximately Assuhpe would be

Procssed125.00k2shipped & processed at

Processed I125,000kg another facility.

Would be shipped to

AHF as Work-in-Process & Storage Waiting to be Shipped Approximately AHF customer. Added

18,000kg, transportation cost to

DFP.

Would be shipped to

CaF2 as Material-in-Process & Storage Awaiting Approximately AHF customer. Added

Shipment to Customer 20,000kg transportation cost to

DFP.

ApprximaelyWould ship to vendor or

Regenerated KOH Solution Residual In Process Approximately user FOB for transport

7.k •cost.

Included in Storage Tanks Equipment List

Storage Areas Included in

Buildings

Radiological Waste Areas Included in

Buildings

Equipment Decontamination Areas See Table 10-2

TOTAL NON-LLW DISPOSAL 5,978

TOTAL LLW DISPOSAL 6,889

Financial Assurance RAIs Page 128
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

TABLE 10-2 DECONTAMINATION BUILDING AND LABORATORY COMPONENTS

Number of Total Total Component Volume for Volume for

Component Components Component Volume After Non-LLW LLW Disposal

Volume Reduction Disposal

EQUIPMENT/MATERIALS

Fume Cupboards (hoods) 4 80 80 0 80

Floors (concrete/dike demolition) 1 1000 1000 0 1000 Walls And Ceilings (building demolition) 1 1000 1000 1000 0

Grit Blast Booth/Equipment 1 1998 666 0 666

Dust Collector 1 588 235 0 235

Hold Tank 2 560 187 0 187

Precipitation Tank 1 279 93 0 93

Centrifugal Pumps 4 7 7 0 7

Water Spray Submersible Pump 1 2 2 0 2

Secondary Dust Collector 1 96 38 0 38

Drum Fill Station 2 288 288 0 288

Dust Collector Blower 1 71 71 0 71

Primary Filters 2 151 151 0 151

Polishing Filters 4 170 170 0 170

Ion Exchange Columns 2 141 141 0 141

Decontamination Building Piping 1 19 19 0 19

Motors 5 9 9 0 9

Misc Conduit, Instruments, Control Panel 1 20 20 0 20

Cleaning Solution Waste 1 1875 1875 0 1875

Hazardous Waste 1 750 750 0 750

Ventilation Ducting from Table 10-6:

Decontamination Ducting 1 78 26 0 26

Laboratory HVAC Ducting 1 78 26 0 26

TOTAL NON-LLW 1,000

TOTAL LLW 5,854

Financial Assurance RAIs Page 129
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAls

TABLE 10-3 FEP PROCESS BUILDING COMPONENTS FOR SIF 4 PROCESS

Number of Total Total Volume for Volume for

Component Components Component Component Non-LLW LLW Disposal

Volume Volume After Disposal

Reduction

EQUIPMENT/MATERIALS

Si02 Storage 1 785 0 785 0

Oxide Hopper 1 306 102 0 102

Oxide Hopper Rotary Valves 1 14 14 0 14

Drum Filling Enclosure 1 49 49 0 49

Piping from Oxide Hopper to Dust Collector 1 28 28 0 28

Piping for Drum Station 1 5 5 0 5

Calciner Inlet Conveyor 1 2 2 0 2

Rotary Calciner 1 66 66 0 66

Cooling Screw Conveyor 1 3 3 0 3

Cooling Screw Conveyor Water Jacket 1 5 5 5 0

DUF 4 Feed Hopper 1 21 21 0 21

DUF 4 Hopper Rotary Valves 1 14 14 0 14

DUF,4 Gate-Lock Hopper 1 1 1 0 1

DUF•; Hopper Vacuum Filter/Receiver 1 3 3 0 3

Piping from DUF4 Hopper to Dust Collector 1 28 28 0 28

Vacuum Secondary Filter, Pump & Discharge Silencer 1 1 0

Si0 2 Feed Hopper 1 21 21 21 0

SiO2 Hopper Rotary Valves 1 14 14 14 0

DUF4 Screw Conveyor 1 1 I 0 1

SiO, Screw Conveyor 1 1 0 1

Ribbon Blender 1 29 29 0 29

Financial Assurance RAIs Page 1 30
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

Number of Total Total Volume for Volume for

Component Components Component Component Non-LLW LLW Disposal

Volume Volume After Disposal

Reduction

Vibrating Screen 1 94 94 0 94

Pre Filter 1 42 42 0 42

Dust Collector & Blower 1 2280 1026 0 1026

Primary Dust Collector Rotary Valve 1 14 14 0 14

Secondary Dust Collector & Blower 1 215 86 0 86

Backup Dust Collector Rotary Valve 1 14 14 0 14

Backup D)ust Collector Drum Enclosure 1 49 49 0 49

Primary & Secondary Sintered Metal Filter 4 13 13 0 13

Pre-Condenser 2 1 1 1 0

Product Cold Traps 3 1 1 1 0

SiF 4 Compressor 1 67 67 67 0

Chiller 1 30 30 30 0

Separator 1 _33 33 33 0

Heat Exchanger 1 30 30 30 0

Nash Vacuum Pump 1 18 18 18 0

SiF 4 Storage Tanks 3 377 377 377 0

SiF 4 Cylinder Fill Manifold & Containment 1 67 67 67 0

SiF 4 Dump Tank 1 126 126 126 0

Venturi Scrubber Downstream of DUF4 Dust Collector I 50 50 0 50

Blowers

Venturi Scrubber Downstream of SiF.4 Dust Collector 1 50 50 0 50

Blowers

Venturi Scrubber KOH Pumps for SiF 4 Dust Collector 1 50 50 0

Blowers

Ventilation Ducting friom Table 10-6:

HVAC Ducting 1 1,728 576 0 576

Financial Assurance RAIs Page 131
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

Number Nube of f Total' Total Volume for Volume'for

Component Component Component Non-LLW LLW Disposal CtComponents Volume Volume After Disposal

Reduction

Most i r Package

AMotte 'hdv in remaining

SiF4 Work-In-Process And Storage pproximat ah'e inventorv and 22,000 kg customer ship to

cylinders, customer,

Storage Areas Included in

Buildings

Radiological Waste Areas Included in

Buildings___________

Equipment Decontamination Areas See Table 10-2

TOTAL NON-LLW 1,574

TOTAL LLW 2,435

Financial Assurance RAIs Page 132
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

TABLE 10-4 FEP PROCESS BUILDING COMPONENTS FOR BF 3 PROCESS

Total Volume for

Component Number of Component Component NVolume for Components, Volume After Non-LLW LLW Disposal

Volume Reduction Disposal

EQUIPMENT/MATERIALS

B 20 3 Storage 1 785 785 785 0

Oxide Hopper 1 306 102 0 102

Oxide Hopper Rotary Valves 2 29 29 0 29

Drum Filling Enclosure 2 98 98 0 98

Dust Collector Blower 1 220 220 0 220

Piping from Oxide Hopper to Dust Collector 2 56 56 0 56

Piping from Drum Fill Station 2 18 18 0 18

P & E Chew Traps 4 42 42 42 0

P & E Vacuum Pump 2 36 36 36 0

Pre-Heater Feed Screw 2 4 4 0 4

Pre-Hleater 2 25 25 0 25

Rotary Calciner Feed Screw 2 4 4 0 4

Rotary Calciner 1 66 66 0 66

Cooling Screw Conveyor 1 3 3 0 3

Cooling Screw Conveyor Water Jacket 1 5 5 5 0

DUF 4 Feed Hopper 2 42 42 0 42

DUF 4 Hopper Rotary Valves 4 57 57 0 57

DUF 4 Gate-Lock Hopper I 1 1 0 1

DU F4 1 Hopper Vacuum Filter/Receiver 1 3 3 0 3

Piping DUF4 Hopper to Dust Collector 1 28 28 0 28

Financial Assurance RAIs Page l133
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

Total'• Total Volume for Volume for

Number of Ttl Component Vlm o Component Compen Component Non-LLW Volume Volume After Disposal LLW Disposal

Reduction

Vacuum Secondary Filter, Pump & Discharge 2 3 0 3

Silencer

B2 0- Feed Hopper 2 42 42 42 0

B203 Hopper Rotary Valves 4 57 57 57 0

DUF4 Screw Conveyor 2 1 1 0 1

B203 Screw Conveyor 2 1 1 0 1

Ribbon Blender 2 59 59 0 59

Vibrating Screen 2 189 189 0 189

Dust Collector 1 2280 912 0 912

Primary Dust Collector Rotary Valve 1 14 14 0 14

Backup Secondary Dust Collector 1 215 86 0 86

Backup Dust Collector Rotary Valve 1 14 14 0 14

Backup Dust Collector Drum Enclosure 1 49 49 0 49

Product Cold Traps 1 49 49 0 49

Primary & Secondary Sintered Metal Filters 2 7 7 0 7

Pre-Condenser 2 1 1 1 0

Cold Traps 4 1 1 1 0

BF 3 Compressor 2 133 133 133 0

Chiller 2 60 60 60 0

Separator 2 66 66 66 0

Financial Assurance RAIs Page 134
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAls

TotalTotal

Number of Total Component Volume for Volume for Component Component Colmoenft Non-LLW Components Volume After LLW-Disposal Volume Reduction Disposal

BF- Storage Tank & Dump Tank 26 3268 3268 3268 0

Venturi Scrubber Downstream of DUF 4 Dust 1 50 50 0 50

Collector Blower

Venturi Scrubber Downstream of BF3 Dust Collector

Blower 50 50 50

Ventilation Ducting from Table 10-6:

HVAC Ducting 1728 576 576

Most

A i- it inventory Package remaining BF3 Work-In-Process And Storage pproximaey already in inventory and ship 8,000kg customer to customer.

cylinders.

Included in

Storage Areas Building

Radiological Waste Areas included in

Building_

Equipment Decontamination Areas See Table 10-2

TOTAL NON-LLW 4,497

TOTAL LLW 2,768

Financial Assurance RAIs Page 135
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAls

TABLE 10-5 EPP FACILITY COMPONENTS

Total Total Vomf

ComponentNumber of Component Component Volume for Volume for

Components Volume Volume Red After Non-LLW Disposal LLW Disposal j.fo ::: ..

Reduction

EQ U IPMENT/MATE RIALS

Venturi Scrubber 2 101 101 0 101

Venturi Scrubber Liquid/Gas Separator 2 101 101 0 101

Venturi Scrubber Water Pump 2 4 4 0 4

Packed Tower Scrubber 2 32 32 0 32

Tower Scrubber KOH Pump 2 4 4 0 4

Coke Box 2 266 266 0 266

Coke Box KOH Sump Pump 2 4 4 0 4

Coke Box Blower 2 43 43 0 43

Emergency Scrubber 1 59 59 59 0

Emergencv Scrubber KOH Sump Pump 1 8 8 8 0

Emergency Scrubber KOH Pump 1 2 2 2 0

Emergency Scrubber Blower 1 21 21 21 0

KOH Makeup Tank 1 127 127 127 0

KOH Makeup Tank Pump 1 2 2 2 0

Acid Transfer Tank 1 1008 1008 1008 0

Lime Mixer Tanks and Agitators 2 71 71. 71 0

Lime Mixer Tanks Pumps 2 4 4 4 0

Acid Reaction Tank and Agitators 1 996 996 996 0

Acid Reaction Tank Punps 2 4 4 4 0

Thickener 1 168 168 168 0

Thickener Pumps 3 5 5 5 0

Emergency Acid Tank 1 7360 3680 3680 0

Lime Silo and Dust Collector 1 2276 1138 1138 0

Financial Assurance RAIs Page 136
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

Total ITotal

Component Number of Component Component Volume for Volume for

Components Volume After Non-LLW Disposal L-LW Disposal Volume Reduction

Spent KOH Storage Tank 1 384 192 192 0

KOH Mixing Tank and Agitators 1 35 35 35 0

KOH Mixing Tank Pumps 2 4 4 4 0

KOH Reaction Vessel Pumps 2 4 4 4 0

Thickener and Rake 1 127 127 127 0

Rotary Vacuum Filter 1 168 168 168 0

Filtrate Liquor Tanks 2 56 56 56 0

Dryer 1 192 192 192 0

Dust Collector 1 2253 751 751 0

Clarifier and Rake 1 2202 734 734 0

Clarifier Pumps 3 5 5 5 0

Polishing Filters 2 4 4 4 0

Piping 1 156 156 156 0

HVAC Ducting 1 93 93 93 0

KOH Regeneration Tank 1 385 385 385 0

KOH Reactor Tank 1 754 377 377 0

Lime Silo 1 4620 4620 4620 0

Ventilation Ducting from Table 10-6:

EPP HVAC Ducting 1 279 93 0 93

Lime Storage Shed Ducting 1 100 33 33 0

See Table 10-

Equipment Decontamination Areas S b

TOTAL NON-LLW 15,228

TOTAL LLW 648

Financial Assurance RAIs Page 137
Enclosure 1 JJM-2011-30 I April 29, 2011

Official Response to Financial Assurance RAls

TABLE 10-6 FACILITY COMPONENTS - VENTILATION

Total

Total Volume for

Component Number of Component Component Non-LLW Volume for

Components Volume Volume After Disposal LLW Disposal

Reduction

VENTILATION AND DUCTWORK

Fume Cupboards (hoods) 4 240 80 0 80

Laboratory 1 78 26 0 26

l)UF, Autoclave Area 1 432 144 0 144

DUF 4 Process Building 1 1296 432 0 432

Contamination Building 1 78 26 0 26

SiF 4 Building 1 1728 576 0 576

BF 3 Building 1 1728 576 0 576

EPP Building 1 279 93 0 93

Lime Storage Area 1 100 33 3.3.3 0

NOTE: LL\V and Non-LLW disposal amounts in Table 10-6 are included in each of the building lists in 'Fables 10-1 through 10-5.

Financial Assurance RAIs Page 138
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

TABLE 10-7 PLANNING AND PREPARING (LABOR HOURS)

Project Health Physicist

& Engineer Clerical Management Safety Officer

Project Plan and Schedule 320 40 160 65

Site Characterization Plan 400 150 200 94

Decommissioning Plan 1800 675 900 422

NRC Review Support 600 225 300 141

Specification for Services 400 150 200 94

Project Procedures 720 270 360 169

TOTAL ,HOURS 4240 1510 2120 984

HOURI.Y RATE $77 $84 $79 $23

TOTAL $326,480 $126,840 $167,480 $22,632.

LABOR $643,432

AI)MINISTRATIVE SUPPLIES $1,200

GRAND TOTAL $644,632

Financial Assurance RAIs Page 139
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

TABLE 10-8 FACILITY CHARACTERIZATION

Area Project Health Physicist Health Physics Management Safety Off Technician

DUF 6 Autoclave Room 9 9 73 11

DUF 4 Process Building 19 19 145 23

Decontamination Building 6 6 48 7

FEP Process Building 23 23 186 29

HF Day Tank and Truck Loading Building 6 6 42 6

Maintenance and Stores 3 3 25 4

EPP Building and Scrubber Systems 6 6 51 8

Lime Storage Shed 1 1 7 1

Material Warehouse 5 5 42 6

Utilities Building 3 3 25 4

Main Switchgear Building 3 3 25 4

Fire Pump House 0 0 2 0

Water Treatment Building 1 I 6 1

Process Offices and Laboratories 3 3 26 4

Administration Building 5 5 38 6

Guard house 1 1 5 1

DUF 4 Storage Building 3 3 25 4

Exterior of Buildings 46 46 372 58

TOTAL HOURS 143 143 1143 177

HOURLY RATE $77 $84 $64 $23

LABOR COST $11,011 S12,012 $73,152 S4,071

TOTAL LABOR COST $100,246

ADMINISTRATIVE SUPPLIES $1,900

GRAND TOTAL $102,146

Financial Assurance RAIs Page 1 40
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

TABLE 10-9 DISMANTLING AND DECONTAMINATION

• • ,,":~~ ~~Project ... .. •P I' ll y iCist',::i::: : .. :. . ...... • i e •i•

Area Project Laborer Croaftsman 11 elSupervisorth -Pics , tw gi Clerical .Managenment, & ,-;ipe-v i&6r :Physics E.g.

S .. . Safety : :, . ThnRIic TC i.n ner Ck)a -

< Officer<

DUF,. Autoclave Room 3 13 626 2502 626 626 275 20 120

DUF 4 Process Building 322 646 2581 646 646 382 100 134

Decontamination 638 1276 5104 1276 1276 508 0 239

Buil1ding

FEP Process Building 502 1004 4016 1004 1004 477 80 198

HF Day Tank and

Truck Loading Building 11 22 87 22 2 11l 20 7

EPP Building 298 595 2382 595 595 268 0 112

Lime Storage Shed 45 89 357 89 89 36 0 17

DUF 4 Storage Building 5 10 40 10 10 10 0 3

TOTAL HOURS 2134 4268 17069 4268 4268 1967 220 830

HOURLY RATE $77 $84 $26 $38 $67 $64 $79 $23

LABOR COST $164,318 $358,512 $443,794 $162,184 $285,956 $125,888 $17,380 $19,090

TOTAL LABOR $1,577,122

COST $1___7__22

ADMINISTRAkTIVE S256,500.

SUPPLIES $256,500.

GRAND TOTAL $1,833,622

Financial Assurance RAIs Page 141
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

Table 10-10 RESTORATION OF CONTAMINATED AREAS ON FACILITY GROUNDS (LABOR HOURS)

Labor Labor Labor Labor Labor

Activity Category Category Category Category Category

Backfill and Restore Site (Note 1)

Note 1: The facility is designed to contain and prevent contamination outside the equipment and building areas and the

controlled containment areas; including measures of ALARA radiological controls that will result in a low likelihood

of contaminating the facility grounds at levels that would require excavation or restoration. In the event of a small

spill, the limited area affected will be cleaned, surveyed and decontaminated, if needed, at the time as part of the

required cleanup immediately following any such spill.

Financial Assurance RAIs Page 1 42
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAls

TABLE 10-11 FINAL RADIATION SURVEY (LABOR HOURS)

Project Health Physicist Health Physics e& Technician

Area Management Safety Officer

DUF6 Autoclave Room 13 13 102 16

DUF 4 Process Building 25 25 197 31

Decontamination Building 3 3 23 4

FEP Process Building 27 27 215 34

HF Day Tank and Truck Loading Building 2 2 21 3

Maintenance and Stores Building 2 2 16 2

EPP and Plant KOH Scrubbing System Buildings 1 1 8 1

Lime Storage Shed 0 0 1 0

Material Warehouse Building 3 3 25 4

Utilities Building 2 2 14 2

Main Switchgear Building 2 2 14 2

Fire Pump House 0 0 1 0

Water Treatment Building 0 0 4 1

Process Offices and Laboratory Building 5 5 43 7

Administrative Building 3 27 4

Guard House 1 1 4 1

DUE 4 Storage Building 2 2 14 2

Building Perimeter Sampling 5 5 68 10

Grid Sampling 5 30 10

Date Evaluation 70 370 70 64

Close-Out Radiological Survey Report 90 280 40 51

i + +

Financial Assurance RAIs Page 1 43
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

Project Health Physicist Health Physics

Area Projectn& HethPics Clerical

Area Management Safety Officer Technician

TOTAL HOURS 261 751 937 249

HOURLY RATE $77 $84 $64 $23

LABOR COST $20,097 $63,084 $59,968 $5,727

TOTAL LABOR COST $148,876

ADMINISTRATIVE SUPPLIES $4,680

SAMPLE ANALYSIS @.250 $32,750

GRAND TOTAL $186,306

Financial Assurance RAIs Page 144
Enclosure 1 JJM-2011-30

Official Response to Financial Assurance RAIs

TABLE 10-12 SITE STABILIZATION AND LONG TERM SURVEILLANCE (LABOR HOURS)

AciiyLabor Labor Labor Labor Labor Category Category Category Category Category

(Note 2)

Note 2: The facility is designed to contain and prevent contamination outside the equipment and building areas and the controlled containment areas;

including measures of radiological ALARA controls that will result in a low likelihood of contaminating the facility grounds at levels that would

require excavation or restoration. In the event of a small spill, the limited area affected will be cleaned, surveyed, and decontaminated, if needed,

as part of the required cleanup immediately following any such spill. Therefore, site stabilization and long-term surveillance will not be required

and associated decommissioning costs are not provided.

April 29, 2011

Financial Assurance RAIs Page 1 45
Enclosure 1 JJM-2011-30 April 29, 2011

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TABLE 10-13 TOTAL WORK DAYS BY LABOR CATEGORY (LABOR DAYS)

Health iei:i: :

Proect Physicist Het

STas & 'Laborer : Craftsmint 1• Superlisor Physics Engieer Clerical

~Saley C V11CII S 

Planning and Preparation 530 189 0 0 0 0 265 123

Facility Characterization 18 18 0 0 0 143 0 22

Decontamination & 267 534 2134 534 534 246 28 104

Dismantling

Restoration of

Contaminated Areas

(Note 1)

Packaging 0 0 1778 0 593 593 593 0

Final Survey 33 94 0 0 0 117 0 31

Site Stabilization & Long

Term Surveillance

(Note 1)

TOTAL WORK DAYS 848 835 3,912 534 1,127 1,099 886 280

NOTE 1: The facility is designed to contain and prevent contamination outside the equipment and building areas and the controlled containment area- including measures of

ALARA radiologieal controls that will result in a low likelihood of contaminating the facility grounds at levels that would require excavation or restoration. In the event of a small

spill, the limited area afTected will be cleaned. surveved and decontaminated, if needed, at the time as pail of the required cleanup immediately lbllowing any such spill.

Financial Assurance RAIs Page 1 46
Enclosure 1 JJM-2011-30 April 29, 2011

Official Response to Financial Assurance RAIs

TABLE 10-14 WORKER UNIT COST SCH EDUILE

Project Health PhVsici st>Ifeth

Mnenet& §Laborer Craftsman Supervisor 1Ph'VSics v ný,ineer J Clerical

Safety Officer~ Techniician

Salary &

Fringe $83,900 $92,243 $28.808 $41 811 S72,832 $70.000 $86,609 $25.530

(S/year)

Fringe at 30% $25.170 $27.673 $42 $12.543 $21.850 $21,000 $25.983 $7,659

Rate

Overhead at 60% vrate $50,340 $55346 $17,285 $25,087 $41,699 S4Z0 $15,318

Total Cost per S159.410 $175,262 $54,735 $79.441 $138,381 $133.000 $164J557 S48,507

Year

Total Cost per S613 $674 $211 $306 $532 $512 $633 $187

Work Dav y _ _

Hourly Rate $77 $84 S26 $38 $67 $64 $79 $23

* Based on 2,080 work hours per year and 8 hours per working day.

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Official Response to Financial Assurance RAIs

TABLE 10-15 TOTAL LABOR BY MAJOR DECOMMISSIONING TASK

Health

Project Physicist D I eaItit

Task Mai.ee &S Laborer Craftsman Supleric str Py.-sics Eagineer ~i Clerical

SafeivTechniician

,Officer~

Planning and Preparation $326,480. $126,840. $-0- $-0- S0- $-0- $167 480 $22.632

Facility Characterization $11,011 $12.012 $-0- $-0- S-0- $7,52 $0 $4.071

Decontamination& $164.318 $338.512 S443.794 S162.184 $285.956 S 5888 $17,380 $19,090 Dismantling ______"__ _"_

Restoration of

Contaminated Areas (Note I1)

Packaging 0 0 $369.720 0 $317,580 S$ 3360 S374.460 $0

Final Survey $20U097 $63.084 $-0- $-0- S-0- $5968 $0 S5.727

Site Stabilization & Long

Term Surveillance (Note 1)

TOTAL COST S521,906 $560.448 $813,514 $162,184 $603,536 $56ý2368 $599,320 $51,520

Note 1: The facility is designed to contain and prevent contamination outside the equipment and building areas and the controlled containment area: including measures of

ALARA radiological controls that will result in a low likelihood of contamrinating the facility grounds at levels that would require excavation or restoration. In the event of a small

spill, the limited area affected will be cleaned, surveyed and decontaminated, if needed, al the time as part ofthe required cleanup immediately following any such spill.

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Official Response to Financial Assurance RAIs

TABLE 10-16 PACKAGING, SHIPPING AND DISPOSAI OF RADIOACTIVE WASTES (SEE FOOTNOTE)

Volume of LLW Packaging LLW Disposal Transportation Areas (Cubic Feet) Cost Cost Cost

DUF6 Autoclave RoorniDUF. Process/HF Day Tank

Building.s $177,109 $1.650,920 $330.184

Decontamination Building and Laboratory 5.854 $106,53 $1.205.396 $241,079

FEP Buildin!4 50 $195,612 $ .192,377 $238,475

EPP Buildins- and Lime Storase Shed 648 $97,502 $152,578 $30.516

TOTAL VOLUME 18,594

SHIPMENT OF REMAINING DUF 6 $55,000

TOTAL COST $576,976 S4,201,271 $895,254

PACKAGING SUPPLIES $120,000

TRANSPORTATION SUPPLIES $40,000

LLW PACKAGING TOTAL $696,976

LLW TRANSPORTATION TOTAL $935,254

LLW DISPOSAl, TOTAL $4,201,271

GRAND TOTAL $5,833,501.

NOTE: Packaging. Disposal and Transportation costs for Non-LLW wastes are not shown in this Table. but are included in Table 10-18.

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Official Response to Financial Assurance RAIs

TABLE 10-17 TOTAL ADMINISTRATIVE SUPPLIES BY MAJOR DECOMMISSIONING TASK

Task Equipmernt Cost

Planning and Preparation $1.200.

Facility Characterization $1,900.

Decontamination and Dismantling $256,500.

Packaging $300,000.

Transportation $100,000.

Final Survey $4,680.

TOTAL S664,280.

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Official Response to Financial Assurance RAIs

TABLE 10-18 TOTAL DECOMMISSIONING COST

Task Estimated .... Base Cost With 12%. , . .argin For Totl C t

-, . COSt Third Parv Contractor , With ....... genc+ ....

Planning and Preparation $644,632 $72 1988. $902_485

Facility Characterization S102,146 $114,404 $143,005

Decontamination and [)ismantling S 1,833,622 $2,053,657 $2,567,071

Restoration of Contaminated Areas (Note 1)

Sizing and Packaging $1,665,120 $1,864,934 $2.331,168

Transportation and Disposal $5,290,578 $5,290,578 (Note 3) $6,613,223

Final Survey $186,306 $208,663 $260,829

Site Stabilization and Long Term Surveillance

(Note 2)

TOTAL PROJECT COST S9,722,404 $10,254,224 $12,817,781

Note 1: The facility is designed to contain and prevent contamination outside the equipment and building areas and the controlled containment area; including measures of

ALARA radiological controls that will result in a low likelihood of contaminating the facility grounds at levels that would require excavation or restoration. In the event of a small

spill, the limited area affected will be cleaned, surveyed and decontaminated, if needed. at the time as part of the required cleanup immediately following any such spill.

Note 2: The facility is designed to contain and prevent contamination outside the equipment building areas and the controlled containment areas: including measures of

radiological ALARA controls that will result in a low likelihood of contaminaling the facility grounds at levels that would require excavation or restoration. In the event of a small

spill. the limited area affected will be cleaned. surveved and decontaminated, if needed, as part of the required cleanup immediately following any such spill. Therefore. site

stabilization and long-term surveillance will not be required and associated decommissioning costs are not provided.

Note 3: Transportation and Disposal Cost already includes profit which would be realized by the transport and disposal companies and not by a third party contractor. Therelbre.

the third party contractor margin was not applied.

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