May 3, 2011 

Mr. John J. Miller, CHP 

International Isotopes, Inc. 

4137 Commerce Circle 

Idaho Falls, ID 83401 

SUBJECT: U.S. NUCLEAR REGLATORY COMMISSION’S POSITION ON INTERNATIONAL 

ISOTOPES, INC.’S, REQUEST FOR 40-YEAR LICENSING TERM FOR THE 

INTERNATIONAL ISOTOPES FLUORINE PRODUCTS’S PROPOSED FLUORINE 

EXTRACTION PROCESS AND DEPLETED URANIUM DE-CONVERSION PLANT 

Dear Mr. Miller: 

We received your letter, dated March 7, 2011, in which you requested a 40-year licensing term 

for the International Isotopes Fluorine Products’s (IIFP) proposed Fluorine Extraction Process 

and Depleted Uranium De-conversion Plant. 

In the Staff Requirements Memoranda (SRM) to SECY-06-0186, the Commission approved the 

staff’s recommendation to implement maximum license terms of up to 40 years. This term can 

be considered for new applications which implement an integrated safety analysis (ISA), as 

required by Title 10 of the Code of Federal Regulations (10 CFR) Part 70, Subpart H. 

International Isotopes, Inc. is required to comply with ISA requirements in 10 CFR Part 70, 

Subpart H, as stated in SRM to SECY-07-0146. The 10 CFR Part 40 is also undergoing 

rulemaking to incorporate similar ISA requirements, see SRM to SECY-10-0128. Once 

approved, these ISA requirements will apply to the IIFP facility. Therefore, the U.S. Nuclear 

Regulatory Commission’s (NRC’s) staff agrees that the IIFP facility may be granted up to a 

40-year licensing term, provided the license application is approved and a license has been 

issued. 

In accordance with 10 CFR 2.390 of the NRC’s “Rules of Practice,” a copy of this letter will be 

available electronically for public inspection in the NRC Public Document Room or from the 

Publicly Available Records System component of the NRC’s Agencywide Documents Access 

and Management System (ADAMS). ADAMS is accessible from the NRC Web site at 

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
J. Miller - 2 - 

If you have any questions regarding this matter, please contact me at 301-492-3566 or via 

e-mail to Maria.Guardiola@nrc.gov. You may also contact Matthew Bartlett at 301-492-3119 or 

via e-mail to Matthew.Bartlett@nrc.gov. 

Sincerely, 

/RA/ 

 Maria Guardiola, Project Manager 

 Conversion, Deconversion 

 and Enrichment Branch 

 Division of Fuel Cycle Safety 

 and Safeguards 

Office of Nuclear Material Safety 

 and Safeguards 

Docket No. 40-9086
J. Miller - 2 - 

If you have any questions regarding this matter, please contact me at 301-492-3566 or via 

e-mail to Maria.Guardiola@nrc.gov. You may also contact Matthew Bartlett at 301-492-3119 or 

via e-mail to Matthew.Bartlett@nrc.gov. 

Sincerely, 

/RA/ 

 Maria Guardiola, Project Manager 

 Conversion, Deconversion 

 and Enrichment Branch 

 Division of Fuel Cycle Safety 

 and Safeguards 

Office of Nuclear Material Safety 

 and Safeguards 

Docket No. 40-9086 

DISTRIBUTION: 

CDEB r/f AMalliakos INIS Web site - YES 

ML111170661 

OFFICE NMSS/FCSS/CDEB NMSS/FCSS/CDEB NMSS/FCSS/CDEB NMSS/FCSS/CDEB 

NAME MGuardiola MBartlett LAllen DMorey K. Mattern for 

DATE 5/3/11 5/3/11 5/3/11 5/3/11 

OFFICIAL RECORD COPY