International Isotopes Fluorine Products, Inc. (IIFP) 

A Wholly Owned Subsidiary of 

International Isotopes, Inc. (INIS)

Fluorine Extraction Process & Depleted 

Uranium De-conversion 

(FEP/DUP) Plant 

License Application 

 

Chapter 9 

Environmental Protection 

Revision B 

 November 4, 2011 

LA-IFP-001 Revision B CHAPTER 9 
LA-IFP-001 Revision B CHAPTER 9 November 4, 2011 

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TABLE OF CONTENTS 

LIST OF FIGURES ................................................................................................................................. 9-iii 

LIST OF TABLES ................................................................................................................................... 9-iii 

ACRONYMS and ABBREVIATIONS (Provided in License Application Chapter 1 Revision B) 

9 ENVIRONMENTAL PROTECTION ............................................................................................. 9-1 

 9.1 ENVIRONMENTAL REPORT ............................................................................................... 9-2 

 9.1.1 Date of Application ...................................................................................................... 9-4 

 9.1.2 Environmental Considerations ...................................................................................... 9-4 

 9.1 2.1 Description of Proposed License Action ........................................................ 9-4 

 9.1.2.2 Purpose and Need for Proposed License Action ............................................ 9-4 

 9.1.2.3 Description of Affected Environment ............................................................ 9-4 

 9.1.2.4 Discussion of Considerations ......................................................................... 9-5 

 9.1.3 Analysis of Effects of Proposed Actions and Alternatives............................................ 9-7 

 9.1.4 Status of Compliance..................................................................................................... 9-7 

 9.1.5 Adverse Information...................................................................................................... 9-8 

 9.2 ENVIRONMENTAL PROTECTION MEASURES ................................................................ 9-8 

 9.2.1 Radiation Protection ....................................................................................................... 9-9 

 9.2.1.1 Radiological (ALARA) Goals for Effluent Control....................................... 9-9 

 9.2.1.2 Effluent Controls to Maintain Public Doses ALARA .................................... 9-9 

 9.2.1.3 ALARA Reviews and Reports to Management ........................................... 9-10 

 9.2.1.4 Waste Minimization ..................................................................................... 9-10 

 9.2.2 Effluent and Environmental Controls and Monitoring ................................................ 9-15 

 9.2.2.1 Effluent Monitoring ..................................................................................... 9-16 

 9.2.2.2 Environmental Monitoring ........................................................................... 9-23 

 9.2.3 Integrated Safety Analysis ............................................................................................ 9-25 

REFERENCES .................................................................................................................................... 9-26 

 

 

 
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LIST OF FIGURES 

Figures 9-1 Location of the IIFP Site....................................................................9-2

LIST OF TABLES 

No List of Table Entries 
LA-IFP-001 Revision B CHAPTER 9 November 4, 2011 

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 9 ENVIRONMENTAL PROTECTION 

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

Inc. (INIS), will build and operate a depleted uranium processing facility near Hobbs in Lea County, New 

Mexico. The IIFP Facility (also referred to as the FEP/DUP Plant) is being licensed under Title 10 Code 

of Federal Regulations (CFR) Part 40. A summary description of the planned facility is provided in the 

IIFP License Application (LA), Revision B Chapter 1 “General Information.” 

Chapter 9 addresses the two (2) major components that provide the basis for adequate environmental 

protection assurance during both normal and credible abnormal operations for the IIFP Facility that is to 

be built near Hobbs, New Mexico. These two (2) distinct components are: 1) the Environmental Report 

(ER) and 2) the Environmental Protection Measures. The ER evaluates the environmental impacts of the 

facility whereas the Environmental Protection Measures define the programs and sampling and analysis 

measures necessary to maintain adequate environmental assurance during the operating lifetime of the 

facility. 

In addition to the environmental effects for the facility requested in the current licensing activity and LA, 

the ER evaluates the environmental effects of a future add-on depleted uranium hexafluoride (DUF6) 

process for direct de-conversion to depleted uranium oxide that would result in an expanded IIFP Facility 

referred to as Phase 2. The DUF6-to-oxide de-conversion future expansion is not part of the current 

License Application or requested activities. The future Phase 2 facility was evaluated in the current ER 

submittal owing to the plans to begin adding this process to the original facility within approximately 3-4 

years of the first facility operation. The Phase 2 expansion would require a separate and future licensing 

activity at the appropriate time prior to its construction. 

The ER considers and evaluates impacts of the IIFP Facility during construction and operation. IIFP may 

request an exemption for some pre-license construction that could start as early as 4th Quarter of 2012. In 

the ER, pre-license construction is also considered in evaluating the environmental impacts. It is 

anticipated that pre-license approval will be obtained and some selective construction activities will be 

accomplished prior to issuance of a license by the U.S. Nuclear Regulatory Commission (NRC). These 

pre-license construction activities will be preparatory in nature and will not involve any process or safetyrelated equipment or systems. 

The selected pre-license construction activities only affect the timing of work and do not increase the 

scope of the environmental impact of overall facility construction. Some of these activities that are 

proposed and considered in the ER include the following: 

• Clear land 

• Grade site and control erosion 

• Install main entrance roadbed and drainage to highway 

• Install construction trailer 

• Prepare preliminary site roadways and gravel parking area 

• Drill water wells, if needed 

• Construct power substation 

• Stub in gas line to meter 

• Begin administration building construction 

• Install geothermal heating/cooling loops 

• Begin general warehouse (no contents) construction 

• Install firewater tanks 
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In summary, the pre-license construction was evaluated in each impact area of the ER. The impacts of 

pre-license construction were found to be no greater than if included during the time of full construction 

itself and are expected to be “SMALL”. The full construction impacts are determined in the ER to be 

SMALL except that the transportation and ecological impacts along some travel corridors are both 

determined to be MODERATE. A National Pollution Discharge Elimination System (NPDES) General 

Permit for Storm Water and a Spill Prevention, Control and Countermeasures (SPCC) Plan will likely be 

required and implemented earlier for the pre-license construction as it otherwise would have been done 

later for full construction. 

Figure 9-1 Location of the IIFP Site 

9.1 ENVIRONMENTAL REPORT 

The ER, Revision B constitutes one portion of an application to be submitted by IIFP to construct and 

operate a facility that offers de-conversion services of DUF6 and extracts the fluoride from the DUF 6 to 

produce high-purity fluoride gas products and anhydrous hydrofluoric acid (AHF). During this initial 

(Phase 1) IIFP Facility operation the DUF6 uranium will be de-converted into depleted uranium 

tetrafluoride (DUF4) and then into depleted uranium (DU) oxide. In the future, an expansion will be made 

to the original (Phase 1) IIFP Facility that will result in a Phase 2 Facility. The expansion that will be 

licensed and constructed as a future separate activity will utilize an additional and different process for 

direct de-conversion of DUF6 to AHF and DU oxide. In both processes, the extracted and recovered 
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fluorine products and AHF are sold and the depleted uranium oxide is sent for off-site disposal to a 

licensed low-level radioactive waste disposal facility. 

The IIFP Facility will be located near Hobbs, New Mexico (Figure 9-1). The ER, Revision B for the 

facility serves two primary purposes. First, it provides information that is specifically required by the 

NRC to assist in meeting its obligations under the National Environmental Policy Act (NEPA) of 1969 

(NEPA,1969) and the U.S. Environmental Protection Agency’s (EPA) NEPA-implementing regulations. 

Second, it demonstrates that the environmental protection measures proposed by IIFP are adequate to 

protect both the environment and the health and safety of the public. 

IIFP has prepared the ER to meet the requirements specified in 10 CFR 51, Subpart A, particularly those 

requirements set forth in 10 CFR 51.45(b)-(e), “Environmental Report” (CFR, 2009a). The organization 

of the ER is generally consistent with NUREG-1748, “Environmental Review Guidance for Licensing 

Actions Associated with NMSS Programs, Final Report,” (NRC, 2003). 

The full ER evaluates the environmental impacts of the IIFP facility near Hobbs, New Mexico. 

Accordingly, the ER discusses the Proposed License Action (hereafter referred to as Proposed Action), 

the need for and purposes of the Proposed Action and applicable regulatory requirements, permits and 

required consultations. The ER is presented to the NRC in separate documentation comprised of the 

following list: 

• Chapter 1, “Introduction of the Environmental Report” identifies briefly the general Proposed 

Action, the affected region and site area, the Proposed Action schedule for implementation and 

the applicable regulations with the current status. 

• Chapter 2, “Alternatives” describes in more detail the Proposed Action, process descriptions and 

considers the No-Action and Reasonable Alternatives, if any, to the Proposed Action. 

• Chapter 3, “Description of the Affected Environment” describes the IIFP Facility and the 

environment potentially affecting the Proposed Action. 

• Chapter 4, “Environmental Impacts” presents and compares the potential impacts resulting from 

the Proposed Action and its alternatives. 

• Chapter 5, “Mitigation Measures” identifies mitigation measures that could eliminate or lessen 

the potential environmental impacts of the Proposed Action. 

• Chapter 6, “Environmental Measurements and Monitoring Programs” describes environmental 

measurements and monitoring programs. 

• Chapter 7, “Cost-Benefit Analysis” provides a cost benefit analysis. 

• Chapter 8, “Summary of Environmental Consequences” summarizes those environmental 

consequences. 

• Listings of references and preparers are provided in Chapter 9, “References” and in Chapter 10, 

“List of Preparers.” 
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9.1.1 Date of Application 

As required by 10 CFR 40.31(f), “Application for Specific Licenses,” (CFR, 2009b), the submittal date 

of December, 2009 is at least nine (9) months prior to facility construction, which is scheduled to begin in 

late 2012. The proposed startup date for the facility is scheduled for late 2013 or early 2014 timeframe. 

9.1.2 Environmental Considerations 

The IIFP ER addresses the requirements of 10 CFR 51.45(b) (CFR, 2009a) as discussed below. 

9.1.2.1 Description of Proposed License Action 

The current IIFP License Application is for the Phase 1 Facility only as discussed above in Section 9.1. 

This proposed action for Phase 1 is described in the IIFP ER, Revision B Section 2.1. The “Proposed 

License Action” discussed in the ER is the issuance of an NRC license under 10 CFR 40 (CFR, 2009b) 

for the possession of up to 750,000 kilograms of uranium (kgU) and for construction and operation of a 

facility for de-conversion of DUF6 and the production of fluoride products and anhydrous hydrofluoric 

acid. 

A description of the IIFP Site is contained in the ER, Revision B Section 1.3.3 “The IIFP Site.” A detailed 

description of the facility and specific process descriptions are included in ER, Revision B Section 2.1. A 

discussion of the method utilized to extract fluorine products from the source material (DUF6) is also 

described in this section. Additional information regarding the facility design, the site and the facility 

operating features is contained in the IIFP Revision B Integrated Safety Analysis (ISA) Summary. 

9.1.2.2 Purpose and Need for Proposed License Action 

The IIFP ER, Revision B Section 1.2 “Purpose and Need for the Proposed License Action” demonstrates 

the need for DUF6 de-conversion facilities to support additional uranium enrichment capacity in the 

United States. The proposed action is intended to de-convert DUF6 (tails) into chemically stable depleted 

uranium oxide while extracting the valuable fluorine to produce fluoride products for commercial use. It 

is estimated that new commercial uranium enrichment facilities will eventually be producing more than 

85 million pounds of DUF6 tails each year in the U.S. The U.S. Department of Energy (DOE) is building 

its own facilities for de-conversion of the DOE stockpile of depleted tails but those facilities will not be 

able to provide de-conversion of these new commercial tails for an estimated twenty (20) to twenty-five 

(25) years. Without the IIFP commercial de-conversion facility, it is likely that over a billion pounds of 

commercial tails will be accumulated in the U.S. over that time and most of the valuable fluorine trapped 

in this inventory will be wasted. The IIFP Facility offers a solution beginning in the near-term to depleted 

uranium storage, conducts recycling and recovery of important fluorine and produces products using just 

a fraction of the energy required to produce those fluoride products using conventional methods. 

9.1.2.3 Description of Affected Environment 

IIFP ER, Revision B Chapter 3 “Description of the Affected Environment” contains a description of the 

affected environment. The chapter provides a baseline characterization of the New Mexico site and its 

environment prior to any activities associated with construction, operation or decommissioning of the 

facility. 
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IIFP ER, Revision B Chapter 3 addresses the following topics: 

• Land Use 

• Transportation 

• Geology and Soils 

• Water Resources 

• Ecological Resources 

• Meteorology, Climatology and Air Quality 

• Noise 

• Historic and Cultural Resources 

• Visual/Scenic Resources 

• Socioeconomics 

• Public and Occupational Health 

• Waste Management 

Each subsection discusses the regional, local and site conditions as they currently exist in order to 

establish a baseline. IIFP ER, Revision B Chapter 4 “Environmental Impacts” describes how the baseline 

environment is potentially impacted as a result of the construction, operation and decommissioning of the 

IIFP Facility. Basic supporting information was gathered from federal, state and county sources and sitespecific data. The information represents both seasonal and long-term environmental trends. 

9.1.2.4 Discussion of Considerations 

The following discussion summarizes the information in the IIFP ER, Revision B with respect to the 

environmental impacts from, and the alternatives to, both the IIFP Facility processes and the Hobbs, New 

Mexico site. 

Impact of the Proposed Action on the Environment

In accordance with 10 CFR 51.45(b) (1) (CFR, 2009a), the IIFP ER, Revision B Chapter 4 discusses the 

impact of the Proposed Action on the environment. Each subsection in IIFP ER, Revision B Chapter 3 has 

a corresponding subsection in ER, Revision B Chapter 4 which ensures that each environmental aspect is 

addressed with respect to its impact from the IIFP Facility. 

Adverse Environmental Effects

The adverse environmental effects are discussed in each subsection of IIFP ER, Revision B Chapter 4 as 

well as in ER, Revision B Section 8.3 “Short-Term and Long-term Impacts” and Section 8.4 

“Relationship between Short-Term Use of the Environment and the Maintenance and Enhancement of 

Long-Term Productivity.” These sections satisfy the requirements in 10 CFR 51.45(b) (2) (CFR, 2009a). 

Overall, adverse impacts for the Proposed Action (Phase 1) and the expansion to the Phase 2 Facility are 

determined to be SMALL. However, in some resource areas during construction and operation of the 

Phase 1 Facility and later Phase 2, SMALL to MODERATE or MODERATE environmental impacts 

were identified; for example, in the resource areas of transportation and ecological. A complete listing of 

the environmental impacts in each stage of the project, including cumulative impacts, is provided in Table 

2-7 of the ER, Revision B Chapter 2. Radiation and chemical releases from operations, in general, may 

cause adverse impacts. However, the releases and corresponding exposures from the IIFP Facility would 

be well below regulatory limits and proportionally very small. 
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IIFP ER, Revision B Chapter 4 has an additional section that discusses Environmental Justice, a federal 

policy under which each agency identifies and addresses disproportionately high and adverse human 

health or environmental effects of agency policies and activities on minority and low-income populations. 

For the nearby centrifuge uranium enrichment facility near Eunice, New Mexico and essentially the same 

populous, the NRC staff concluded that no disproportionately high and adverse impacts would occur to 

minority and low-income populations living near the enrichment facility or along likely transportation 

routes into and out of the enrichment facility as a result of the proposed action. 

Alternatives to the Proposed Action

Alternatives to the Proposed Action are discussed in the IIFP ER, Revision B Chapter 2, “Alternatives,” 

pursuant to Section 102(2)(E) of the National Environmental Policy Act of 1969 (NEPA) (NEPA, 1969) 

and 10 CFR 51.45(b)(3) (CFR, 2009a). Environmental impacts of the Proposed Action, including the noaction alternatives, are presented in comparative form. A discussion of site selection and design 

alternatives is also included. 

Relationship of Short-Term Uses and Long-Term Productivity

In accordance with 10 CFR 51.45(b)(4) (CFR, 2009a), Revision B Chapter 8 of the IIFP ER, “Summary 

of Environmental Consequences,” discusses the relationship between local short-term uses of the 

environment and the maintenance and enhancement of long-term productivity from the IIFP New Mexico 

operation. 

During construction, the potential short-term impacts are soil erosion and fugitive emissions from dust 

and construction equipment, minor disruption to ecological habitats and cultural resources, noise from 

equipment and traffic from worker transportation and supply deliveries. These impacts are temporary and 

limited in scope during the construction process to the greatest extent possible. During operation, the noaction alternative would avoid increased traffic due to feed/product deliveries and shipments and worker 

transportation, increased demand on utility and waste services and public and occupational exposure from 

effluent releases. However, those impacts are SMALL to MODERATE because the local roadway (U.S. 

Highways 62/180) already has significant traffic of similar nature, there is sufficient capacity of utility 

and waste services in the region and effluent releases are strictly controlled, monitored and maintained 

below regulatory limits. No adverse impact on the long-term productivity of the environment after the 

decommissioning of the facility has been identified. 

While the no-action alternative would have no significant impact on the socioeconomic structure of the 

Lea County, New Mexico area, the Proposed Action would have moderate to significant beneficial effects 

(see the “Cost Benefit Analysis” in Revision B Chapter 7 of the IIFP ER). The results of the economic 

analysis show that substantial positive fiscal impacts are derived from the 14-18 month construction 

period associated with the facility. There is a large beneficial impact on local business revenues as a result 

of local construction expenditures. Significant impacts on household earnings and jobs are associated with 

construction payroll and employment projected during the construction period. Operation of the facility 

also has a significant net positive impact on Lea County and surrounding counties and will help diversify 

the regional economy and provide additional insulation from the volatility of the oil and gas dependent 

economy of the region. 
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Irreversible and Irretrievable Commitments of Resources

In accordance with 10 CFR 51.45(b) (5) (CFR, 2009a), Revision B Chapter 8 of the IIFP ER also 

discusses the irreversible and irretrievable commitments of resources necessary to construct, operate and 

decommission the facility. No commitments of environmental resources at, or in proximity to the Hobbs, 

New Mexico site, were identified for the construction, operation and decommissioning of the IIFP 

Facility that ultimately could not be restored (that is, become irretrievable) after facility closure and 

decommissioning of the site for unrestricted use. Soils found at the site are applicable for range, wildlife 

and recreation areas and not for any standard agricultural activities. Therefore, construction and operation 

of the IIFP Plant are not anticipated to displace any potential agrarian use. 

9.1.3 Analysis of Effects of Proposed Actions and Alternatives 

The analysis of the effects in regards to the Proposed Action compared to alternatives in accordance with 

10 CFR 51.45(c) (CFR, 2009a) is discussed in ER, Revision B Chapter 2. The comparison of effects 

considers information about the environmental, economic, social and other benefits and costs associated 

with the IIFP Proposed Action. ER, Revision B Chapter 4 contains a description of impacts. IIFP ER, 

Revision B Chapter 7 discusses the economic and environmental cost and benefits of the IIFP Proposed 

Action. 

The analysis presented in ER, Revision B Chapter 2 considered and balanced the environmental effects of 

the Proposed Action, the environmental impacts of alternatives to the Proposed Action and alternatives 

available for reducing or avoiding adverse environmental effects. The analysis also considered technology 

alternatives to the IIFP Facility process technology, design alternatives and alternative site locations. 

9.1.4 Status of Compliance 

In addition to the NRC licensing and regulatory requirements, a variety of environmental regulations 

apply to the IIFP Facility during the construction and operation phases. These regulations require permits 

from, consultations with, or approvals by other governing or regulatory agencies. IIFP ER, Revision B 

Chapter 1 summarizes the applicable environmental regulatory requirements, permits, licenses or 

approvals, as well as the current status of each, as of the effective date of the ER. Permits include the 

following: 

• NPDES “General Permit for Industrial Stormwater” 

• Air Quality Permit for joint construction and operation 

• National Environmental Standards for Hazardous Air Pollutants (NESHAP) Permit (if required) 

• Groundwater Discharge Permit 

• EPA Hazardous Waste ID Number 

• Drinking Water System Permit 

• Above-ground Storage Tank Registration 

• NPDES Storm Water Pollution Prevention Plan (SWPPP)/Notice of Intent (NOI) 

• State Access (Highway Right of Way) Permit 

• Rare, Threatened and Endangered Species Survey Permit 

IIFP will also develop a Storm Water Pollution Prevention Plan and file a Notice of Intent with the EPA 

at least seven (7) days prior to the commencement construction activities. An agreement has been 

obtained with the New Mexico Environment Department (NMED) on the type and maximum quantities 
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of depleted uranium and container possession limits. The NMED Agreement limits are provided LA, 

Revision B Chapter 1 “General Information” Table 1-1. 

Miscellaneous regulations include the following: 

• New Mexico Statutes Annotated (NMSA) Chapter 74, Article 12, “Night Sky Protection,” 

establishes requirements to preserve and enhance the state’s dark sky while promoting safety, 

conserving energy and preserving the environment for astronomy. These requirements will be 

addressed during detailed design of the facility. 

• New Mexico Statutes Annotated (NMSA) Chapter 50, Sections 1-25, and implementing 

regulations at New Mexico Administrative Code (NMAC) Title 11, “Labor Workers 

Compensation,” Chapter 5, “Occupational Safety and Health” establishes state requirements for 

assuring safe and healthful working conditions for every employee. These state regulations are 

being followed to ensure any additional requirements beyond the federal U.S. Occupational 

Safety and Health Administration (OSHA) regulations are adequately addressed. 

• Groundwater monitoring wells are permitted through Office of the State Engineer (OSE) and well 

locations along with the boring logs are submitted to the OSE. Site-wide groundwater levels will 

be monitored routinely, and the groundwater monitoring well and pumping well networks will be 

analyzed to confirm that the changes in groundwater levels associated with the operation of the 

IIFP are minimal. Future detailed engineering and hydrological studies will identify the 

appropriate systems and locations. Monitoring wells are discussed in the IIFP ER, Revision B 

Chapter 6 “Environmental Measurements and Monitoring Program.” 

9.1.5 Adverse Information 

In accordance with 10 CFR 51.45(b) (2) and (e) (CFR, 2009a), several sections in the IIFP Environmental 

Report, Revision B discuss adverse environmental effects. ER, Revision B Chapter 2 considers the 

potential impacts of the IIFP Facility to the alternatives. ER, Revision B Chapter 4 details environmental 

and socioeconomic impacts due to site preparation/construction, operation and decommissioning of the 

IIFP Facility New Mexico site. ER, Revision B Chapter 5 “Mitigation Measures” describes mitigation 

measures to minimize potential adverse impacts. Lastly, IIFP ER Chapter 8 provides a summary of the 

environmental consequences. 

The overall environmental impacts resulting from the IIFP Facility construction, operation and 

decommissioning have been determined to be a SMALL value (where SMALL is defined as 

environmental impacts that are non-detectable or so minor that those impacts will neither destabilize nor 

noticeably alter any important attribute of an applicable environmental resource). Furthermore, minor 

impacts are controlled to the greatest extent possible through the use of mitigation measures and best 

management practices described in Revision B Chapter 5 of the IIFP ER. 

9.2 ENVIRONMENTAL PROTECTION MEASURES 

Environmental protection measures will be maintained at the IIFP Facility as part of the IIFP 

Environmental Protection Program. The primary purpose of this Program is to maintain radiological and 

chemical effluent control such that exposure of the workers, public and environment to radioactive 

materials or chemicals from facility operations is kept as low as reasonably achievable (ALARA). This is 
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accomplished through facility design, effluent engineering controls, administrative controls and staff 

training and qualification. Effluent and environmental monitoring is an additional best management 

practice to document and verify that effluent emissions and performance of the Environmental Protection 

Program are consistent with the guidance contained in Regulatory Guide 8.37, “As Low As Reasonably 

Achievable (ALARA) Levels for Effluents from Materials Facilities” (NRC, 1993). In addition, IIFP will 

comply with the air quality permitting requirements specified in New Mexico Administrative Code Title 

20 Chapter 2. 

9.2.1 Radiation Protection 

The following sections address the four acceptance criteria that describe the facility Radiation Protection 

Program (RPP) as it applies to environmental protection. The RPP is discussed further in Revision B 

Chapter 4 “Radiation Protection” of the LA. Specific references to supplemental information are provided 

in each section, as appropriate. 

9.2.1.1 Radiological (ALARA) Goals for Effluent Control 

Monitoring of facility effluents, analysis of monitoring samples and evaluation of sampling data allow for 

the determination of the quantity of radioactive material released from the facility during normal 

operating conditions thereby demonstrating attainment of ALARA goals and effluent limit compliance. 

Identification of the quantity of material released from the facility permits the evaluation of the success of 

control and containment of contamination. In addition, the determined quantity of radioactive material 

released from the facility will allow for the estimation of potential off-site dose to the public. Finally, 

identification of an unexpected increase in material quantities released from the facility allows for the 

detection of any unexpected release pathways previously unidentified. 

ALARA goals are set to demonstrate compliance with 10 CFR 20, “Standards for Protection Against 

Radiation,” (CFR, 2009c) with respect to doses to the public, doses to the worker and environmental 

effluents and will initially be set at 20% of the 10 CFR 20 Appendix B values (CFR, 2007). Goals are set 

by the IIFP ALARA Committee and reviewed annually to assess the need to adjust specific values based 

on what may be ALARA for the particular measure. Compliance with the ALARA goals is demonstrated 

through monitoring, analysis and evaluation of air emissions, liquid effluents and disposition of solid 

waste. 

Trends are assessed using the monitoring results to evaluate the following: 1) facility operations control 

and containment of contamination, 2) projections of potential dose to off-site populations and 3) detection 

of any unanticipated pathways for transport of radionuclide(s) within the environment. In accordance with 

the ALARA Program, these monitoring results are summarized and presented to the ALARA Committee 

on an annual basis. The ALARA Program and associated goals are further described in LA, Revision B 

Section 4.2.2 “ALARA Goals.” 

9.2.1.2 Effluent Controls to Maintain Public Doses ALARA 

Effluent controls are used to maintain public doses ALARA. Gaseous effluents, that may contain depleted 

uranium, pass through pre-filters, porous metal filters and carbon-bed filters prior to entering the Plant 

Potassium Hydroxide (KOH) Scrubbing System (three-stages, in series). After scrubbing, the effluents are 

discharged to the atmosphere via the scrubbing system stack. Certain storage vessels, powder transfer 

systems and packaging stations, where depleted uranium particles are involved, are connected to dust 

removal systems comprised of two or three stages to ensure capture and recovery of depleted uranium 
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particles prior to venting the systems to the atmosphere. The stacks are continuously sampled and are 

routinely analyzed to measure radioactivity of the exhaust gases. 

Effluent controls are described in the IIFP ER Revision B as part of the facility process descriptions in 

subsections 2.1.3.6, 2.1.3.7, and 2.1.3.9. In addition, ER Table 2-2 provides a list of design efficiencies 

for process vent off-gas treatment equipment, and ER Table 2-3 provides a list of major process vent 

stacks. ER, Revision B Section 6.1 identifies the proposed sampling and monitoring locations for gaseous 

effluents, liquid effluents and groundwater and provides an overview of the IIFP Facility Effluent 

Monitoring Program to achieve ALARA. IIFP ER Figure 6-1 illustrates the planned monitoring locations 

at the site. IIFP ER, Revision B subsections 6.1.1 and 6.1.2 provide additional details about effluent and 

radiological monitoring. Effluent control and conservation features are described in subsections of ER, 

Revision B Section 4.13.4. Section 3.1.10 of the IIFP Revision B ISA Summary describes the process 

vent stacks at the IIFP Facility. Table 3-4 in Revision B ISA provides the listing of design efficiencies for 

the off-gas treatment equipment as does Table 2-2 of the ER. Table 3-5 of the ISA provides the stack 

heights and estimated flow rates of the major process vent stacks. 

Plant process water discharges are treated and are contained on-site either by recycling and reusing in the 

process or by evaporating. Cooling water is recycled. The facility liquid effluent collection and recycle 

systems provide a means to control liquid waste and maintain a process-water practical mass balance 

using flow-surge tanks, scrubber solution regeneration/recycle and evaporation equipment. There is no 

discharge to a Publicly Owned Treatment Works (POTW). Sanitary water usage is minimized through 

efficient designs and the sanitary water discharge is tertiary treated to render it suitable for watering of the 

facility shrubs and trees. Storm water runoff from process building roofs and pads is collected and 

transported to an approved design retention basin via the plant storm water sewer system. The storm 

water is temporarily stored in the Storm Water Retention/Evaporation Basin until it is evaporated or 

sampled and discharged in accordance with the State of New Mexico Groundwater Discharge Permit. 

9.2.1.3 ALARA Reviews and Reports to Management 

In accordance with the ALARA Program, the environmental protection aspects of the Radiation 

Protection Program are reviewed as part of the annual ALARA review. Review of the ALARA Program 

is addressed in LA, Revision B Chapter 4 Section 4.2.3. The ALARA review includes analysis of trends 

in release concentrations, environmental monitoring data and radionuclide distribution. The review then 

determines the need for operational changes to achieve the ALARA effluent goals and evaluates designs 

for system installations or modifications. The results of the ALARA review are reported to senior 

management along with recommendations for changes in facilities or procedures that are necessary to 

achieve ALARA goals. The members on the ALARA Committee include the Chief Operations Officer, 

Radiation Protection Manager, selected department managers, the Environmental Safety and Health 

Manager and selected supervisors and hourly workforce personnel. 

9.2.1.4 Waste Minimization 

The facility is designed and operated in accordance with 10 CFR 20.1406, “Minimization of 

Contamination” (CFR, 2009d) to minimize contamination, facilitate eventual decommissioning and 

minimize to the extent practicable the generation of radioactive waste. The waste minimization practices 

during design, construction and operation of the facility are consistent with the guidance in Regulatory 

Guide 4.21, “Minimization of Contamination and Radioactive Waste Generation: Life-Cycle Planning,” 

(NRC, 2008). 
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The IIFP Facility incorporates several waste minimization systems in its operational procedures and 

design that aim at a high priority of conserving materials and preventing the spread of contamination. The 

major of those systems and procedures are discussed below. 

Recycling on-site is an important strategy of the IIFP Facility Waste Minimization Program; for example: 

1) regenerating and recycling of KOH scrubbing solution for use in the Plant KOH Scrubbing System. 

This design and operation eliminates the need to otherwise discharge the flow as treated wastewater and 

also conserves the use of the treating agent and saves cost, 2) collection and recycling of steam 

condensate back to the facility steam boilers, where applicable, for saving energy and minimizing 

disposal and 3) conserving valuable water resources by using air coolers and recirculation of process 

cooling water thereby avoiding once-through flow of water. 

Another important aspect of the Waste Minimization Program is the employment of waste segregation 

methods and procedures to facilitate recycling and to minimize contamination. Various receptacles are 

provided to allow for segregation of clean and contaminated materials. To prevent cross contamination, 

training is provided with emphasis on minimizing waste and controlling disposal costs. The outer 

packaging associated with consumables is removed prior to use in a contaminated area to minimize 

potential for contamination and to facilitate recycling and disposal of the clean segregated materials. 

Collected waste such as trash, compressible dry waste, scrap metals and other candidate wastes will be 

volume reduced, where feasible, at a centralized on-site and/or off-site waste processing facility. An offsite facility will be used for the segregated “clean waste,” such as cardboard, office paper waste, 

aluminum cans and scrap metal, where recycling is practical and can be best operated by a commercial 

vendor. ALARA controls will be maintained during facility operation to account for standard waste 

minimization practices as directed in 10 CFR 20.1406 (CFR, 2009d). 

Lubrication oils and other oils are segregated to prevent cross contamination. The oils are collected and 

stored in containers that are temporarily staged in a sealed-concrete pad area utilizing curbs and dikes for 

secondary containment in accordance with Resource Conservation and Recovery Act (RCRA) 

requirements. Non-contaminated waste oil is sent to an off-site recycle facility, where applicable. Oil that 

cannot be recycled is disposed at an off-site licensed disposal facility. 

Facility ventilation systems are designed to confine airborne radioactive materials within the process area 

and as close to the point of origin as practicable. Construction materials for ventilation systems are 

selected as to have a smooth internal surface finish and IIFP minimizes the number of changes in 

direction to the extent practicable. 

Mechanical integrity and preventative maintenance procedures are utilized in accordance with the facility 

Chemical Process Safety Program (CSP) that is also in compliance with the OSHA Process Safety 

Management Program. In part, the inspections, surveillance, scheduled and planned maintenance and 

audits provide a means by which the potential for leaks on piping and equipment are prevented or 

minimized. Design and operational procedures provide early detection if leaks do occur thus allowing 

prompt assessment to support timely and appropriate response. Monitoring and surveillance programs are 

extremely important in minimizing contamination. IIFP uses fluoride detector instrumentation, radiation 

detectors and personnel surveillance techniques to minimize contamination. If leaks are suspected, area 

samplers are utilized to investigate and identify the area for correction. Where leaks of hazardous 

materials are suspected, area postings and warning lights are utilized to protect employee health and 

communicate potential contamination problems. Suspected or known leakage problems are investigated, 
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the equipment operation is curtailed if needed and the leakage is resolved, including any cleanup where 

applicable. 

The IIFP Facility is designed to minimize the usage of natural resources. Closed-loop cooling systems 

have been incorporated in the designs to reduce water usage. Power usage is minimized by efficient 

design of lighting systems, selection of high-efficiency motors and use of proper insulation materials. 

Solar panels and geothermal heating systems are utilized to reduce carbon based fuel requirements where 

practical. 

The Plant KOH Scrubbing System and Environmental Protection Process are designed to recycle KOH 

thus conserving the treating agent. Secondary containment for tanks and tank systems is provided with a 

holding capacity margin of safety to ensure containment in the event of a leak or spill of the largest tank 

capacity per EPA requirements. Tank sampling stations are designed to minimize the possibility of 

sample fluid leaking to the ground. Areas involving diesel refueling are also provided with secondary 

containment. 

Radioactive, hazardous and mixed wastes are generated at the IIFP Facility. Such wastes are collected in 

labeled containers in each Restricted Area (RA) and transferred to a waste storage area for inspection. 

Suitable waste is volume reduced, if feasible, then disposed of at a licensed waste disposal site. 

Sanitary sewage effluent is discharged into a package unit where it receives primary, secondary and 

tertiary treatment. The effluent from sanitary treatment is used in the facility for process water makeup or 

for landscape and watering of the IIFP Site tree farm. 

An area (Decontamination Building) is provided in the operating facility for decontaminating equipment 

that may need to be cleaned before repair or for cleaning of materials, where feasible, prior to disposal. 

This process helps minimize the spread of contamination. Some of the equipment and systems provided 

in this area include: 

• High pressure water/steam/air equipment with a sloped sealed-type floor runoff and collection 

double contained sump pit 

• Totally enclosed grit blast unit with dust collection system 

• Ion-exchange units suitable to collect soluble uranium from solution 

• High efficiency filters suitable to remove small particulates of uranium from solution 

• Tanks to provide hold capability and precipitation capacity for soluble uranium 

 

The operating facility Decontamination Building includes an area to perform a series of steps following 

equipment disassembly including degreasing, decontamination, drying and inspection. Items from 

uranium processing systems, waste handling systems and miscellaneous other items can be 

decontaminated in this area. Air suits and portable ventilation units are available and may be used in 

minimizing worker exposure and preventing airborne radiological contamination that may result from 

equipment dismantlement in the area. Piping and vessels in the Decontamination Building are designed 

to protect against spillage or leakage. Hazardous wastes and materials are contained in tanks and other 

appropriate containers and are strictly controlled by procedures. 
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Practices Consistent with Regulatory Guide 4.21 include:

A. Minimizing Facility Contamination 

• Worker access to contaminated areas is controlled to assure that workers wear proper protective 

equipment and limit their time in the areas. Protective equipment is cleaned, stored or disposed of 

in proper locations and receptacles. 

• Waste volume reduction is considered and implemented at every opportunity, including training 

of employees. 

• Leak and spill collection areas are provided. 

• Floor liners and catch basins are included in areas of higher leak potential. 

• Personnel surveillance techniques are part of leak identification and correction. 

• Monitoring is conducted for leaks or spills in area Control Rooms; for example, fluoride detectors 

and radiation detectors. 

• Radiological boundary control and monitoring stations are used in strategic locations to prevent 

spreading of potential contamination. 

• Controlled purge and evacuation (P&E) systems are used to prevent area contamination and 

potential out-leakage during maintenance and inspection. 

• Decontamination Building and equipment are provided to clean equipment that has been removed 

for repair and re-installation. 

• Floors are appropriately sloped for spills. 

• Drains from locker rooms and cleanup showers in potential contamination areas are routed 

selectively to the Decontamination Building. 

• Proper ventilation systems maintain positive pressure in Control Room areas. 

• Secondary containment is provided in outside areas and includes excess capacity to capture leaks 

or spills from the largest vessel in the area in accordance with EPA requirements. 

• Monitoring wells are provided and sampled both up gradient and down gradient with established 

baselines. 

• Storm Water Retention/Evaporation Basins have two impermeable barriers if required. 

• Exterior tanks are located on or above concrete pads above grade and with curbs and dikes. 

• Areas used to support radioactive material handling are controlled and contained. 
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• Facility ventilation system designs confine airborne radioactive materials within the process area 

and as close to the point of origin as practicable. Construction materials for ventilation systems 

are selected as to have a smooth internal surface finish and minimize the number of changes in 

direction to the extent practicable.

B. Minimizing Contamination of the Environment 

• Building areas where uranium is processed and handled are separated physically from other 

building rooms and areas where there is no need to have uranium present. These areas have 

separate ventilation and filtration systems to preclude the spread of contamination. Boundary 

control stations and hand/foot and portable monitors are used at applicable locations to verify that 

personnel and items exiting uranium process areas are not spreading radiological materials into 

non-uranium areas. The DUF4 Process Building, FEP Oxide Staging Building, Decontamination 

Building, DUF4 Container Storage Building, DUF4 Container Staging Building and the FEP 

Process Building (in areas where licensed material is processed) meet these specific design 

features.

• All areas of the facility are sectioned into Unrestricted, Controlled or Restricted Areas. Restricted 

Areas limit access for the purpose of protecting individuals against undue risks from exposure to 

radiation and radioactive materials. All procedures for these areas fall under the Radiation 

Protection Program and serve to minimize the spread of contamination and simplify the eventual 

decommissioning.

• Routine radiological surveys will be conducted throughout the life of the facility operation and 

will minimize the likelihood that radioactive contamination goes undetected and will provide a 

historical record which will simplify the Site characterization process.

• Non-radioactive process equipment and systems are minimized in locations subject to potential 

contamination. This limits the size of the Restricted Areas and limits the activities occurring 

inside these areas.

• Containment equipment with hoods that exhaust through dust collectors that are designed with 

high removal efficiencies are used where uranium materials are being packaged or withdrawn 

from process systems.

• The hazardous material processes include designs for P&E systems and dust-collection 

equipment as a means to provide effective clean out of residual chemicals or dust from equipment 

or piping prior to opening systems for maintenance. The P&E and dust collector systems have 

multiple collection equipment that is configured in series (defense-in-depth) to ensure removal 

and treatment efficiency, redundancy, effectiveness and reliability.

• Storm water runoff via the storm sewer system flows to a “double lined” retention basin 

 for either evaporation or for landscape (tree farm) watering. It is not likely that collected storm 

water would exceed acceptable or regulated levels, but routine sampling for reuse or for discharge 

is conducted for further assurance. Domestic sanitary wastewater is tertiary treated to meet all 

discharge standards and is either evaporated or used as harvested water for facility trees, grass 

and shrubs. The facility is designed for no liquid process water discharges. Engineered systems 
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are used to provide for regeneration of scrubbing solutions and recycle within the process 

systems. 

C. Facilitating Decommissioning 

• During construction a washable coating is applied to designated floors and walls in the Restricted 

Areas that have the higher potential to become radioactively contaminated during operation. The 

coating serves to lower waste volumes during decontamination and simplify the decontamination 

process. 

• Sealed, nonporous pipe insulation is used in areas with higher potential to become contaminated. 

This facilitates cleaning in event of a spill and will reduce waste volume during 

decommissioning.

• Ample access is provided for efficient equipment dismantling and removal of equipment that may 

be contaminated. This minimizes the time of worker exposure.

• Tanks have access for entry and decontamination. Design provisions are also made to allow for 

removal of the wastes or materials contained in the tanks.

• Connections in the process systems, provided for required operation and maintenance, allow for 

thorough purging at facility shutdown. This system and procedure remove a significant portion of 

radioactive contamination prior to disassembly and prevent leakage to the general environment 

upon opening of equipment or piping.

• Design drawings, produced for all areas of the facility, will simplify the planning and 

implementing of decontamination procedures. This in turn will shorten the durations that workers 

are exposed to radiation.

• Worker access to contaminated areas is controlled to assure that workers wear proper protective 

equipment and limit their time in the areas.

• Radioactive and hazardous wastes produced during decommissioning will be collected, handled 

and disposed of, in accordance with all regulations applicable to the facility at the time of 

decommissioning. Generally, procedures will be similar to those described for wastes produced 

during normal operation. These wastes will ultimately be disposed of in licensed radioactive or 

hazardous waste disposal facilities located elsewhere. Non-hazardous and non-radioactive wastes 

will be disposed of in a manner consistent with good industrial practice and in accordance with 

applicable regulations. 

• To facilitate decommissioning, the information relating to the facility design, facility 

construction, design, modifications, site conditions before and after construction, on-site 

contamination and results of monitoring and radiological surveys will be readily recoverable 

through the IIFP document control and management process. 

9.2.2 Effluent and Environmental Controls and Monitoring 

Effluent and environmental controls and monitors are maintained at and around the facility to ensure that 

doses to the workers, the public and the environment remain ALARA. In order to monitor and 
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characterize meteorological phenomena (e.g., wind speed, direction and temperature) during plant 

operation conditions will be monitored using a meteorological tower located on site. In addition, monitors 

provide indication of potential off-normal occurrences requiring further investigation. Guidance provided 

in Regulatory Guide 4.16, “Monitoring and Reporting Radioactivity in Releases of Radioactive Material 

in Liquid and Gaseous Effluents from Nuclear Fuel Processing and Fabrication Plants and Uranium 

Hexafluoride Production Plants,” (NRC, 1985) has been utilized in the preparation of the environmental 

protection aspects of the IIFP RPP where applicable. 

Administrative and engineered controls for environmental effluents are described in the IIFP ISA 

Summary, Revision B Sections 2.4.10, 2.4.11 and 3.1. These controls are also described in the LA, 

Revision B Chapter 1 Section 1.1.3. These controls are also described in the IIFP ER Revision B 

(subsections 2.1.3, 4.6.4, 6.1, 6.2, and 6.3. The IIFP Radiation Protection Plan that addresses 

environmental protection is described in ER, Revision B Sections 6.1, 6.2 and 6.3 and is also described in 

LA, Revision B Section 4.1-4.7. As described in LA, Revision B Section 4.2, the ALARA Program is a 

subset of the RPP. With regard to effluent and environmental controls, the ALARA principle demands 

that radioactive effluents are monitored and that environmental releases stay significantly below the 

regulatory limits. An additional aspect of the ALARA Program includes the preparation and review of an 

annual report to evaluate effluent release trends as a means to ensure the ALARA programs are 

effectively implemented. 

9.2.2.1 Effluent Monitoring 

The following sections address the acceptance criteria related to effluent monitoring. 

Expected Concentrations

The expected concentrations of radioactive materials based on calculations and modeling in effluents 

were estimated using conservative assumptions. Calculated estimates airborne effluents are shown in 

Table 4-38, “Estimated and Bounding Radiological Releases from the Stacks during Phase 1 Operations” 

of the IIFP ER Revision B. 

The concentrations are controlled to be ALARA and below the limits specified in 10 CFR 20. As stated 

above, the liquid effluent streams that have potential for containing uranium are recycled, reused and 

maintained on the IIFP Site. Additional discussion of gaseous and liquid effluents is provided in the 

following subsections. Section 6, Revision B of the IIFP ER discusses in detail the IIFP Environmental 

Measures and Monitoring Program. Also, Section 6.1.1.1 and Section 6.1.1.2 of the Revision B IIFP ER 

more specifically describe the IIFP Facility Gaseous Effluent Monitoring and the Liquid Effluent 

Monitoring Program, respectively. Types of solid wastes and estimated amounts are given in the IIFP ER, 

Revision B Section 3.12.2 “Solid Waste Management.” 

Calculation of Total Effective Dose Equivalent

Dose projections to members of the public are performed routinely in accordance with approved written 

procedures to ensure the annual dose to members of the public are kept ALARA and within the regulatory 

limit. Compliance as described in 10 CFR 20.1302, “Compliance with Dose Limits for Individual 

Members of the Public,” (CFR, 2009e) is demonstrated through either the calculation of the total effective 

dose to the individual likely to receive the highest dose or through the calculation of annual average 

concentrations of radioactive material released in gaseous and liquid effluents. To demonstrate 

compliance with 10 CFR 20.1301 (via calculation of the Total Effective Dose Equivalent (TEDE) to the 
LA-IFP-001 Revision B CHAPTER 9 November 4, 2011 

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individual likely to receive the highest dose), IIFP will apply the EPA Radiation Risk Assessment 

software, CAP-88 or COMPLY. There are four primary exposure pathways associated with plant effluent: 

1) inhalation, 2) immersion in an effluent plume, 3) direct radiation due to deposited radioactivity on the 

ground surface (ground plane exposure) and 4) ingestion of contaminated food products. Of these four 

exposure pathways, inhalation exposures are expected to be the predominant pathways at site boundary 

locations and also at off-site locations that are relatively close to the site boundary. Input assumptions for 

the EPA codes will reflect the configuration and location of the release points, site-specific meteorology, 

the potential location of the maximally exposed individual and the regional land use. Input assumptions 

similar to those applied in the ER dose calculations (documented in ER, Revision B Section 4.12.6 

“Public and Occupational Exposure Impacts”) will be used as necessary. Table 4-41of the ER provides 

the annual and committed dose equivalents for exposures to the maximally exposed individual (MEI) 

from gaseous effluents. Table 4-42 from the ER provides annual and committed dose equivalents for 

exposures to the nearest resident from gaseous effluents. The estimated dose rate for sit boundary 

locations, the MEI and the nearest resident is provided in Table 4-45. The guidance in Regulatory Guide 

4.20, “Constraint on Releases of Airborne Radioactive Materials to the Environment for Licensees Other 

than Power Reactors” (NRC, 1996), is followed to determine compliance with dose limits to members of 

the public. Compliance with the dose limits to the members of the public is reported to the NRC in the 

semi-annual effluent report as required by 10 CFR 40.65 “Effluent Monitoring Reporting Requirements” 

(CFR, 2009). 

Effluent Discharge Locations

Two types of airborne effluent discharges are involved for the IIFP Site; stack effluent discharges and 

roof exhaust fan discharges. The locations of stack effluent discharges are illustrated in the IIFP Site Plot 

Plan, “Modified Site Features with Sampling Stations and Monitoring Locations” of the IIFP ER, 

Revision B. Roof exhaust fans are located on buildings which house areas where uranium is processed or 

handled. Both discharge types will be monitored as described in Section 6.1.1 of the ER, Revision B 

Chapter 6. 

Thirteen (13) stacks are contributing sources in the airborne effluent discharge locations of the Proposed 

Action (Phase 1 Facility). The FEP Dust Collector Stack (number 03) is a common system for the SiF4

and BF3 processes. The process off-gases from the DUF4, SiF4 and BF3 processes are all scrubbed in the 

three-stage (in series) equipment of the Plant KOH Scrubbing System. The treated gas from the last stage 

of the scrubbers exits the Plant KOH Scrubbing System Stack (number 01). 

Liquid plant process effluents are maintained on the IIFP Site for reuse or recycle and there is no 

discharge of chemical process wastewater. Discharge of sanitary waste is from the package sanitary 

treatment plant and after monitoring to ensure discharge limits are met, the treated water is used for 

silvaculture (IIFP tree farm watering). The treated sanitary discharge is sampled and analyzed routinely 

in accordance with the State of New Mexico Groundwater Permit requirements. Storm water that 

accumulates in two collection basins will either be evaporated or used for watering the tree farm. In cases 

where the basin water is sent to the tree farm, the discharges are sampled and analyzed to ensure New 

Mexico Groundwater Permit limits are not exceeded. 

Continuous Sampling Airborne Effluents

The IIFP ER, Revision B Chapter 6 addresses the Radiological Environmental Monitoring Program 

(REMP). The purpose of the REMP is to ensure that surveys are performed as necessary to demonstrate 

compliance with regulations and to demonstrate that the amount of radioactive material present in the 
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facility effluent remains ALARA. Effluent monitoring is discussed in Section 6.1.1 of the IIFP ER, 

Revision B. 

The effluent stacks, where licensed materials are involved, are sampled continuously and routinely 

analyzed to measure radioactivity of the exhaust air. The collection filters in the sample systems are 

removed periodically and analyzed for gross alpha and beta activity. The filters are composited 

periodically and an isotopic analysis is performed. Radiological analyses are performed on ventilation air 

filters if there is a 25% increase in gross radioactivity or when a process change or other circumstances 

cause significant changes in radioactivity concentrations. 

Sample Collection and Analysis

The REMP establishes sample collection and analysis methods and frequencies for the effluent medium 

and the radionuclide(s) analyzed. Sample collection and analysis methods and frequencies for the effluent 

medium will be performed in accordance with Regulatory Guide 4.15 “Quality Assurance for 

Radiological Monitoring Programs (Normal Operations) – Effluent Streams and the Environment” and 

Regulatory Guide 4.16, “Monitoring and Reporting Radioactivity in Releases of Radioactive Materials in 

Liquid and Gaseous Effluent from Nuclear Fuel Processing and Fabrication Plants and Uranium 

Hexafluoride Production Plants.” Sampling methods ensure that representative samples are obtained 

using appropriate sampling equipment and sample collection and storage procedures. Monitoring 

instruments are calibrated at least annually or more frequently if recommended by the manufacturer. IIFP 

ensures that sampling equipment (pumps, pressure gages and air flow calibrators) are calibrated by 

qualified individuals. Sampling equipment and lines are inspected for defects, obstructions and 

cleanliness as part of the plant preventive maintenance procedures. 

Section 6.1of the ER, Revision B describes the proposed sampling and monitoring locations for gases 

effluents and liquid effluents. Figure 6-1 “Modified Site Features with Sampling Stations and Monitoring 

Locations” indicates the locations of the environmental sampling stations and monitoring locations. 

Further, Section 6.1.1 describes the sampling media, frequency and analysis types to be performed. 

Radionuclide-Specific Analysis

Radionuclide-specific analyses are performed on selected composited samples as indicated in the ER 

Section 6.1.1. Because uranium in gaseous effluent may exist in a variety of compounds (e.g., depleted 

uranium hexafluoride, uranium oxide, depleted uranium tetrafluoride, and depleted uranyl fluoride, 

effluent data is maintained, reviewed and assessed by the facility’s Radiation Protection Manager to 

assure that gaseous effluent discharges comply with regulatory release criteria for uranium. The REMP 

falls under the oversight of the IIFP Radiation Protection Program. As a matter of compliance with 

regulatory requirements, potentially radioactive effluent from the facility is discharged only through 

monitored pathways. Effluent sampling for the IIFP Facility is designed to determine the quantities and 

concentrations of radionuclides discharged to the environment. Uranium isotopes and daughter products 

are expected to be the prominent radionuclides in the gaseous effluent. Process stacks and air vents are 

sampled continuously through the use of air filters and analyzed in accordance with the State of New 

Mexico Air Quality Permit. Samples for gross alpha/beta and isotopic analysis are composited and 

analyzed quarterly. 

Facility preventive maintenance procedures will be specified to be maintained on-site and implemented. 

These preventive maintenance procedures and the associated configuration management for these 

procedures are described in LA, Revision B Chapter 11 “Management Measures” Section 11.2.2. 
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Monitoring reports show the quantities of individual radionuclide(s) estimated on the basis of methods 

other than direct measurement and include an explanation and justification of how the results were 

obtained. Monitoring reports are discussed below in “Reporting Procedures.” 

Radionuclide analysis may be performed more frequently at the beginning of the monitoring program 

until a predictable and consistent composition is established. Likewise, the analysis frequency may be 

increased when there is a 50% increase in gross radioactivity in effluents or a process change or other 

circumstance that might cause a significant variation in the radionuclide composition. 

Minimum Detectable Concentrations

ER, Revision B Chapter 6 Section 6.1.1 describes the gaseous effluent monitoring requirements for the 

facility. A minimum detectable concentration (MDC) of at least 3.7x10-11 Bq/ml (1.0x10-15 μCi/ml) will 

be required for all gross alpha analyses performed on gaseous effluent samples. 

Laboratory Quality Control

Monitoring and sampling activities, laboratory analyses and reporting of facility-related radioactivity in 

the environment are conducted in accordance with industry-accepted and regulatory-approved 

methodologies. The Quality Control (QC) procedures used by the laboratories performing the 

environmental monitoring are adequate to validate the analytical results and to conform to the guidance in 

Regulatory Guide 4.15 “Quality Assurance for Radiological Monitoring Programs” (NRC, 2006). These 

QC procedures include the use of established standards such as those provided by the National Institute of 

Standards and Technology (NIST) as well as standard analytical procedures such as those established by 

the National Environmental Laboratory Accreditation Conference (NELAC). 

Action Levels

Administrative action levels are established for effluent samples and monitoring instrumentation as an 

additional step in the effluent control process. All action levels are sufficiently low so as to permit 

implementation of corrective actions before regulatory limits are exceeded. Action levels will be set at 

50% of the 10 CFR 20 Appendix B Table 2 values. Effluent samples that exceed the action level are cause 

for an investigation into the source of elevated radioactivity. Processes are designed to include, when 

practical, provision for automatic shutdown in the event action levels are exceeded. 

Federal and State Standards for Discharges

New Mexico Statutes Annotated (NMSA), Chapter 74, “Environmental Improvement,” Article 2, “Air 

Pollution,” (NMSA, 2009a) and implementing regulations in the New Mexico Administrative Code 

(NMAC) Title 20, “Environmental Protection,” Chapter 2, “Air Quality,” (NMAC, 2009a) establish airquality standards and permit requirements prior to construction or modification of an air-contaminant 

source. IIFP defines an air-contaminant source as any building, structure or facility, or combination 

thereof, which emits or is capable of emitting air contaminants to the atmosphere that are regulated by 

federal, state and local requirements. These regulations also define requirements for an operating permit 

for major producers of air pollutants and impose emission standards for hazardous air pollutants. 

Accordingly, IIFP will file applications and obtain appropriate air construction and operating permits, 

where applicable. The IIFP Environmental Report Revision B Chapter 1 Table 1-9 addresses applicable 

regulatory requirements and status. 
LA-IFP-001 Revision B CHAPTER 9 November 4, 2011 

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40 CFR 122, “National Pollutant Discharge Elimination System,” (NPDES) “General Permit for 

Industrial Stormwater” (EPA, 2009) is required for point source discharge of storm water runoff from 

industrial or commercial facilities to the waters of the state. All new and existing point source industrial 

storm water discharges associated with industrial activity require a NPDES Stormwater Permit from the 

EPA Region 6 and an oversight review by the New Mexico Water Quality Bureau. Most common is a 

general permit which is available to almost any industry, but there is also an option to obtain an individual 

NPDES permit. IIFP will file and obtain a Storm Water Permit prior to pre-license construction or full 

construction in accordance with the EPA and state requirements. 

NMSA, Chapter 74, Article 6 “Water Quality” (NMSA, 2009b) and implementing regulations found in 

NMAC Title 20, Chapter 6 “Ground and Surface Water Protection” (NMAC, 2009b) establishes waterquality standards and applies to permitting prior to construction, during operation, closure, post-closure 

and abatement, if necessary. Generally, a permit is required for discharges that could impact surface or 

groundwater. Any impoundments for sewage treatment facilities, cooling water or other discharges that 

exceed the standards listed in 20.6.2.3103 NMAC or contain toxic constituents require a permit. IIFP is 

working with the State of New Mexico to obtain a Groundwater Discharge Permit and to determine if any 

other related permitting requirements prior to construction or operation, as applicable. 

Leakage Detection Systems

The design status of leak detection (and mitigation procedures) for basins and tanks has not yet 

progressed to final design. The facility conceptual design does include appropriate spill and leak control 

pads and containment dikes. The IIFP Facility will conform to leak detection recommendations in 

NUREG-1520, “Standard Review Plan for the Review of a License Application for a Fuel Cycle 

Facility,” (NRC, 2002). Permits, if any, will be obtained through the State of New Mexico for 

requirements on design, leak detection, monitoring and maintenance of the Storm Water 

Retention/Evaporation Basins. 

Releases to Sewer Systems

All liquid process effluents are to be maintained on the IIFP New Mexico Site. In lieu of connecting to the 

local sewer system, sanitary waste is routed to the sanitary treatment system for primary and secondary 

treatment. After removal of the biomass, the liquids are sand-filtered, treated by ultraviolet radiation as 

tertiary treatment and rendered suitable for on-site silvaculture purposes. The biomass is shipped off-site 

to an approved disposal facility. 

Reporting Procedures

Effluent recording procedures implement the guidance specified in Regulatory Guide 4.16 (NRC, 1985). 

The semi-annual effluent record contains the concentrations of principle radionuclide(s) released to 

unrestricted areas in liquid and gaseous effluents and includes the MDC for the analysis and the error for 

each data point. 

Waste Management Procedures

The design of the IIFP Facility includes treatment of fluoride-bearing waste liquors to regenerate 

solutions for reuse and recycle in the Plant KOH Scrubbing System. Relatively small volumes of 

miscellaneous waste liquors that have potential to contain uranium are concentrated, filtered and the 

uranium is removed from the liquid steams. The removed uranium is collected and sent to a licensed low-
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level waste (LLW) disposal site along with the waste uranium oxides produced by the de-conversion 

processes. The IIFP ER, Revision B Chapter 4 Subsection 4.13.4.3 and Section 4.13.5 provides an 

overview of the liquid waste treatment systems. 

Solid waste management facilities with sufficient capability to enable preparation, packaging, storage and 

transfers to licensed disposal sites in accordance with the regulations are incorporated into the IIFP 

Facility design and are maintained in proper operating condition as required to support the operation of 

the facility. Waste management procedures and processes are performed in various buildings and areas of 

the IIFP Facility depending on the locations and characteristics of the waste stream. The main buildings 

involved are the FEP Process Building, FEP Oxide Staging Building, Decontamination Building, 

Environmental Protection Process Building and the Material Warehouse. These major buildings and areas 

are either described below or in detail in Sections of the IIFP LA, Revision B Chapter 1 “General 

Information” and the ISA Summary Section 2. 

The locations of the buildings and areas discussed below are shown in the IIFP License Application, 

Revision B Chapter 1 Figure 1-5. A larger and more legible site drawing showing the subject buildings 

and locations is provided as Drawing 100-C-0001, Revision F and is part of the engineering drawing 

package provided to the NRC as separate document files of the IIFP License Application. The subject 

building sizes are provided in Table 1-2, Revision B Chapter 1 of the LA. 

Table 1-3, Revision B Chapter 1 of the LA shows the estimated annual quantity of waste generated at the 

IIFP Facility. The largest amount of solid waste generated is the depleted uranium oxide that is a byproduct of the FEP process. This uranium oxide waste is managed using the equipment and facilities of 

the FEP Process Building and the FEP Oxide Staging Building. The depleted uranium oxide from the FEP 

process is collected in the oxide storage hopper for temporary storage until it is packaged for shipment. 

The depleted uranium oxide by-product is filled into Department of Transportation (DOT) approved 

drums (or other approved transport containers). The depleted oxide is filled into the packaging container 

using an enclosed filling (drum off) station located in the FEP Process Building. The oxide hoppers and 

the drum-off stations are located on the first level of the building. The filling station enclosure is 

connected to the FEP oxide dust collection system to provide negative pressure in the enclosed filling 

station to contain and capture dust during the filling process. After filling, the uranium oxide shipping 

containers are then checked, labeled and staged temporarily in the FEP Oxide Staging Building for 

scheduled loading and shipment by trailer truck to a licensed disposal site. The FEP Oxide Staging 

Building is adjacent to, and on the east side of, the FEP Process Building. The wall between the FEP 

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

is a two (2)-level building with a reinforced concrete floor on the first level with containment-type 

curbing. It is used for staging of oxide waste containers for loading into truck trailers and transporting to 

an off-site licensed waste disposal facility. Equipment in the building consists of weighing equipment, 

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

and ductwork connections to the primary dust collector system. 

The Decontamination Building serves as a facility with equipment to manage LLW other than the 

depleted uranium oxide waste. The Decontamination Building is located adjacent to, and on the north side 

of, the DUF4 Process Building. The construction provides for a fire barrier between the Decontamination 

Building and the DUF4 Process Building. This building is used for decontamination of equipment for 

maintenance and for handling and preparing LLW for shipments. The Decontamination Building contains 

an equipment cleaning booth and hood system, equipment for sorting and packaging LLW and mixed dry 

solid waste, loading station, weighing scales, drying equipment, primary and secondary dust collector 

system in series, contaminated-water holding tanks, primary and polishing filters, associated pumps, 
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piping, field equipment instrumentation panels, ion exchange columns and associated controls and 

backwash systems. 

Radioactive waste, including dust collector bags, ion exchange resin, crushed-contaminated drums, 

contaminated trash and contaminated carbon-bed trap material is collected in labeled containers in each 

radiological controlled area and transferred to a temporary radioactive waste storage area located in the 

Decontamination Building. In this area, LLW is sorted, if needed, prepared, packaged and surveyed. 

Suitable waste is volume-reduced using compaction equipment, if feasible. The LLW is loaded and 

transported for disposal at an off-site licensed disposal facility. 

Also in the Decontamination Building, relatively small volumes of miscellaneous waste liquors that have 

potential to contain depleted uranium are concentrated, filtered and treated to remove the depleted 

uranium from liquid steams. Depleted uranium removed from liquid streams is collected and dried for 

volume reduction to meet acceptance criteria. This dried solid waste is sent to an off-site licensed LLW 

disposal site along with the waste depleted uranium oxides produced by the de-conversion processes. 

The Environmental Protection Process (EPP) Building and adjacent area is used to treat and manage 

fluoride-bearing waste liquors. The design of the IIFP Facility includes equipment to regenerate spent 

KOH solutions that can be reused and recycled in the Plant KOH Scrubbing System. This design and 

operation eliminates the need to otherwise discharge the flow as treated wastewater and also conserves 

the use of the treating agent and saves cost. Also, aqueous waste solutions that are not licensed material, 

but contain fluoride or trace metals, are treated in the EPP. 

The treatment of fluoride-bearing liquors results in a solid particulate calcium fluoride (CaF2) which may 

be sold as a raw material for use in the fluorine chemical industry. Converting the fluoride in the subject 

liquors to a solid is the means by which fluoride wastes are managed with potential use as a resource in 

other industrial markets. The treatment process, preparation and packaging procedures for the CaF2 are 

conducted in the EPP Building and adjacent area. In this area, the CaF2 is filtered from the process and 

dried for shipment to customers, where there is a demand, or shipped to an approved off-site disposal site 

if there is no feasible market demand. The EPP Building and equipment is described in the IIFP LA, 

Revision B Chapter 1 Section 1.1.2.1 and in the ISA Summary, Revision B Section 3.1.8. 

The Material Warehouse is located just northeast of the Process Offices and Laboratory Building. This 

warehouse is used to receive and store such items as piping components, electrical conduit, wiring, 

equipment for capital construction projects and spare parts. Small quantities of chemicals such as paints, 

oils and cleaning agents may be stored in the warehouse. No licensed materials are stored in this building. 

Part of the Material Warehouse is used for managing non-radioactive waste. Designated areas inside the 

Material Warehouse and some collection containers on the adjacent outside curbed concrete pads are used 

to collect, sort, package, if necessary, and load non-radioactive waste. This waste has been segregated and 

surveyed to be determined as non-radioactive prior to moving to the Material Warehouse area. Waste sent 

to this area must be approved for release to licensed commercial disposal or recycling. This waste 

includes industrial non-radioactive wastes, such as cardboard, paper, wood, scrap metal, etc. Some of 

these wastes, such as cardboard, paper and metal may be shipped to off-site facilities for recycle or 

minimization, and, then sent, if required, to an off-site licensed waste disposal facility. 

One area in the warehouse is designated for these types of wastes. Another area in the warehouse is set 

aside to manage small quantities of RCRA waste that is not otherwise handled at the EPP. The RCRA 
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waste is packaged, labeled, manifested and loaded for shipment. A permitted transport contractor is used 

to transport the waste to a permitted RCRA facility for disposal. 

9.2.2.2 Environmental Monitoring 

The following sections address the acceptance criteria related to environmental monitoring. 

Background and Baseline Measurements 

The Radiological Environmental Monitoring Program at the IIFP Facility establishes a process for 

collecting data for assessing radiological impacts on the environs. The REMP includes the collection of 

data prior to operating the facility in order to establish baseline radiological information that will be used 

in determining and evaluating impacts from operations at the plant on the local environment. The REMP 

will be initiated at least twelve (12) months prior to facility operations in order to develop a sufficient 

database. Samples will be collected from the site and analyzed to determine a baseline to be used in 

evaluating changes in potential environmental conditions caused by facility operations. Vegetation and 

soil samples, both from on and off-site locations will be collected on a quarterly basis in each sector 

during the pre-operational REMP. Air and water samples will be collected from remote locations in order 

to provide background data during operations. 

Monitoring 

The following sections describe the types of monitoring to be performed. 

Direct Radiation 

Direct radiation monitoring of the stored DUF6 cylinders will be accomplished by use of environmental 

thermoluminescent dosimeters (TLDs) placed at the facility perimeter fence line and other location(s) 

close to the DUF6 cylinders and sources. 

Air 

Air samples will be collected at locations that are close to the facility that would provide the best 

opportunity to detect and identify facility-related radioactivity in the ambient air. Air monitoring stations 

will be located along the fence perimeter, next to the Storm Water Retention Basins, at the nearest 

resident and at a “control comparative” location. The control sample location will be established beyond 5 

km (3.1 mi) in an upwind sector. Air samplers will operate on a continuous basis. 

Vegetation and Soil 

Vegetation and soil samples both from on and off-site locations will be collected in five different sectors. 

Vegetation samples may include vegetables and grass, depending on availability. Soil samples will be 

collected in the same vicinity as the vegetation samples.

Groundwater 

Groundwater samples from monitoring wells will be collected. Two or three wells are expected to be 

located down gradient to the facility of which one well may be located on the southeast side of the Full 
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DUF6 Cylinder Storage Pad. As many as four up-gradient wells may be needed along the east and 

northeast side of the IIFP Facility. The final number of wells and locations will be consistent with the 

New Mexico Groundwater Discharge Permit that will be approved and issued to the IIFP Facility. 

Sediment 

Sediment samples will be collected from the storm water runoff retention basis on site in accordance with 

the New Mexico Groundwater Discharge Permit to monitor for any buildup of uranic material being 

deposited. 

Storm Water

Storm water samples will be collected from the site Storm Water Retention Basin (s) and the DUF6 

Cylinder Storage Pads Basin in accordance with the New Mexico Groundwater Discharge Permit. Storm 

water monitoring is discussed in the IIFP ER, Revision B Section 6.2.4. 

Sampling Locations and Frequencies

Table 6-2 of the IIFP ER, Revision B Chapter 6 summarizes the radiological site area sampling locations, 

frequencies and type of analysis to be performed for each sample type described. The exact locations will 

be finalized with the completion of final site design. Section 6.1 of the Chapter 6 discusses the site area 

radiological monitoring.

Monitoring Procedures

Monitoring procedures will employ well-known acceptable analytical methods and instrumentation. The 

Instrument Maintenance and Calibration Program will be appropriate to the given instrumentation in 

accordance with manufacturers’ recommendations. 

IIFP will ensure that the on-site laboratory and any contractor laboratory used to analyze IIFP samples 

participates in third-party laboratory inter-comparison programs appropriate to the media and analytes 

being measured. IIFP will require that all radiological and non-radiological laboratory vendors are 

certified by the National Environmental Laboratory Accreditation Program (NELAP) or an equivalent 

state laboratory accreditation agency for the analytes being tested.

Action Levels

Action levels will be established to identify concentrations at which an investigation will be performed, as 

well as levels at which process operations would be shut down. Action Levels for vegetation, soil, 

groundwater, sediment and storm water samples will initially be set at twice background. Action levels 

for direct radiation monitoring samples will initially be set at 10% of the 10 CFR 20 dose limits to the 

public. Action levels for air monitoring will initially be set at 1% of the 10 CFR 20 Appendix B values. 

Action levels will be reviewed and adjusted annually as necessary. 

Minimum Detectable Concentration

Minimum Detectable Concentrations (MDCs) will be specified for sample analysis on the basis of the 
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action levels. The environmental MDCs will at least be as low as those selected for effluent monitoring in 

air, 3.7x10-11 Bq/ml (1.0x10-15 μCi/ml). 

Data Analysis

As specified in approved written procedures, data analysis methods and criteria used in evaluating and 

reporting the environmental sampling results will be appropriate and indicate when an action level is 

being approached in time to take corrective actions. 

Status of Licenses, Permits and Approvals

The federal, state and local requirements for environmental monitoring are followed in accordance with 

the licenses and permits described above in Section 9.2.2.1 “Federal and State Standards for Discharges.”

Monitoring for “High” and “Intermediate” Consequence Accidents

Based on the consequence analysis discussed in Section 9.2.3 below, the ISA did not identify any 

accidents that resulted in “High” or “Intermediate” consequences with respect to environmental impact. 

The REMP will be utilized for assessing impacts to the environment from potential radioactive and nonradioactive releases. 

9.2.3 Integrated Safety Analysis 

IIFP has prepared an Integrated Safety Analysis Summary in accordance with 10 CFR 70.62, “Safety 

Program and Integrated Safety Analysis” (CFR, 2009f), which includes the evaluation of high and 

intermediate consequence events involving releases of radioactive material to the environment. Accident 

sequences that could result in radiological or non-radiological releases to the environment are described in 

the ISA Summary, Revision B Section 3 “Processes, Hazards and Accident Sequences.” Demonstration 

of compliance provided in Section 4 of the ISA Summary Revision B. Section 5 of the ISA Summary 

Revision B details the Process Hazard Analysis methodology. 

Table 5-10, “Risk Matrix and Risk Index Values” in the ISA Summary, Revision B depicts the matrix for 

the Severity of Consequences and Likelihood of Occurrences. Items Relied on for Safety (IROFS) are 

established for any accident for which the Risk Index is greater than 4. Consequence categories are 

determined for environmental exposure by comparison of the 24-hour averaged release of radioactive 

materials outside the restricted area to 5000 times the values in Table 2 of Appendix B to CFR Part 20. If 

an accidental release results in concentrations exceeding this metric, the accident is assigned a 

consequence category of intermediate. If the likelihood category of the accident is greater than 2 (not 

unlikely), then IROFS would be assigned to lower the Risk Index to 4 or less. There were no accident 

sequences identified which resulted in concentrations exceeding the environmental performance metric 

therefore, no IROFS were designated for accidental releases on the environment outside the IIFP Site 

boundary. 
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CFR, 2009c Title 10, Code of Federal Regulations, Section 20, "Standards for Protection Against 

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CFR, 2009d Title 10, Code of Federal Regulations, Section 20.1406, "Minimization of 

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NRC, 1993 Regulatory Guide 8.37, "ALARA Levels for Effluents from Materials Facilities," U.S. 

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LA-IFP-001 Revision B CHAPTER 9 November 4, 2011 

Page | 9-27

NRC, 1996 Regulatory Guide 4.20, "Constraint on Releases of Airborne Radioactive Materials to the 

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NRC, 2002 NUREG-1520, "Standard Review Plan for the Review of a License Application for a 

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